1
Introduction
Page Number
Our Code of Conduct
Employment Relationship
Nondiscrimination
Harassment or Abuse
Forced Labor
Child Labor
Freedom of Association and Collective Bargaining
Health, Safety, and Environment
Hours of Work
Compensation
4-5
Implementation of our Code of Conduct
Code of Conduct Communication
Code of Conduct Compliance Benchmarks
Management Systems
5-6
Additional Policies
Environmental Responsibility
No Unauthorized Subcontracting
Finished Goods Supplier and Subcontractor Disclosure
No Homeworking
Prohibited Sourcing from Xinjiang
Forced Labor & Responsible recruitment
Zero Tolerance
6-9
Assessment Policy & Guidance
Facility Authorization Process
Assessment Planning & Submission
Mutual Recognition Acceptance Requirements
Assessment Policies & Procedures
Assessment Matrix/ Rating
Zero Tolerance Violations
Remediation and Continuous Improvement
Better Buying Initiative
Corrective Action Plan (CAP) Management Process
10-17
Chemical Management
Our Mission
Higg Facility Environmental Module (FEM)
Chemicals in Final Products
Our Manufacturing Restricted Substance List (MRSL)
Our Restricted Substance List (RSL)
Supplier Responsibility
Our Printing & Dyeing Standards
Our Finishing Standards
18-21
Better Materials
Ref Fiber Standards
Lenzing Fibers
Deadstock Fabrics
22-24
2
Leather
Certification and Sourcing Learning Center
Additional Policies
Ethical Animal Welfare
Sustainable Forests Commitment
Prohibited Sourcing from Xinjiang
Traceability and Transparency
Trims & Other Product Specific Guidelines
Trims
Footwear
Jewelry & Hardware
Sunglasses
24-27
Acknowledgment of Receipt and Acceptance of Terms Letter
Sustainability Team Contact Information
28
29
Appendix A: Chargebacks for Social and Environmental Compliance
Appendix B: Scheduling a Social Assessment with our Preferred Assessment Partners
Appendix C: Facility Assessment Approach and Guidance, and Frequently Asked
Questions (FAQ)
Appendix D: Document List Required to Complete Assessment
Appendix E: Self Assessment Questionnaire for Pre-Screening
Appendix F: Factory Code of Ethics (COE) Letter
Appendix G: Fair Trade Principles
Appendix H: Self Assessment Questionnaire for Fair Trade
Appendix I: Fair Labor Association (FLA) Workplace Code of Conduct and Compliance
Benchmarks
Appendix J: Forced Labor and Responsible Recruitment Benchmarks
Appendix K: QuickBase Handbook Instructions
Appendix L: Sustainable Forests Commitment
Appendix M: Better Buying Initiative
References
30-64
Introduction
Dear Business Partner,
Reformation’s mission is to bring sustainable fashion to everyone. Since 2009, we have had the opportunity to work
with incredible partners to make a real impact in the industry, and get closer to realizing that mission.
Reformation is committed to achieving fair, safe, and healthy working conditions throughout our supply chain, and
minimize environmental impact. This guide outlines our minimum standards and expectations for partners to do
just that. It also provides resources on how we will support our suppliers in achieving our standards, as well as
guidelines for how suppliers can implement policies, procedures, and processes to comply with and also move
beyond compliance.
We seek to partner with suppliers who share a common vision of sustainability, accountability, and transparency
and are willing to go beyond compliance to achieve the highest standard of social and environmental responsibility.
To be an approved Reformation partner, you will need to affirm:
● Social responsibility. All our partners must agree to our Code of Conduct and additional policies which
establishes minimum requirements for ethical and legal operations, and allow for third-party audits and
CAP management as needed.
● Safe & non-toxic. All our partners must agree to our Restricted Substance List and pass testing if
applicable.
● Quality . All our finished products and fabric must pass our quality standards and testing protocol.
● Better materials. Our products can only be made from a list of approved fibers and must have a
transparent supply chain. This guide is also a resource for preferred certifications, traceability guidelines,
dyeing, printing, and finishing practices.
We recognize that this effort is a process and requires a collaborative approach with open communication. As
critical partners in ensuring social and environmental responsibility, your feedback is very important to us. If you
have comments or questions about this guide or any suggestions for improvement, please contact the Reformation
Sustainability Team at sustainability@thereformation.com . We also encourage you to provide your feedback by
participating in anonymous surveys about our purchasing practices through the Better Buying Initiative.
This document will be updated periodically to enable continuous improvement. We ask that you review carefully,
and initial throughout. In addition, please sign the Acknowledgment of Receipt Letter on page 28, acknowledging
the receipt of our Sustainable Partners Guide. For more information on Reformation’s sustainability values and
practices please visit www.thereformation.com/whoweare .
We look forward to a successful partnership with you. We are excited to build a better future in fashion together!
Sincerely,
Kathleen Talbot
Chief Sustainability Officer and VP of Operations
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Our Code of Conduct
LYMI, Inc. dba Refo rmation (hereinafter “Reformation”) is committed to conducting business in an ethical and legal
manner that protects the environment. As a Participating Company of the Fair Labor Association (FLA), our Code of
Conduct references th e FLA Workplace Code of Conduct which is based on International Labor Organization (ILO)
standards and internationally accepted good labor practices.
All of our suppliers are expected to adhere to our Workplace Code of Conduct . Requirements in our Code of
Conduct apply to the entire supply chain, including sub-suppliers and subcontractors. Standards comprised in our
Code of Conduct equally apply to permanent, temporary, and agency workers, as well as piece-rate, salaried,
hourly, part-time, night workers, homeworkers, young workers and migrant workers.
Your signature on our Acknowledgement of Receipt and Acceptance of Terms Letter (AOR) confirms that all raw
goods and finished goods which you will manufacture and deliver to us will be produced in full compliance with our
Code of Conduct as well as the additional policies outlined in this guide. Please additionally refer to Appendix I to
review our Code of Conduct in other languages and Benchmarks.
