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Even beyond these specific cases, the Company uses a "trust but verify" approach with respect to its vendors, mills, and factories (described in detail above in How We Minimize Risk Using Internal and External Resources). Therefore, regardless of the country in which sourcing or manufacturing occurs, the Company's partners and their downstream partners are held to an independent standard in labor practices which exceeds legal compliance

If any labor issues are uncovered during an audit, the factory must take immediate steps to correct the problem. This begins with creating a corrective action plan within 30 days. The vendor then comes under Company conservatorship to ensure there are no recurrences, which requires regular updates on the corrective measures taken, as well as photographic evidence.4

During the life of the partnership, the factory not onlyreceives audits as described above, but product is inspected for compliance with our regulatory and quality standards. If any factory should fail on any of these indicators and/or refuse to make improvements, the relationship could be terminated.5