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I. INTRODUCTION As the global supply chains used by multinational enterprises (MNEs) become increasingly complex, brands have turned toward Codes of Conduct (COCs) as tools for maintaining oversight and control [...], Multinational enterprises increasingly use Codes of Conduct to govern the conditions of labor and production among their suppliers' operations around the globe. These Codes of Conduct, produced unilaterally by companies as well as by multistakeholder bodies, often include references to public international law instruments. This article takes a closer look at thirty-eight Codes of Conduct from the global apparel industry and uses social network analysis to identify the patterns in these Codes and how they refer to international legal instruments. Although some international legal instruments stipulate rules that can be directly transposed into the private context of supply chains, this study instead finds that the global apparel industry's Codes of Conduct are more likely to refer to instruments that only stipulate rules that pertain to public authorities. The findings call into question the legitimizing role that international law plays as it is transposed into transnational private governance.