Code of Conduct
EMPLOYMENT RELATIONSHIP: Employers shall adopt and adhere to rules and conditions of employment that
respect workers and, at a minimum, safeguard their rights under national and international labor and social
security laws and regulations.
NONDISCRIMINATION: No person shall be subject to any discrimination in employment, including hiring,
compensation, advancement, discipline, termination, or retirement, on the basis of gender, race, religion, age,
disability, sexual orientation, nationality, political opinion, social group or ethnic origin.
HARASSMENT OR ABUSE: Every employee shall be treated with respect and dignity. No employee shall be subject
to any physical, sexual, psychological, or verbal harassment or abuse.
FORCED LABOR: There shall be no use of forced labor, including prison labor, indentured labor, bonded labor or
other forms of forced labor.
CHILD LABOR: No person shall be employed under the age of 15 or under the age for completion of compulsory
education, whichever is higher.
FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING: Employers shall recognize and respect the right of
employees to freedom of association and collective bargaining.
HEALTH, SAFETY, AND ENVIRONMENT: Employers shall provide a safe and healthy workplace setting to prevent
accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the
operation of employers’ facilities. Employers shall adopt responsible measures to mitigate negative impacts that
the workplace has on the environment.
HOURS OF WORK: Employers shall not require workers to work more than the regular and overtime hours allowed
by the law of the country where the workers are employed. The regular work week shall not exceed 48 hours.
Employers shall allow workers at least 24 consecutive hours of rest in every seven-day period. All overtime work
shall be consensual. Employers shall not request overtime on a regular basis and shall compensate all overtime
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work at a premium rate. Other than in exceptional circumstances, the sum of regular and overtime hours in a week
shall not exceed 60 hours.
COMPENSATION: Every worker has a right to compensation for a regular work week that is sufficient to meet the
worker’s basic needs and provide some discretionary income. Employers shall pay at least the minimum wage or
the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages, and provide any
benefits required by law or contract. Where compensation does not meet workers’ basic needs and provide some
discretionary income, each employer shall work with the FLA to take appropriate actions that seek to progressively
realize a level of compensation that does.
Reformation would like to know If any of our suppliers are violating any of these codes. Please email us at
sustainability@thereformation.com in your local language. All information that we receive will be kept in strict
confidence and your identity protected.
Implementation of our Code of Conduct
Code of Conduct Communication
Reformation requires our suppliers to communicate our Code of Conduct to all employees, including full-time,
part-time, permanent, and temporary employees.
Suppliers are required to:
• Post our Code of Conduct, labor standards, and grievance procedures in a conspicuous place, frequented by all
employees, in the local language(s) spoken and understood by employees, supervisors, and managers. Various
translations of the Code of Conduct can be found here .
• Conduct annual, documented training efforts to educate current and new employees about labor standards and
grievance mechanisms.
Code of Conduct Compliance Benchmarks
The Compliance Benchmarks identify specific requirements for meeting compliance with each Code standard.
Please refer to Appendix I below to review each benchmark and Code standard in full detail.
Management Systems
Reformation expects our suppliers to adopt a management systems approach to social and environmental
responsibility in order to ensure effective implementation. These policies, processes, and procedures should ensure
compliance with any relevant labor or environmental standards and help to anticipate and avoid issues related to
non-compliance. It is important to remember that written policies and procedures need to be implemented and
turned into consistent processes that require commitment and training. There are publicly available resources that
provide a strategic framework outlining fundamental and advanced steps corresponding to each of the procedures.
Please refer to the GSCP Social Labor Management Systems , Social Accountability International resources for
Environmental and Social Management System and FLA Grievance Mechanisms Toolkit for Suppliers .
Specifically, the following policies and procedures shall be implemented by the supplier:
● Appoint a senior management staff to take responsibility for implementing our Code of Conduct and
additional policies. In addition, suppliers must provide appropriate training for managers on how to
implement their social compliance policies and procedures.
● Establish a written social compliance policy and code endorsed by senior management and cover the key
elements of our Code of Conduct and additional policies.
● Communicate our Code of Conduct and additional policies to all employees in a language they
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understand. Additionally, suppliers shall implement a communication/grievance system, and ensure
workers are aware of and knowledgeable on how to use the system.
● Implement a system to identify and monitor laws, regulations, and Reformation requirements that apply
to the supplier. Up-to-date versions of applicable laws, regulations and customer requirements shall be
obtained.
● Conduct regular management reviews (at least annually) of its social compliance system in order to
identify improvement opportunities. Written records (correspondence, report, meeting minutes, etc.)
from management review meetings should be available for review.
● Take appropriate actions to address non-conformances identified during assessments and also have
preventative measures in place to avoid recurrence.
● Management systems shall undergo regular review and revisions to policies and procedures to ensure
compliance with local laws, adherence to our Code of Conduct, and mitigation of risks related to our Code
of Conduct.
Additional Policies
Reformation expects our suppliers to additionally adhere to the following additional policies:
Environmental Responsibility
Reformation expects our suppliers to respect and protect the local environment in which they operate. This applies
to all raw material processing, agricultural, manufacturing, and logistics facilities that are involved in Reformation’s
supply chain. Suppliers shall commit to establishing effective policies and procedures to manage, monitor, and
minimize their environmental impacts, including but not limited to energy and natural resource use, water use,
wastewater, emissions to air, waste management, and their initiatives for pollution prevention.
● All sites must ensure that they comply with and possess up-to-date certifications, permits, licensing,
and/or registrations pertaining to all local and national environmental laws.
● Suppliers must ensure that an Environmental Management System (EMS) is in place with a trained
employee who monitors, tracks, and reports the environmental practices of the facility.
● Waste disposal must be done in a responsible manner that complies with local and national regulations.
Suppliers must also strive to meet international standards that apply. Personal Protective Equipment and
adequate training must be made available.
