CALIFORNIA DISCLOSURE
In September of 2010, the state of California enacted legislation
requiring
all companies doing business in the state to disclose information on the actions being taken to
address the risks of human trafficking and slavery in their global supply chains. Shown below
are
Carhartt's responses to the five required disclosures outlined in the legislation:
-
All factories producing goods for Carhartt are required to comply
with
the Company's Workplace Code of Conduct, which includes a specific "prohibition of
involuntary,
prison, or forced labor - indentured, bonded or otherwise" and a methodology to verify
compliance with labor standards. All suppliers also are expected to meet the standards of
the
US Customs-Trade Partnership Against Terrorism (C-TPAT), including recommended safeguards
protecting against the introduction of non-manifested cargo. These expectations extend to
all
sub-contractors. Verification takes place through third-party assessment of responsible
labor
conditions, using the Worldwide Responsible Accredited Production (WRAP) protocol, or a
similar
third-party factory certification approach.
Responsible labor practices are confirmed through third-party factory
assessments, using the Worldwide Responsible Accredited Production (WRAP) social audit
protocol, or a similar third-party factory certification approach. Supplier audits are
conducted by reputable third-party assessment firms and are unannounced within a 30-day
window.
These audits evaluate present factory conditions as well as the policies, procedures and
management systems which are necessary for ongoing compliance.
-
Carhartt's Workplace Code of Conduct requires all of our suppliers to
comply fully with all local laws, including those related to slavery and human trafficking.
In
the event local laws are not robust, Carhartt's Workplace Code of Conduct further prohibits
suppliers from using "involuntary, prison, or forced labor - indentured, bonded or
otherwise."
Suppliers certify that they understand and comply with these expectations before starting
Carhartt production and periodically thereafter.
Responsible labor conditions have been a core value at
Carhartt for more than 125 years. Internal accountability resides with the leadership of the
core business functions responsible for the relevant commercial relationships - e.g., the
Sourcing function for all relationships with cut and sew suppliers and the Licensing
Department
for all license agreements. All Carhartt contractors and licensees must adhere to our Code
and
maintain appropriate third-party certifications.
If an audit demonstrates that a
contractor
does not comply with Carhartt's Code of Conduct, we take appropriate remedial action. While
we
prefer to work with contractors to achieve improved conditions, violations involving human
trafficking or slavery would be considered "zero tolerance" issues that must be immediately
corrected or Carhartt would act to terminate the contractual relationship.
-
With support from WRAP, Carhartt has conducted training on the Company's
Workplace Code of Conduct - including provisions related to human trafficking and slavery.
Individuals completing this training include supply chain leadership from the Vice President
through the manager level in our Sourcing and Quality Assurance activities. Select
individuals
in our Customs activity also have completed the training. We are presently in the process of
extending the training to others within our organization.