Summary of Results
As the second-lowest scoring theme and one that is critical to reducing instances of forced labor in supply chains, engagement with supply chain workers is an area where the industry needs to significantly improve, not least as engagement with workers can help identify, resolve and prevent labor abuses in the supply chain that traditional monitoring systems do not catch.
Seven companies communicate their human trafficking and forced labor policies and standards to workers in their supply chains. Most companies do so by posting posters of their code in local languages at suppliers' factories. Notably, to improve the effectiveness of this process, adidas provides supporting guidance, such as SMS messaging services and trainings, tailors information such as booklets and videos to focus on local labor laws, and communicates with factories who employ foreign workers. Another example is Primark, which empowers supply chain workers to take ownership of the company's code (e.g., through role play, facilitation by local NGOs, and peer-to-peer learning at factories in India, China, and Bangladesh). Primark publishes its code of conduct in 39 languages on its website, covering all major languages used at its production facilities, and requires suppliers to communicate its code to workers. Ten additional companies make their policies and standards available in the languages of suppliers' workers.
It is encouraging that five companies provide at least limited details on engaging workers outside of the context of the factories in which they work in a manner that may give more voice to workers, a practice rarely seen in other sectors.
Equally encouraging is that, where there are regulatory constraints on freedom of association, three companies encourage suppliers to ensure workplace environments in which workers are able to pursue alternative forms of organizing. Two additional companies provide examples of engaging suppliers on this issue.
While company-level grievance mechanisms are common, only 11 companies have a grievance mechanism for suppliers' workers in place, and only seven disclose ways in which the mechanism is made accessible to workers in their supply chains (e.g., the mechanism is available in workers' languages). Five companies ensure that the existence of the mechanism is proactively communicated to suppliers' workers, for example by posting the grievance mechanism details in factories, by providing training on the use of the mechanisms, or by providing relevant contact details directly or via SMS systems to workers. Further, four companies require suppliers to have in place a grievance mechanism for workers and to convey this same requirement to their suppliers. Seven companies are members of the Fair Labor Association and therefore third parties such as suppliers' workers have access to the FLA's Third Party Complaint procedure.
While most grievance mechanisms tend to focus on factory level, VF states that all worker communities, including tier 2 and tier 3 suppliers' workers, have access to VF's Ethics Helpline, and that suppliers are encouraged to establish their own grievance mechanisms. In addition to establishing a grievance mechanism, H&M provides its contact information to workers in its supply chain so that they are able to report complaints directly to the company. Notably, H&M works with local trade unions as grievance channels, whereby trade union representatives are given business cards to distribute to workers. H&M then follows up on the grievances.