● Suppliers must take a proactive approach toward preventing the accidental release or discharge of
hazardous substances into the local environment. The air emissions must at a minimum meet the
regulated discharge limits. This should be included in the EMS Operator’s duties. In case of such an
incident, the EMS operator must be trained in controlling the spill.
Suppliers may be required to disclose energy, water, and chemical usage to Reformation upon request.
No Unauthorized Subcontracting
Subcontracting may only be utilized with Reformation’s prior written approval and only after the subcontractor has
agreed to comply with our Code of Conduct and has been approved as an authorized supplier, without exception.
This applies to all test, sample, and bulk production orders and includes all product components.
Our Code of Conduct, policies, and requirements, and all applicable laws and regulations must be communicated to
all sub-suppliers and/or approved subcontractors in the local language . In addition, our direct suppliers are
required to continuously monitor all approved subcontractors and sub-suppliers for compliance with our Code of
Conduct and our Additional Policies.
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Finished Goods Supplier and Subcontractor Disclosure
As an effort towards greater traceability and accountability, we publish our bi-annual Supplier List on our website.
We require the following to be disclosed for all finished good assemblers and subcontractor facilities: Parent
Company, Supplier, Facility Name, Facility Address (including city, state/province, zip code), Supplier Type, Product
Type, Number of Employees, Male vs. Female ratio, Union Presence, and Collective Bargaining Agreement (CBA).
No Homeworking
Reformation does not permit any homeworking.
Prohibited Sourcing from Xinjiang
Reformation is a signatory to the Call to Action to End Uyghur Force Labor and prohibits sourcing and production
(including direct and indirect sourcing of raw materials, inputs, or finished products) from Xinjiang. Please refer to
our policy and benchmarks on Forced Labor and Responsible Recruitment below.
Forced Labor and Responsible Recruitment
This section outlines the requirements for the responsible recruitment and fair treatment of migrant workers in our
supply chain.
Human trafficking, also known as modern-day slavery, is a form of slavery that can include forced labor, bonded
labor, prison labor, sex trafficking, and domestic servitude. Reformation believes modern slavery and human
trafficking are egregious violations of human rights and we are deeply committed to doing our due diligence to
minimize, detect, and remediate forced labor and human trafficking within our supply chain.
It is increasingly apparent that one of the greatest drivers of modern slavery, permeating all economic sectors was
the exploitation of migrant workers occurring at the hands of unscrupulous recruitment agencies and/or labor
brokers.
The Governing Body of the International labor (ILO) Organization, in its 2014 Recommendations of Supplementary
Measures for the Effective Suppression of Forced Labor, calls out the corporate responsibility of “protecting
persons, particularly migrant workers, from possible abusive and fraudulent practices during the recruitment and
placement process” in combating forced labor. Additionally, in 2016 the Governing Body issued general principles
and operational guidelines for fair recruitment stating that companies and public employment services should
include “human rights due diligence assessments of recruitment procedures and should address adverse human
rights impacts with which they are involved.”
We are committed to the fair treatment of workers in the apparel and footwear supply chains and to eliminating
the practice of migrant workers paying recruitment costs and fees to secure their employment. We support the
Dhaka Principles for Migration with Dignity to enhance respect for the rights of migrant workers from the moment
of recruitment, during employment, and through to further employment or safe return. Our Supplier Code of
Conduct references th e FLA Workplace Code of Conduct which is based on International Labor Organization (ILO)
standards and internationally accepted good labor practices, including forced labor and responsible recruitment in
supply chains. These standards apply equally to permanent, temporary, and agency workers, as well as piece-rate,
salaried, hourly, part-time, night workers, homeworkers, young workers, and migrant workers. We require, that as a
condition of doing business with us, suppliers:
1. Agree not to engage in any form of human trafficking or slavery. We describe examples of good
management practices for evaluating and addressing risks of human trafficking in their supply chain,
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including not using forced or involuntary labor of any type (e.g., forced, bonded, indentured,
involuntary prison labor) or illegal child labor.
2. At a minimum, comply with all applicable wage and hour laws and regulations, including those relating
to minimum wages, overtime hours, piece rates, and other elements of compensation, and provide
legally mandated benefits.
3. Treat all employees with respect and will not use corporal punishment, threats of violence, or other
forms of physical coercion or harassment. Supplier should have a policy that prohibits inappropriate
conduct and a process for employees to report such conduct for supplier’s investigation and resolution.
In July 2019 we pledged our support to the joint American Apparel & Footwear Association (AAFA) and FLA industry
pledge, committing to working with our suppliers to ensure the following:
1. No worker pays for their job or right to work;
2. Workers retain control of their travel documents and have full freedom of movement; and
3. All workers are informed of the basic terms of their employment before leaving home.
W e expect our suppliers to adopt and maintain terms of employment for their employees that comply with local
law and our Supplier Code of Conduct and the below provisions addressing factors that are “enablers” or
contributors to situations or risks of human trafficking and forced labor. These standards apply equally to
permanent, temporary, and agency workers, as well as piece-rate, salaried, hourly, part-time, night workers,
homeworkers, young workers, and migrant workers. Please vie w Appendix J for benchmarks to help serve as a basis
for establishing and monitoring performance indicators.
● FORCED OR INVOLUNTARY LABOR : Workers shall not be subject to any form of forced, compulsory,
bonded, indentured, or prison labor. All work must be voluntary and workers shall have the freedom to
terminate their employment at any time without penalty, given notice of reasonable length.
● RECRUITMENT FEES: Workers shall not be charged any fees or costs for recruitment, directly or indirectly,
in whole or in part, including costs associated with travel, processing official documents, and work visas in
both home and host countries. All costs and fees associated with recruitment, travel, and processing of
migrant workers from their home community to the workplace, including through to return when the
relocation is not permanent should be covered by the employer. The employer should pay the costs of
recruitment directly to the extent possible. When not possible, or where the migrant worker is legally
required to pay a fee or cost directly, the migrant worker shall be reimbursed by the employer as soon as
practicable upon discovery.
