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Hiring practices

Inadequate hiring practices are one of the most common challenges encountered in the industry. When facilities do not have a formal hiring process and controls in place, they are at higher risk of using unethical practices. ���������ƽ�� expects all facilities to have a functioning human resources department that enforces the policy that no candidate can be hired until approved by human resources. We do not allow exceptions, including those for temporary, migrant and contract workers. During the responsible sourcing audit, personnel records are reviewed and the hiring process is discussed with management.

Through this process, verification of established formal procedures ensuring review of age documentation, vetting of labor brokers and safeguarding of high-risk candidates are undertaken. Maintenance of standard personnel files for all workers where information is readily available is also confirmed. Finally, ���������ƽ�� reviews that all facilities are upholding the , reiterating the expectation that the costs of recruitment are paid by the employer — not the worker. A follow-up audit is conducted to ensure that a formal hiring process has been implemented.

Forced labor

We are committed to working with supply chain partners and industry experts to prevent, identify and eradicate forced labor in our global manufacturing supply chains.

We identify risk of forced labor through our responsible sourcing audit process, audit history and a variety of risk intelligence sources. We also closely monitor and collaborate with NGOs and other brands to identify and mitigate these risks. If we find credible indicators of forced labor at any facility, we prioritize the well-being of the workers, which means that where possible, we strive to frame and implement a corrective action plan that will facilitate the remediation of the indicators and a continuation of the business relationship once remediation is complete. Only when remediation is not possible will we work with the appropriate stakeholders to develop a responsible disengagement strategy whereby we intend to mitigate additional harm to the workers. See our for more information.

Any parties wishing to report concerns related to forced labor at any ���������ƽ�� or ���������ƽ��-affiliated facility may use the ���������ƽ�� Integrity Hotline.

Underage labor 

As articulated in the ���������ƽ�� underage labor policy found in the Standards of Vendor Engagement (SOVE), ���������ƽ�� does not tolerate underage labor practices. We work closely with industry partnerships and multi-stakeholder initiatives alongside peer brands that share the common goal of eliminating underage labor. If underage labor is discovered within our owned brand supply chain, we will do everything possible to protect underage workers from further harm. We also work collaboratively with local partner organizations to develop and implement long-term solutions that support affected individuals and their family.

If the remediation is unsuccessful or not possible, we deactivate the factory for non-compliance. In all cases, we do not accept any merchandise in production if we believe the merchandise was made with underage labor. Additionally, we also partner with in countries where they operate to systematically address underage labor and remediate cases of underage labor when found in the apparel and rug industries, respectively.

Migrant labor 

We expect all workers, including foreign and domestic migrant workers, to be provided wages, benefits and working conditions that are fair, comparable to local workers and in accordance with local law. We do not condone holding workers’ passports or other personal documents, charging any type of fee or deposit for employment, allowing labor agents or brokers to charge fees or engaging in deceptive recruitment practices. We review these policies in detail during our audit process and expect our vendors to share these views and comply.

Discipline 

���������ƽ�� expects that all employees are to be treated with dignity and respect. ���������ƽ�� will not knowingly work with vendors or factories who use physical abuse or intimidation against their workers. Our assessors conduct multiple checks to ensure these practices are not occurring in the facilities, including interviews with employees about working conditions and disciplinary actions. If corporal punishment is identified, we consider it a zero-tolerance violation.

Discrimination 

We respect cultural and individual differences and discrimination is not tolerated. Vendors and factories are expected to maintain a discrimination-free workplace and to employ workers based upon their abilities, rather than their race, color, sex, pregnancy status, gender identity, marital status, political opinions, religion, age, disability, sexual orientation, social origin, national origin or any other characteristics unrelated to an individual’s ability to perform the work required by the job. We also prohibit the use of pregnancy testing as a condition of employment or as a reason to terminate employment.

Working hours and time off 

���������ƽ�� expects a 60-hour maximum work week, including overtime, in all facilities. If local law differs, a facility must follow the stricter requirement. We also expect workers to receive a minimum of one full rest day after six consecutive workdays. We adopted both guidelines from the International Labour Organization. All facilities must use an effective timekeeping system to ensure timecards are accurate and completed by the employees themselves. During an audit, the auditor will review recent payroll records, cross-checking timecards to make sure they are accurate and in accordance with local law and ���������ƽ�� standards. If violations are identified, we consider them critical under the Responsible Sourcing Audit Program.

Excessive working hours is a widespread practice in many parts of the world. Workers often comply in order to earn higher wages but are not always paid the appropriate legal overtime. Many factors lead to excessive working hours, including company purchasing decisions that impact production deadlines. ���������ƽ�� asks vendors to communicate production challenges so that we can partner with sourcing team members to develop solutions and prevent recurrences. 

