'While subcontracting is a common practice in the apparel industry, engaged in by suppliers to manage production capacity and fulfill large orders, it can pose a risk. Unauthorized Subcontracting (UAS) is problematic because suppliers may outsource production to facilities that we have not approved and that do not uphold our requirements for safe, fair labor practices and working conditions. Smaller, unauthorized units may have labor practices that put workers at risk, and are beyond the view of our assessment and remediation team. Expanding the collaboration between our sustainability and sourcing teams can help us address UAS issues since incidents can be difficult to detect through the periodic factory assessments conducted by our sustainability field team. We take extra precautionary measures in countries with high risk of UAS, such as specialized training for suppliers and factory management.'

'In addition to ongoing training, our Assessment & Remediation team convenes regularly to discuss program effectiveness and improvements. In April 2015, based on a thorough risk assessment, we strengthened our Foreign Contract Worker requirements and updated them by providing additional detailed guidance on recruitment, fees, employment contracts, and onsite policies and practices, including equal treatment and non-discrimination. Additionally, we added a requirement for our vendors to conduct due diligence and regular assessments of employment agencies. '