● CONTRACTS OF EMPLOYMENT: Written contracts of employment shall be provided to migrant workers in
a language they understand, clearly indicating their rights and responsibilities with regard to wages,
working hours, and other working and employment conditions. Migrant workers shall be provided with
their employment contract prior to departing their home country . The use of supplemental agreements
and the practice of contract substitution (the replacement of an original contract or any of its provisions
with those that are less favorable) are strictly prohibited.
● DOCUMENT RETENTION: Confiscating or withholding worker identity documents or other valuable items,
including work permits and travel documentation (e.g. passports), is strictly prohibited. The retention of
personal documents shall not be used as a means to bind workers to employment or to restrict their
freedom of movement.
● DEPOSITS: Migrant workers shall not be required to lodge deposits or security payments at any time.
● HUMANE TREATMENT: The workplace shall be free of any form of harsh or inhumane treatment.
Disciplinary policies and procedures shall be clearly defined and communicated to all workers, and shall
not include any inhumane disciplinary measure, including any corporal punishment, mental or physical
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coercion, or verbal abuse of workers; nor shall they include sanctions that result in wage deductions,
reductions in benefits, or compulsory labor. The use or threat of physical or sexual violence, harassment,
and intimidation against a worker, his or her family, or close associates, is strictly prohibited.
● WORKPLACE EQUALITY: All workers, irrespective of their nationality or legal status, shall be treated fairly
and equally. Migrant workers shall benefit from conditions of work (including but not limited to wages,
benefits, and accommodations) no less favorable than those available to country nationals. Migrant
workers (or their family members) shall not be threatened with denunciation to authorities to coerce
them into taking up or maintaining employment.
● WAGES AND BENEFITS: All workers shall be paid at least the minimum wage required by applicable laws,
and shall be provided all legally mandated benefits. Wage payments shall be made at regular intervals and
directly to workers, in accordance with national law, and shall not be delayed, deferred, or withheld. Only
deductions, advances, and loans authorized by national law are permitted and, if made or provided,
actions shall only be taken with the full consent and understanding of workers. Clear and transparent
information shall be provided to workers about hours worked, rates of pay, and the calculation of legal
deductions. All workers must retain full and complete control over their earnings. Wage deductions must
not be used as a disciplinary measure, or to keep workers tied to the employer or to their jobs. Workers
shall not be held in debt bondage or forced to work in order to pay off a debt. Deception in wage
commitments, payment, advances, and loans is prohibited.
● WORKING HOURS: Workers shall not be forced to work in excess of the number of hours permitted in
national law. Where the law is silent, normal working hours shall not exceed eight per day and forty-eight
per week, and total working hours including overtime shall not exceed sixty. All overtime shall be purely
voluntary, unless part of a legally recognized collective bargaining agreement. No worker shall be made to
work overtime under the threat of penalty, dismissal, or denunciation to authorities. No worker shall be
made to work overtime as a disciplinary measure, or for failure to meet production quotas.
● FREEDOM OF MOVEMENT AND PERSONAL FREEDOM: Workers’ freedom of movement shall not be
unreasonably restricted. Workers shall not be physically confined to the workplace or related premises,
such as employer- or recruiter-operated residences; nor shall any other coercive means be used to restrict
workers’ freedom of movement or personal freedom. Mandatory residence in employer-operated facilities
shall not be made a condition of employment.
● GRIEVANCE PROCEDURES: An effective grievance procedure shall be established to ensure that any
migrant worker, acting individually or with other workers, can submit a grievance without suffering any
prejudice or retaliation of any kind.
● PRIVATE EMPLOYMENT AGENCIES AND LABOR RECRUITERS: Companies should hire migrant workers
directly whenever possible. When the subcontracting of recruitment and hiring is necessary, companies
shall ensure that the labor agencies they engage operate legally, are certified or licensed by the competent
authority, and do not engage in fraudulent behavior that places workers at risk of forced labor or
trafficking for labor exploitation. Suppliers must have a formal policy and due-diligence process in place for
vetting recruitment agencies responsible for the labor supply.
ZERO TOLERANCE
× Situations of forced labor - using coercion or fraud to hire and retain workers - or any involvement in acts of
trafficking in humans can have serious consequences for a supplier. For Reformation, these are Zero Tolerance
issues. If found, we will try to remediate the situation first, ensuring that workers currently in forced or indentured
conditions are taken care of and terminate if the situation is not rectified in a timely manner which should be
reasonable and defined.
× In many countries trafficking in labor is a criminal offense. Harsh penalties may apply, including substantial fines
and a lengthy prison sentence for directors and business owners.
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Assessment Policy & Guidance
Reformation expects our suppliers to strive to meet our requirements as well as demonstrate a commitment to our
core values of transparency, open and ongoing communication, accountability and continuous improvement. We
have developed a proactive approach to sustainable sourcing in order to drive real change throughout our supply
chain. We monitor for compliance with our Code of Conduct and additional policies in a tailored and risk-based
manner which enables us to decrease audit fatigue and focus more resources on continuous improvement support.
The goal of our assessments is not only to help us evaluate our supplier’s overall compliance but to also identify
progress and stimulate improvement. Violations, open communication and genuine continuous improvement will
always be regarded higher than false documents and hidden violations. We believe that suppliers should be
involved as much as possible in the assessment process and we hope that you will use these assessments as an
opportunity to learn how to improve working conditions and labor standards in your facility.
Below you will find information explaining our assessment process and assessment methodology. Please refer to
our Domestic Assessment Frequency and Appendix B for information on scheduling a social assessment with our
preferred assessment partners.
Facility Authorization Process
All suppliers involved in the manufacturing of Reformation products with contracts regardless of supply chain level
must go through a facility authorization process as outlined below before POs can be issued. This applies to all test,
sample and bulk orders. Suppliers must accept the terms and conditions and will be designated with a rating level
based on our independent review of the supplier’s compliance to our Code of Conduct and Additional Policies.