We consider transparency of paramount importance and in exceptional cases, when facilities demonstrate transparency, we may continue to do business with a factory with excessive overtime violations if it can be established to our satisfaction that the overtime was voluntary, paid at a premium and where a corrective action plan has been agreed to that will eliminate instances of non-compliance in the future. If a facility is not able to meet local law or attempts to circumvent ���������ƽ��'s requirements through falsification, forgery or withholding information, the factory will be deactivated for a minimum of six months.

Payment of wages 

���������ƽ�� has a firm stance on the payment of wages and will not tolerate when factories or vendors do not follow local law and our standards related to the payment of wages.

During an audit, the assessor does a thorough review of timecard and payroll records to ensure workers were paid legal wages for all the hours they worked, including regular, overtime, holiday and vacation wages and that those wages were timely paid. Also during an audit, the assessor discusses the wage policy with management and makes sure employees understand their wages, benefits and deductions. We also make sure they have access to their own records to verify their hours and wages, and that they know with whom to discuss discrepancies. We consider wage violations critical.

Responsible exit and decline  

We have expectations for business partners and internal ���������ƽ�� teams to follow when fully exiting or declining business at a factory location, which we formalized in 2024. We also provided training to more than 1,000 internal team members and more than 2,300 suppliers on these expectations. 

Grievance mechanisms 

We are committed to providing ���������ƽ�� team members, workers in our supply chain, community members and other stakeholders with access to effective grievance mechanisms. We expect our business partners to share any ethical concerns or potential misconduct so that we can investigate and address concerns promptly. These mechanisms are an important aspect of our ongoing human rights due diligence, and our strategic focus on promoting workers’ voices and well-being. We believe the most effective way to ensure respect for human rights and good working conditions is to enable and empower individuals to speak up.

Training, governance & programs 

Our ethics and responsible sourcing and sustainability teams conduct ethics training(s) with business partners worldwide. The trainings promote the ���������ƽ�� Integrity Hotline, a channel available to all team members and supplier workers for confidentially reporting issues related to the SOVE or any other ethical concerns or business misconduct; the call is free and handled by an independent third party, and local language interpreters are available 24 hours a day.

We do not share or publish specific grievances or specific issues raised and do not tolerate any retaliation against any team member who reports in good faith.

Integrity Hotline Numbers

• US: 1-800-541-6838

• India: 000-800-100-1657 

• Reverse Dial: 470-219-7116

In 2022, we partnered with Article One to create an in-depth training experience for our sourcing team members worldwide. The training, provided both as a self-paced e-module and in a train-the-trainer format, covered an overview of business and human rights and ���������ƽ��’s approach, including our human rights statement and business operations and supply chain due diligence efforts intended to deepen understanding of human rights issues and to recognize the importance of having effective grievance mechanisms in place for all workers in our supply chain.

���������ƽ�� continues to explore opportunities to increase awareness and accessibility of reporting options and drive comfort in using the reporting options provided. During 2021, we distributed information on accessing and engaging with ���������ƽ��’s Integrity Hotline to all factory and supplier locations. 

Third-party helplines 

We support suppliers in collecting data on grievance types, resolution and mechanism channels, and through third-party helplines associated with our audit program partners, enhancing effectiveness and worker engagement. Examples of third-party helplines include: 

Grievance lifecycle

Once a grievance is raised, ���������ƽ�� leverages a strict triage process to ensure issues are addressed and/or investigated by the appropriate, qualified team. For supply chain investigations, we use a combination of internal and third-party investigators depending on the issue and region. Complaints received are thoroughly reviewed and investigated. Factories are prohibited from retaliating against third-party workers, who may remain anonymous, for reporting any potential violations of our SOVE. Grievances are managed from intake to resolution. Additionally, we recognize our responsibility to exercise influence through our business relationships and build leverage with others to address issues deeper in our supply chain where we may not have direct business relationships.

This specific analysis of human rights impacts is integrated into our existing routine for handling cases and incidents. To prevent reoccurrence, we have ongoing monitoring programs in place to assess progress, incentivize suppliers that share our ambition for responsible and sustainable business practices through more business, and encourage engagement in various programs at local and global levels.  

Outcomes of remedy 

���������ƽ�� has enacted extensive remediation policies and practices to respond to human rights violations and impacts. When a grievance is identified as founded, ���������ƽ�� will engage with its business partners to remediate any and all adverse impacts. In some cases, we will partner with globally recognized nonprofit organizations such as Verité, Impactt and The Centre for Child Rights and Business to support capability building and remediation of complex workplace human rights issues, to be sure that we are providing the most effective solution. 

