EMPTY STATE
COMPARISON TOOL

Foot Locker 12/100

(NYSE:FL) 33 of 43 (2018)

Foot Locker Inc. (Foot Locker), a US-based footwear and apparel retailer, ranks 33rd out of 43 companies and discloses significantly less information on its forced labor policies and practices than its peers. Its score is based on some disclosure on the themes of Commitment & Governance, Purchasing Practices, Worker Voice, and Monitoring. The company is encouraged to improve its performance and disclosure on the themes of Commitment & Governance, Traceability & Risk Assessment, and Recruitment.

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12 /100

2018 Ranking: 33 of 43

HOW DO THEY COMPARE?

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12

The average score for the sector was 37/100 compared to 49/100 in 2016. The number of companies assessed in 2018 increased from 20 to 43. Since 2016, the methodology has been strengthened, making it more difficult for companies to achieve the same score. The 19 companies benchmarked in both 2016 and 2018 saw their average score increase from 49/100 to 56/100, which is significant given the changes to the methodology.

METHODOLOGY

2018

12

The average score for the sector was 37/100 compared to 49/100 in 2016. The number of companies assessed in 2018 increased from 20 to 43. Since 2016, the methodology has been strengthened, making it more difficult for companies to achieve the same score. The 19 companies benchmarked in both 2016 and 2018 saw their average score increase from 49/100 to 56/100, which is significant given the changes to the methodology.

METHODOLOGY

THEME AND INDICATOR SCORE

The benchmark methodology has seven themes, selected to capture the key areas where companies need to take action to eradicate forced labor from their supply chains. There are a total of 23 indicators across the seven themes. For each theme, a company can score a total of 100 points.

Commitment and Governance

This theme evaluates a company's commitment to addressing forced labor, whether it discloses supply chain standards, and to what extent it has management processes and board oversight, training programs, and engagement with stakeholders on forced labor in place.

OVERALL 22
INDICATORS
Commitment
50
Supply Chain Standards
60
Management and Accountability
0
Training
0
Stakeholder Engagement
0

Traceability and Risk Assessment

This theme measures the extent to which a company demonstrates an understanding of its suppliers and their workforce by disclosing relevant information (such as supplier names or sourcing countries) and assesses and discloses forced labor risks across its supply chains.

OVERALL 0
Traceability
0
Risk Assessment
0

Purchasing Practices

This theme assesses to what extent a company adopts responsible purchasing practices (such as providing price premiums and procurement incentives) and integrates supply chain standards into supplier selection and supplier contracts, and whether it cascades them down the supply chain.

OVERALL 31
Purchasing Practices
0
Supplier Selection
25
Integration into Supplier Contracts
0
Cascading Standards through the Supply Chain
100

Recruitment

This theme measures a company's approach to reducing the risk of exploitation of supply chain workers by recruitment agencies, eliminating workers' payment of fees during recruitment processes throughout its supply chains, and protecting the rights of migrant workers.

OVERALL 0
Recruitment Approach
0
Recruitment Fees
0
Monitoring and Ethical Recruitment
0
Migrant Worker Rights
0

Worker Voice

This theme measures the extent to which a company engages with workers in its supply chains, enables freedom of association, and ensures access to effective and trusted grievance mechanisms.

OVERALL 13
INDICATORS
Communication of Policies
50
Worker Voice
0
Freedom of Association
0
Grievance Mechanism
0

Monitoring

This theme evaluates a company's process for auditing suppliers, including whether audits include non-scheduled visits, review relevant documents such as wage slips or contracts, interview workers, and audit lower-tier suppliers and provide disclosure on the outcomes of supplier audits.

OVERALL 15
Auditing Process
30
Audit Disclosure
0

Remedy

This theme measures the extent to which a company has corrective action plans and processes for non-compliant suppliers and ensures remedy is provided to workers in its supply chains who are victims of forced labor. Publicly available allegations of forced labor in a company's supply chains that occurred in the past three years, and how a company has responded to and addressed those allegations, are also assessed as part of this theme.

OVERALL 0
Corrective Action Plans
0
Remedy Programs and Response to Allegations
0

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