Currently, we require assessments of our tier 1 facilities (manufacturing units - cut, sew & finish, vertically
integrated factories) and our tier 2 facilities (all wet processing facilities, mills and component manufacturing
facilities).
Please follow the below steps within one week of receiving an invitation to QuickBase. The invitation to QuickBase
will be sent from priscilla.pacheco@thereformation.com .
Step 1: New Supplier Setup: We use QuickBase as a tool to help with onboarding and to help with our social
compliance monitoring program.Please click on the link in the QuickBase invitation email and follow the
instructions to register and create a login. Once you register with QuickBase you will have your own access
information and portal that will allow you to keep track of your facility and add new facilities for authorization.
Step 2: Review, Sign and upload on-boarding Documents: There are several forms that must be signed, filled out
and uploaded to QuickBase. These forms will be attached to the onboarding email, but can also be found in the
"Template" line in the "Onboarding" tab.
● Mutual Non-Disclosure Agreement (NDA)
● Facility Profile
● Acknowledgment of Receipt and Acceptance of Terms Letter of the Sustainable Partners Guidebook
● COVID-19 Safety Guidelines - Acknowledgment of Receipt and Acceptance of Guidelines
● COVID-19 Preparedness Observations Checklist
Step 3: Please follow our facility authorization process listed in the QuickBase instructions handbook (i.e. Domestic
onboarding vs International onboarding).
Please review the Assessment Planning & Submission requirements below to submit an audit for review.
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Assessment Planning & Submission: All suppliers are required to either:
1. Submit a full social assessment report and a CAP to priscilla.pacheco@thereformation.com and
carrie@thereformation.com (Subject: Supplier name: [insert Audit company] Assessment report) from one
of the approved third-party programs or approved brands. Please be sure to follow our Mutual
Recognition Acceptance Requirements below.
a. Reformation will validate that the report meets our acceptance requirements
b. Valid reports will be assessed and assigned a color rating based on the third-party program’s
evaluation of the facility and Reformation’s review of the reports.
c. Assessment ratings and next steps will be communicated to the supplier.
OR
2. Participate in an assessment with our Preferred Third-Party Assessment Partner. Assessments will be semi-
announced (14-day window), however we reserve the right to conduct unannounced audits when we find
necessary. Please see Appendix B for a detailed procedure of how to schedule a facility assessment with
our Preferred Assessment Partner. For an overview of the Facility Assessment Approach and Methodology,
please see Appendix C through Appendix F for a list of documents required to complete the inspection.
a. A CAP (see Remediation and Continuous Improvement section below for CAP requirements).
Mutual Recognition Acceptance Requirements
Approved Third-Party Programs
Assessments from the following third-party programs can be submitted to satisfy assessment requirements.
Assessments must be authentic and dated and have taken place within the last 12 months. Submissions must
include the full assessment report including any follow-up assessments and a CAP (including root cause analysis,
preventative and corrective actions) highlighting a defined timeline to address any findings along with any evidence
to show completed CAP closures. We will not accept just the certification, corrective action plans or a list of the
violations. If the report is older than 12 months, an updated facility assessment must be submitted prior to PO
placement. If the assessment is accepted, we will assign a Reformation facility rating. We reserve the right to reject
a third-party assessment and require additional assessments if we feel necessary.
● Business Social Compliance Initiative (BSCI)
● Better Work
● SEDEX Members Ethical Trade Audit (SMETA)
○ Reformation only accepts the listed seven audit firms for SMETA audits: BV, Elevate, Intertek, UL,
SGS, TUV Rhineland, TUV SUD
● Social Accountability International (SA8000)
● Worldwide Responsible Accredited Production (WRAP)
○ WHAP report must be submitted
● Elevate Responsible Sourcing Tool (ERSA)
● Intertek Workplace Conditions Assessment (WCA)
● SLCP Verified Data
● HIGG Verified Facility Social Labor Module (VFSLM)
● Labor Law Monitoring *Labor Law Monitoring audits will only be accepted as an initial assessment and
must have taken place within the last 3 months (California only).
Unacceptable Audit Firms
Due to audit quality concerns, any reports issued by the following audit firms are not acceptable through our
mutual recognition program:
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● ABS QE
● CISE ( Centro per l’innovazione e lo Sviluppo Economico
● DNV GL Business Assurance
● EUROCERT European Inspection and Certification Company S.A
● Global Group of Companies Ltd
● IQNET Ltd
● LSQA S.A
● Apparel Resources
Other Guidelines and Considerations for our Mutual Recognition Program :
The following are additional guidelines and considerations that we take into account when accepting mutual
recognition audits:
● Auditors must be APSCA approved auditors from vertical firms
● Our Preferred audit firms are: ELEVATE, Omega, Arche Advisors, Verite, Fair Working Conditions, Better
Work, UL, TAOS Network and Insite
● Audits should not be paid for and negotiated by the supplier
● Country Risk Profile
Acceptance of other Brands’ Audits
Reformation may accept assessment reports from other brands that continue to demonstrate a commitment to
Social Responsibility. Our criteria for accepting other brands assessments include:
● Assessments must be less than 12 months old
● The full assessment report, including any follow-up assessments and a CAP (including root cause analysis,
preventative and corrective actions) highlighting defined timelines to address any findings along with any
evidence to show completed CAP closures.
● We will review the brand’s program, code standards, assessment tools and protocols to confirm they are in
line with our standards
● If the assessment is accepted, we will assign a Reformation facility rating. We reserve the right to reject
other brands’ assessments and require additional assessments if we feel necessary.
Assessment Policies & Procedures
Cost of Audits
Reformation will pay for the cost of the initial assessment with our Prefered Third-Party Assessment Partner.
Additionally, Reformation will pay for the cost of ongoing monitoring (Follow-up & Annual assessments) for all
yellow and green rated inspections. However, Reformation will charge back those suppliers that require more
regular monitoring due to substandard audit findings and non-action on CAP improvement.