Health and safety review  

Health and safety violations have been a major focus of ���������ƽ��'s responsible sourcing audit program. The assessor conducts an in-depth review of a facility’s health and safety practices across all buildings, reviewing fire safety equipment and preparedness to worker safety, such as clean facilities, the availability of personal protective equipment, chemical safety and employee training. An assessor will identify any violations during the tour of the factory and explain procedures for making and sustaining corrections. The assessor also will review health and safety training records and ensure that a facility has a schedule to provide regular training to workers.

���������ƽ�� emphasizes the importance of having measures in place to ensure that factory workers know what to do in an emergency, as well as policies and procedures to prevent emergencies. 

���������ƽ�� was a founding member of the Alliance for Bangladesh Worker Safety. The Alliance, which helped improve fire safety, electrical safety and the structural integrity of buildings, audited all factories used by ���������ƽ�� in Bangladesh. Additionally, the Alliance also provided worker training on fire safety and has launched a help line for workers to express safety concerns in Bangladesh. This health and safety capability building work was taken over by in 2018, of which ���������ƽ�� was a founding board member. NIRAPON seeks to advance health and safety in Bangladesh by promoting safety, systems and education with factories and members.

Sandblasting 

Since 2012, ���������ƽ�� has banned the use of sandblasting on all ���������ƽ��-brand apparel due to health concerns associated with silica exposure. In 2023, we expanded the scope of our policy to include all sandblasting, regardless of the industry or brand. ���������ƽ�� defines sandblasting as any abrasive blasting with a media that contains crystalline silica.

Exceptions may be granted for processes that use a very low-silica content media; when blasting occurs with engineering controls to reduce worker exposure; and when the site has adequate respiratory protection programs including appropriate personal protective equipment, regular air testing and worker medical monitoring appropriate to the hazard. 

Conflict minerals policy 

���������ƽ�� supports the humanitarian goals of the  and recognizes the adverse impact of the mining and trade of columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten (collectively, “3TG”) by armed groups in the Democratic Republic of the Congo and its adjoining countries (the "Covered Countries"). ���������ƽ�� encourages its suppliers to source 3TG responsibly. ���������ƽ�� seeks to neither finance nor benefit those armed groups directly or indirectly. ���������ƽ�� will not knowingly purchase or sell any owned or exclusive brand products that contain 3TG that finances armed conflict in the Covered Countries.

���������ƽ�� also recognizes that there are many smelters and refiners that source from the Covered Countries whose activities do not finance or benefit armed groups and who are certified as “Conformant” by the . In order to avoid the undue harm to local populations that a generalized embargo upon this region could perform, ���������ƽ�� encourages vendors to identify Conformant smelters and refiners within the Covered Countries and to source from them when commercially practicable.

���������ƽ�� requires its owned and exclusive brand product vendors to: 

1. Adopt a policy related to 3TG sourcing that is consistent with ���������ƽ��’s Conflict Minerals Policy and the , including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold.
2. Complete a , which is the standard form developed by RMI for gathering information regarding 3TG usage and related sourcing procedures.
3. Exercise due diligence in seeking upstream information to support vendor responses to the questions in the .
4. Use smelters and refiners certified by RMI as "Conformant," but avoid a generalized embargo on smelters and refiners in the Covered Countries.
5. Make available the due diligence used in determining the source of its 3TG upon ���������ƽ��’s request.

���������ƽ�� continues to be engaged with multi-stakeholder initiatives that encourage responsible 3TG sourcing and is a member of and participates in the RMI.

Cotton Origin Policy 

���������ƽ�� does not knowingly buy or sell products that are made, in whole or in part, using forced or underage labor. Moreover, our vendors and their suppliers are prohibited from using forced or underage labor to produce their goods for ���������ƽ�� in accordance with the requirements of ���������ƽ��'s SOVE. Additionally, ���������ƽ�� may choose to prohibit the use of cotton from certain geographies in ���������ƽ�� products due to consumer preferences, sustainability considerations, supply chain instability or other economic reasons.

���������ƽ�� does not accept:

• Products containing Turkmen cotton, regardless of where produced; and
• Products containing cotton originating in the Xinjiang province of China, regardless of where produced.

���������ƽ�� continually monitors and assesses risks associated with, among other things, certain products, various raw materials and regions of production. As a result, our sourcing policies are subject to change at any time and in ���������ƽ��'s sole discretion. Products in violation of ���������ƽ��’s sourcing policies, including the use of cotton violating this policy, constitutes a breach and entitles ���������ƽ�� to exercise any potential remedy available to ���������ƽ�� under the Conditions of Contract, including but not limited to order cancellation.