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Global brands remain under increasing pressure to ensure labor standards and codes of conduct are met by their suppliers. Little is known about how this is addressed by lower tier suppliers. We investigate whether, and how, occupational health and safety standards permeate down the computer industry value chain. We compare first and second tier suppliers' engagement with a private voluntary industry code, the Electronic Industry Code of Conduct, and the publicly regulated European Union Directive on the Restriction of Hazardous Substances. We find the industry code absent at the lower tier, yet second tier suppliers do implement the European Union Directive. This is achieved without support from public agencies or global value chain linkages. Our findings question the emphasis placed on chain governance in studies of labor compliance in global value chains, and suggest that alternative and complementary approaches may be required for effective labor compliance throughout the value chain.

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