Cost of CAP Management Services
CAP Management support service fees incurred through our monitoring partner will be the responsibility of the
supplier. Support levels are jointly determined based on the support needed to effectively remediate issues
identified during the audit process.
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Additional Policies:
● Reformation may additionally require suppliers to fill out the Self Assessment Questionnaire for
Pre-Screening in Appendix E . Suppliers will need to complete the form and return it to the Reformation
Sustainability team within 7 days of request.
● Reformation purchase orders (PO) are required to capture the facility location producing the goods on the
PO. If the facility location is missing, PO’s cannot be issued. It is the vendor’s responsibility to ensure the
facility location is submitted on time to Production team, or the issuance of PO’s will be delayed due to
the fault of the supplier.
● Suppliers must confirm that the facility assessment report they submit is for the same facility that will be
used for orders.
● Falsification of assessment report or facility location, will incur severe chargebacks for non-compliance
and/or cancellation of applicable orders and termination of business relationship.
● Reformation takes our assessment process very seriously and does not accept or condone any form of
bribery. Suppliers should avoid any type of remuneration or bribery. Any attempt to bribe or improperly
influence an inspection will result in a suspension of business with that supplier. This includes offers of any
kind, including but not limited to gifts, facility products or money.
● Suppliers must have a valid, current business license and other documents required for legal operation.
● Suppliers must not have any errors or omissions in government permits, certificates or other records.
● Suppliers must allow assessor(s) full access to its facility premises, workers, and records.
● Suppliers should encourage workers to speak truthfully and should not manipulate workers’ responses in
any way. Suppliers should not “coach” employees to provide false or misleading responses to questions
asked by assessor(s).
● Suppliers should not interfere with selection of workers for interviews and facilitates interviews outside
the presence of managers and supervisors.
● Workers must not be punished through monetary, physical, or other means, for participating in worker
interviews.
● Suppliers must provide accurate and true payroll documents and time attendance records for review.
● Suppliers are responsible for ensuring that the required corrections are completed by the listed dates on
the CAP form. Extensions to these dates may be accepted if the supplier advises Reformation.
● Suppliers with a poor assessment rating must work to correct the issues found from the audit prior to
production of Reformation orders. If corrections are not made prior to production, the supplier may risk
cancellation of orders, at Supplier’s sole expense.
● If any supplier does not comply with these terms, Reformation may cancel any or all outstanding POs.
● The Reformation reserves the right to collaborate and/or share the results of Reformation social audits
with peer companies and/or Non-Governmental Organizations (NGOs).
● Denying access to execute a scheduled audit will result in a cancellation fee charged back to the vendor in
the approximate amount of a full audit.
Assessment Matrix/Rating
Reformation uses a color coded system to indicate the compliance status of facilities. Reformation reserves the
right to assign ratings. Each non-conformity is graded based on the following terminology:
1)Minor
2)Moderate
3)Major
4)Zero Tolerance/Critical
An overall assessment score’s final grade is a summation of those findings. A summary is found below:
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Rating
Category
Rating Meaning
Examples of Key
Violations
Assessment
Frequency
Facility Action Required
Green
Authorized for production
Facility meets or exceeds our code standards.
Production is encouraged to place business.
Facility will have zero to a few
non-conformities found.
California: Assessments are
required within a
maximum of 3-6 months.
International: Assessments
are required within a
maximum of one year.
Continue to identify and
manage any problems.
Yellow
Authorized for production
Facility has some moderate and minor safety,
health or labor-related issues and further
improvement is needed. There are no critical
issues with regards to wages, building safety,
working hours and industrial relations
Facility is transparent, has open communication
and is making continuous improvements.
Production is encouraged to place business.
Facility will have a variety of
minor and moderate
non-conformities (such as
clerical errors & minor safety
violations), Excessive working
hours against the legal
requirements, but the weekly
working hours are below 60.
California: Assessments
are required within a
maximum of 3-6
months.
International:
Assessments are
required within a
maximum of 12 months
Issues shall be corrected in a
timely manner (0-3 months) as
assessed and defined in
Corrective Action Plans and
follow-up facility assessments.
Orange
Authorized for production on a probationary basis
Facility has major s afety, health or labor-related
violations of the Standards and significant action is
required.
Production may place orders while reinforcing the
importance of compliance and making continuous
improvements against a Corrective Action Plan.
Production should consider sourcing another
supplier should no improvement be made. Two
consecutive orange ratings will result in a Red
rating.
Facility will likely have a mix
of minor, moderate or
perhaps only a few major
findings. Weekly working
hours exceed 60, No 1 days
off in 7, No 2 days off in 14,
Insufficient overtime
payment, Insufficient legal
benefits, health & safety
non-conformities, accurate
time records are not kept.
California: Follow-up
assessments are required
within 1-2 months.
International:Follow-up
assessments are required
within a maximum of 4
months
Facility may be authorized to
produce Reformation products
but vendor must take
immediate action to
substantially remediate any
open violations within the
specified time frames (0-3
months) as defined in the
Corrective Action Plan and
facility follow up audits.
Red
Not Authorized for Production
Facility has one or more Zero-Tolerance Violations
and/or has failed to remediate or has major
s afety, health or labor-related violations over the
course of two cycles and urgent action is required.
Facility has demonstrated a lack of transparency,
accountability, commitment and open
communication.
Facility will likely have a
variety of major findings on
site. Any one zero
tolerance/critical issue will
also immediately push a site
into a “Red” score. See list of
Zero Tolerance violations
below.
California: Follow-up
assessments are required
within 1 month.
International:Follow- up
assessments are required
within a maximum of 3
months
ZT violations will require
correction within one
month
These violations may make it
appropriate to temporarily or
permanently terminate the
facility’s ability to produce
product for sale by
Reformation. If a facility is
assessed a Red rating, its ability
to produce product for Ref may
be ended indefinitely, its
production halted and/or its
product refused.
