APPAREL

Themes Key Findings

2018 Apparel & Footwear

The 43 Apparel and Footwear companies were assessed across the benchmark's seven themes, which were developed to capture the key areas where companies need to take action to eradicate forced labor from their supply chains: commitment and governance; traceability and risk assessment; purchasing practices; recruitment; worker voice; monitoring; and remedy. There are a total of 23 indicators across the seven themes. Each theme is weighted equally and determines the company's overall benchmark score on a scale from 0 to 100.

37

Overall Score 2018 Apparel & Footwear
54 Theme Score

Summary of Results

Companies' disclosure on the theme of Commitment & Governance is relatively strong. Companies that were benchmarked in both 2016 and 2018 have a significantly higher average score of 76/100 for this theme, showing meaningful improvements since the 2016 benchmark. However, there is little disclosure on how companies engage with stakeholders on the issue of forced labor, in particular with local stakeholders in countries where suppliers operate.

Commitment and supply chain standards

Twenty-nine out of 43 companies disclose a commitment to addressing forced labor in their supply chains. More than three-quarters of the companies (33 out of 43) disclose a supply chain standard that prohibits forced labor. Thirty-one companies disclose information on how they communicate that standard to their suppliers. Nike discloses that it communicates any updates to its standards to both first- and second-tier suppliers. Ten companies do not publicly disclose a supply chain standard.

Management and Accountability

More than half of the companies (28 out of 43) disclose a team, program, or officer with responsibility for human rights in their supply chains, with 23 disclosing that this responsibility extends to overseeing their supply chain standard which covers forced labor. Walmart, for instance, reports that it has 190 associates around the world working with suppliers to enforce its supply chain standards. Columbia Sportswear discloses that it has manufacturing liaison offices in eight Asian countries, staffed by its direct employees, which, it states, allows it to oversee production as well as monitor its suppliers' compliance with labor standards. Fewer companies reported on accountability at the board level, with 13 companies disclosing detail on board oversight of their supply chain standards on forced labor.

Training

Thirty-one companies disclose that they deliver training to their employees on forced labor, although only 22 make clear that this training is delivered to procurement and sourcing staff. Half of the companies (22 out of 43) disclose that they train their suppliers on their forced labor policies and risks. Further, 13 companies disclose that such trainings are provided for suppliers in different countries or in different tiers. Six companies (Adidas, Asics, Burberry, H&M, L Brands, and Lululemon) disclose training delivered beyond their first-tier suppliers to their second- or third-tier suppliers. L Brands discloses training delivered to it first-, second-, and third-tier suppliers in China, Vietnam, Hong Kong, and Sri Lanka. Since 2016, companies have also strengthened their training programs for both their own staff and their suppliers. Nine companies (Adidas, Gap, Fast Retailing, Hugo Boss, H&M, L Brands, Lululemon, Nike, and Primark) strengthened the training provided to their internal staff or suppliers. For example, H&M provided modern slavery training to its local sustainability staff in Cambodia and Vietnam, and Gap discloses that it conducted training sessions for its suppliers to provide them with an understanding of recruitment issues. Primark launched a mandatory modern slavery training, which was completed by 95% of its suppliers in 2017.

Stakeholder Engagement

Disclosure on how companies engage with stakeholders on the issue of forced labor is poor. More than half of the companies (27 out of 43) provide some information on engagement with stakeholders. However, only ten companies give examples of working with stakeholders on forced labor in local supply chain contexts, and only seven disclose more than one example of doing so. Nike, for example, discloses that it has engaged with the US embassy in Malaysia, the Malaysian Ministry of Human Resources, and the ILO Malaysia office to learn more about government policies and ILO initiatives which focus on migrant workers. Adidas discloses that it engaged with local and global NGOs and industry coalitions, as well as meat processors, traders, and apparel brands in Brazil to understand the risk of forced labor in leather sourcing from Brazil and Paraguay. Companies benchmarked in both years show improvements in their engagements with stakeholders: six companies provided more information on how they have worked with stakeholders, a number of which reported engaging with the Turkish government or local NGOs to address the risks of exploitation of Syrian refugees.

Twenty-seven companies disclose membership in multi-stakeholder initiatives that focus on eradicating forced labor, but only 14 provide detail on how they actively participate in such memberships. This includes initiatives such as the Fair Labor Association, Better Work, and the Mekong Club. VF discloses that it is a member of the Mekong Club and, through its membership, has been educating workers in factories on the risks associated with using labor brokers. It states it is also working with the Mekong Club to ensure it has a program in place to identify instances of forced labor in its Vietnamese and Chinese supply chains.

Commitment

The company publicly demonstrates its commitment to addressing human trafficking and forced labor.

The company: (1) has publicly demonstrated its commitment to addressing human trafficking and forced labor.

Low: 0
High: 100
79

Supply Chain Standards

The company has a supply chain standard that requires suppliers throughout its supply chains to uphold workers' fundamental rights and freedoms (as articulated in the ILO Declaration on Fundamental Principles and Rights at Work), including the elimination of forced labor. The standard has been approved by a senior executive, is easily accessible on the company's website, is regularly updated, and is communicated to the company's suppliers.

The company's supply chain standard: (1) requires suppliers to uphold workers' fundamental rights and freedoms (those articulated in the International Labour Organization's Declaration on Fundamental Principles and Rights at Work), including the elimination of forced labor; (2) has been approved by a senior executive; (3) is easily accessible from the company's website; (4) is updated regularly, following internal review and input from external stakeholders; and (5) is communicated to the company's suppliers.

Low: 0
High: 100
58

Management and Accountability

The company has established clear responsibilities and accountability for the implementation of its supply chain policies and standards relevant to human trafficking and forced labor, both within the company and at the board level.

The company: (1) has a committee, team, program, or officer responsible for the implementation of its supply chain policies and standards that address human trafficking and forced labor; and (2) has tasked a board member or board committee with oversight of its supply chain policies and standards that address human trafficking and forced labor.

Low: 0
High: 100
50

Training

The company has training programs in place to ensure that relevant decision-makers within the company and its supply chains are aware of risks related to human trafficking and forced labor and are effectively implementing the company's policies and standards.

The company undertakes programs which include: (1) the training of all relevant decision-makers within the company on risks, policies, and standards related to human trafficking and forced labor; and (2) the training and capacity-building of suppliers on risks, policies, and standards related to human trafficking and forced labor, covering key supply chain contexts.

Low: 0
High: 100
51

Stakeholder Engagement

The company engages with relevant stakeholders on human trafficking and forced labor. This includes engagement with policy makers, worker rights organizations, or local NGOs in countries in which its suppliers operate, as well as active participation in one or more multi-stakeholder or industry initiatives.

In the last three years, the company has engaged relevant stakeholders by: (1) providing at least two examples of engagements on forced labor and human trafficking with policy makers, worker rights organizations, local NGOs, or other relevant stakeholders in countries in which its suppliers operate, covering different supply chain contexts; and (2) actively participating in one or more multi-stakeholder or industry initiatives focused on eradicating forced labor and human trafficking across the industry.

Low: 0
High: 100
34

Stakeholder Engagement: Notable Example

Inditex

Inditex discloses that, as part of the Global Framework Agreement with IndustriALL Global Union, it has set up dialogue forums in 12 countries in which its suppliers operate, through which it engages with local unions, NGOs, workers associations, and governments to improve its engagement with suppliers. The company discloses that one focus area is forced labor and ensuring that its labor standards are applied locally.

Recommended Action

Stakeholder Engagement

Engage with local stakeholders such as unions, policy makers, or workers' rights organizations on the issue of forced labor in countries in which suppliers operate.