Social Compliance

Our Commitment

2017 Highlights

Internal Auditing Methodology

All company-owned and third party contractor facilities are subject to a complete internal audit based on a risk assessment that evaluates country risk, order volume, the facility’s rating and previous audit performance. Internal audits are conducted by regional audit teams that have been thoroughly trained on our monitoring guidelines and social compliance programs. The Company may also mandate third party audit service providers to conduct internal audits, on its behalf, in some regions.

Audits
Audits

In 2017, 238 complete audits were conducted at our owned facilities, third party contractor facilities and select raw material supplier facilities throughout Asia, Central America, the Caribbean Basin and North America. Of these, 148 audits were conducted by our internal auditors or by third party auditors on our behalf and 90 audits were conducted by external auditors mandated by the FLA, Better Work and WRAP or by customers.

FLA, WRAP and Other External audits
FLA, WRAP and Other External audits

External audits are also regularly conducted at company-owned and contractor facilities. These audits are usually conducted by third party monitoring firms, which have been mandated by the Fair Labor Association (FLA), Worldwide Responsible Apparel Production (WRAP), Better Work or by one of our customers.

Remediation of Audit Findings

Following an internal audit at a company-owned or third-party contractor facility, our regional social compliance teams partner with facility managers to make changes and put in place sustainable remediation actions. The Social Compliance Teams also provide advice and recommendations on how best to address certain issues. Following an assessment, a management action plan is developed and shared with the facility. Facilities are expected to implement corrective actions and to demonstrate improvements within a prescribed timeframe.

New and Potential Third Party Contractors

Third party contractors involved in ongoing production of the Company’s orders are regularly assessed for compliance with our Code of Conduct. If a current contractor achieves a low rating following an audit, our internal Social Compliance Team will partner with the facility’s management to remediate any major issues found during the audit with the establishment of an action plan. In addition, systematic follow-ups are conducted to verify progress made towards resolving any pending issues. Our objective is to help the facility improve their overall performance and remain in compliance with our Code of Conduct.

Current Third Party Contractors

Third party contractors involved in ongoing production of the Company’s orders are regularly assessed for compliance with our Code of Conduct. If a current contractor achieves a low rating following an audit, our internal Social Compliance Team will partner with the facility’s management to remediate any major issues found during the audit with the establishment of an action plan. In addition, systematic follow-ups are conducted to verify progress made towards resolving any pending issues. Our objective is to help the facility improve their overall performance and remain in compliance with our Code of Conduct.