Zero Tolerance Violations:
For Reformation, the following are Zero Tolerance issues. If found, we will try to remediate the situation first,
ensuring that workers are taken care of and terminate if the situation is not rectified in a timely manner which
should be reasonable and defined.
● The facility does not allow assessor(s) and/or Reformation full access to its facility premises, workers,
and/or records.
● The facility attempts to bribe assessor(s) including offering any form of monetary compensation, gifts or
favors.
● The facility does not provide accurate and true payroll documents and time attendance records for review.
● There are employee(s) employed by supplier currently below the age of fifteen (15) or in breach of local
minimum age for work or mandatory schooling.
● The facility uses any type of involuntary labor who are trafficked, prisoned (not in compliance with ILO
Convention 29), bonded, or indentured, either at the facility itself, or a broker.
● The facility engages in or supports for any reason the use of corporal punishment, mental or physical
coercion and verbal abuse including but not limited to threats of violence and sexual harassment.
● The facility uses any form of – or threat of – physical violence, including slaps, pushes or other forms of
physical contact as a means to maintain labor discipline.
● The facility, based on a woman’s pregnancy, makes decisions that result in dismissal, threat to dismiss, loss
of seniority, or deduction of wages.
● The facility does not respect the right of employees to freedom of association and collective bargaining.
No employee shall be subject to harassment, intimidation, or retaliation in their efforts to freely associate
or bargain collectively.
● The facility does not ensure that wages paid for regular working hours are at least legal minimum wage or
industry wage agreed within a collective bargaining agreement (CBA), whichever is higher.
● There are indications of possible structural collapse on the interior or exterior of buildings, such as large
visible cracks or sagging in walls and floors.
● There are not sufficient numbers of emergency exits at the facility (production floors, office areas,
warehouse etc.).
● Emergency exits are locked during working hours (including overtime hours).
● Flammable and combustible material and chemicals are not safely stored away from sources of ignitions.
● There are not sufficient numbers of emergency exits on each dormitory floor as legally required.
● Unauthorized Subcontracting
● Unauthorized Homeworking
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Remediation and Continuous Improvement:
In order to ensure continued compliance with our Code of Conduct , a ll suppliers must agree to announced and
unannounced assessments by Reformation and our independent third-party monitoring firms. In addition to
auditing, Reformation will monitor suppliers by asking them to disclose information about social and environmental
responsibility through surveys, meetings and phone calls with Reformation staff, direct feedback from workers
through cell phone surveys and other types of information gathering. Reformation expects suppliers’ cooperation
in sharing information about social and environmental responsibility. Suppliers must grant full access (all facilities,
employee records and employees for confidential interviews), maintain accurate documentation necessary for
demonstrating compliance with our Code of Conduct and be fully transparent when submitting to assessments.
Reformation expects all suppliers to remediate any noncompliance issues in a timely manner which shall be
reasonable and defined. All suppliers must provide proof of correction to Reformation for each non-compliance
issue . We require all our suppliers to work with us to find the root cause of the issue and to develop necessary
management, reporting and tracking systems within the facility, to ensure ongoing compliance and continuous
improvement. Reformation reserves the right to terminate business relationships with any supplier who is unwilling
or unable to comply with our Code of Conduct.
Based on the findings during the assessment, Reformation will perform concentrated remediation efforts [see
below Corrective Action Plan (CAP) Management Process] and a Corrective Action Plan (CAP) form will be issued to
the supplier detailing the areas which need improvement. It’s the supplier’s responsibility to fill out the below
three areas on the CAP form:
1. Root Cause - Briefly state the root cause of the issue
2. Corrective Action Plan – Briefly state what steps will be taken to fix the issue
3. Preventative Action - Briefly state what practices/processes can be put in place to prevent the issue from
happening again
4. Responsible Staff/Position - Identify who in your facility will be responsible for this
5. Target Completion Date - Indicate when the corrective action will be completed
6. Evidence - Please paste/send images/documentation once findings are addressed
If a CAP form is issued, suppliers should complete the form and return it to the Reformation Sustainability team
within 7-14 days. If the supplier needs guidance in developing an improvement plan, Reformation will act as a
resource. Find additional CAP Guidance here .
We understand that certain issues are easily remedied, while others may take longer. All substandard audit findings
must be remediated in a timely manner. We expect our suppliers to share our value of striving for constant
improvement. Remember, it’s not just about what happens during the audit - we prioritize active continuous
improvement.
Better Buying Initiative
In order to better understand our purchasing practices, we have been participating in surveys through the Better
Buying initiative since 2019. We hope you’ll provide anonymous feedback so we can through the surveys so we can
foster two-way communication and work towards continuous improvement as well.
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Corrective Action Plan (CAP) Management Process:
Reformation suppliers will go into different CAP Management types depending on the color rating category. Below
are example types of CAPs based on the color rating. CAP Support services are administered either by our Social
Compliance team or monitoring firm partner. Support levels are jointly determined based on the support needed
to effectively remediate issues identified during the audit process. CAP Management fees incurred through our
monitoring partner will be the responsibility of the supplier..
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Rating
Category
CAP Support
Purpose
Green
Desktop Review
To verify evidence presented by the facility against the Corrective
Action Plan in order to ensure timely and appropriate closure of
non-conformances.
Yellow
Desktop Review or
CAP Support Light
To verify evidence presented by the facility against the Corrective
Action Plan in order to ensure timely and appropriate closure of
non-conformances.
Orange
CAP Support Depth and/or
On-Site Support Visit
CAP Support Depth: To provide support/tools to enable factories to
develop an acceptable CAP based on their most recent audit results.
This includes communication with the facility to identify the root
causes, appropriate corrective and preventive actions, and CAP due
dates; solicit evidence and review whether the corrective actions
have been fulfilled/remove finding (where applicable); and to ensure
that the facility corrects their non-conformance issues on the right
track.
On-Site Support Visit: To help the facility understand fundamental
elements of the CAP while verifying progress onsite.
