On an on-going basis, we track human rights issues and emerging

risks by monitoring industry, thought leaders, and civil society reports

and trends (e.g., Fair Labor Association (FLA), American Apparel and

Footwear Association (AAFA), Sustainable Apparel Coalition (SAC),

Better Work, International Labour Organization, Organisation for

Economic Co-operation and Development) and utilize tools such as

BSI’s SCREEN. Annually, we refine our risk criteria and evaluate

thresholds across three key risk categories: (1) country-level risk; (2)

worker-type risk and (3) process risk. We use the results to update our

processes and due diligence approach. On-the-ground findings from

our teams also trigger updates to our risk assessments. (p.3)