Codes of conduct covering employment conditions of Southern producers exporting to European markets increased dramatically throughout the 1990s. As a result producers of horticulture products are faced with a considerable variety of codes, particularly in terms of what gender issues should be addressed. Some codes integrate a number of international conventions relating to gender inequality and gender discrimination yet other codes make no mention of gender at all. Even where codes address gender issues, their coverage and sensitivity can often be limited. This is also true for the auditing of codes. Similarly, civil society stakeholders involved in the monitoring and verification of codes can sometimes include the representation of women, but elsewhere this may be absent. A more systematic gender analysis of ethical trade is required in order to provide a basis for addressing the civil, economic and social rights of female as well as male workers in relevant export sectors and to enhance policy formulation. The paper focuses on voluntary codes of conduct in three specific commodity groups and countries exporting to EU markets: South African fruit, Kenyan flowers and Zambian vegetables, and was produced following a one year research project into gender and ethical trade in these countries.