companies policies include:
requiring all suppliers and contractors to comply with local and international laws (including the UN Guiding Principles, ILO standards, or International Conventions), and company’s policies,
prohibiting contractors or suppliers from using forced labour
including clauses on forced labour in Codes of Conduct or Supplier Codes P.3-6
'We focus our risk mitigation efforts on our direct (tier 1) suppliers, since this is the level of the supply chain where we believe that we have the most influence and can therefore be the most effective' P.3
'Alignment with International Standards; Policies' P.3
'Employee Code' P.4
'Supplier Code' P.4
'Verification of Product Supply Chains to Evaluate and Address Risks of Modern Slavery' P.5
'We expect our supply chain partners to conduct their operations in line with our robust factory compliance program'
'Before conducting business with us, direct supply chains are screened through our internal risk assessment process to evaluate the risks of modern slavery at the supplier level'
'Certifications' P.5
'Each direct supplier and licensee must certify compliance with the Supplier Code before being awarded new or additional business with us' P.6
'Audits' P.6
'As part of our factory compliance program, all direct suppliers must register their factories and facilities with our factory compliance team, indicating the locations of those facilities and authorizing us to conduct compliance audits'
'During the on-site audit, the independent third-party auditor will visit and inspect the facility, conduct interviews with supervisors, managers and workers at the facility (without supervisors and managers present), and review relevant books and records of the third-party manufacturer' P.6
'On-site audits also include a review of records of all migrant workers at the facility, including, date of arrival, contract terms (including copies of employment agreements), employment history, anticipated and actual date of return, and recruitment fees paid for the last three years (or such longer time period as may be required by law), together with copies of all recruitment agency or labor broker agreements.' P.6
Internal Accountability and Training
'New employees are provided with a copy of the Employee Code upon hire. All employees are required to undergo compliance and ethics training, including with respect to the Employee Code, upon hire, and on a bi-annual basis thereafter' P.7
pg. 4
“The Supplier Code is informed by international standards, and conveys our expectations around wages, benefits and working hours; prison, forced and child labor; freedom of association and disciplinary practices within the supply chain; and other legal requirements and ethical standards that our business partners must abide by, including as further described below.”
“The Supplier Code expressly prohibits the use of any form of slave, forced, bonded, indentured, or prison labor in any stage of the manufacture of our products. The Supplier Code further provides that suppliers must ensure that no fees or costs have been charged, directly or indirectly, in whole or in part, to jobseekers and workers for their services directly related to recruitment for temporary or permanent job placement, including when using the services of private recruiters, labor brokers or employment agents or performing recruitment activities directly.”
Pg. 5
“The Supplier Code is a critical part of our factory compliance program, communicated during direct supplier onboarding and regularly thereafter, and forming the basis of our third-party audits. Our third-party manufacturing contractors are responsible for ensuring their factories, workers, subcontractors and business partners (including recruitment agencies and labor brokers) involved in our operations comply with the Supplier Code.”
'Suppliers must also ensure that the third-party recruitment agencies (including labor brokers) they use are compliant with the provisions of the Supplier Code and applicable law and must provide us with a list of the recruitment agencies they are using, and the amount of fees being paid to such agencies.' - 5