Red
CAP Support Depth and/or
On-Site Support Visit
CAP Support Depth: To provide support/tools to enable factories to
develop an acceptable CAP based on their most recent audit results.
This includes the communication with facility for identification of the
root causes, appropriate corrective and preventive actions, and CAP
due dates.
To solicit evidence and review whether corrective action has been
fulfilled/remove finding (where applicable), and to ensure that the
facility corrects their non-conformance issues on the right track.
On-Site Support Visit: To help the facility understand fundamental
elements of the CAP while verifying progress onsite.
Chemical Management
Our Mission
Through the responsible management of chemicals and materials used at our facilities, and incorporated into our
products, Reformation strives to reduce environmental and occupational health and safety risks associated with
chemical exposures and hazardous wastes.
Our Company is Committed to:
● Safely and responsibly sourcing and managing chemicals purchased, used in production, and disposed of
after use.
● Striving to reduce the consumption of hazardous materials.
● Following all applicable laws and regulations related to chemicals management and discharges to the
environment.
● Ensuring all chemical hazards are communicated to all levels of staff.
● Ensuring final products conform to industry and government regulations.
Scope:
This policy outlines Reformation’s requirements for the safe and responsible management of all hazardous
substances used or brought on-site. This policy applies to all management and staff. Relevant sections of this policy
also apply to suppliers performing work for Reformation that involves the use of hazardous substances or work in
areas where hazardous substances are present.
The policy has been developed to ensure:
● The health and safety of all staff and contractors
● Compliance with regulatory requirements regarding hazardous substances
● Protection of the surrounding environment
Higg Facility Environmental Module (FEM)
As members of the Sustainable Apparel Coalition (SAC) we encourage use of Higg Facility Environmental Module
(FEM). The Higg FEM informs manufacturers, brands, and retailers about the environmental performance of their
individual facilities, empowering them to scale sustainability improvements. It helps identify and prioritize
opportunities for performance improvements. We are launching the Higg FEM with specific tier 1 & tier 2 suppliers
and will increase enrollment each year. Please let us know if you are interested in participating or are already
utilizing the Higg FEM.
Chemicals in Final Products
Final products must conform to industry and government regulations. It is important to not only focus on the
chemicals in final products but address hazardous substances potentially used and discharged into the
environment during manufacturing and related processes. This is commonly done through the adoption of a
Manufacturing Restricted Substance List (MRSL). The MRSL is a list of chemical substances banned from intentional
use in facilities that process textile materials and trim parts. It establishes acceptable concentration limits for
substances in chemical formulations used within manufacturing facilities. To test chemicals in materials or final
products, a Restricted Substance List (RSL), sets concentration limits for substances to comply with product
regulations and safety standards.
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Our Manufacturing Restricted Substance List (MRSL)
Our MRSL is in accordance with the Zero Discharge of Hazardous Chemicals (ZDHC) MRSL V2.0. This list applies to
chemicals that are used in facilities that process textile materials and trim in apparel and footwear, not just those
that remain in the finished product, with the intent to manage the chemicals that suppliers use while removing
hazardous substances from the manufacturing process. This includes not only chemicals used specifically for
production, but also cleaning supplies, machine cleaners, lubricants, etc. that are in use in the facility for
maintenance and support. The ZDHC MRSL sets restrictions on trace concentrations for banned chemical
substances that are not intentionally used but may be found as unintended contaminants within a commercial
chemical formulation. Companies should verify conformance with ZDHC requirements of at least level 1 through
the ZDHC ‘ Gateway ’. Examples of methods that could be used to verify safe chemistry beyond ZDHC Level 1
include, but are not limited to: Bluesign and C2C Certified™. While not third-party verification,we also accept
ChemSec and Jeanologia as self-assessment of chemical selection.
Visit https://www.roadmaptozero.com/mrsl_online/ to view an interactive electronic version of the MRSL. The full
version can be downloaded at https://www.dropbox.com/s/on7965zpwdmgw7g/ZDHC%20MRSL.pdf?dl=0 .
Our Restricted Substance List (RSL)
Our RSL is in accordance with AFIRM Group industry level standards. This list applies to raw materials, finished
goods and their components. We recognize that this effort requires listening to our suppliers and their employees’
needs, and requires a collaborative approach. Reformation is committed to helping suppliers by directing them to
necessary resources. All fabrics must meet our RSL which can be downloaded here .
Supplier Responsibility
All purchase orders must commit to adhering to our MRSL and RSL. Our direct supplier is responsible for sharing
the MRSL & RSL with all subcontractors and sub-suppliers from raw materials to finished product and ensuring the
standards are met.
Suppliers must adopt a chemical management policy that is monitored and measured. Suppliers should establish,
document and implement a process to monitor operating conditions needed to prevent the potential for adverse
impacts to health or the environment. The organization should document performance against the operating
criteria and maintain associated records.
Our Dyeing & Printing Standards
Dyeing, printing and tanning suppliers must restrict the use of harmful substances currently restricted by law, and
substances known to be harmful to human health. Also, all output water must be treated to local law expectations.
We do not permit direct dyeing, vat dyeing, disperse dyeing, 2-bath dyeing (reactive dyeing followed by disperse
dyeing), conventional soaping, continuous wash off, or discharge printing.
If you adopted natural dyes, azo- free dyes, phthalate free dyes, low-impact reactive inks, reusing water, optimizing
energy use, eliminating harmful substances, better cleaning agents, dye stuff carriers or any other efforts, let us
know.
In order to meet our clean chemistry goals for the future, we’ll only be authorizing new Tier 2 facilities (i.e., mills,
dye houses, and printers) that have one of the following certifications OR can show a ZDHC accepted indicator of
ZDHC MRSL conformance . The table below lists various clean chemistry certifications that we accept.
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Our Finishing Standards
We do not permit chlorine bleaching, silica, aluminum dioxide, formaldehyde containing resins for 3D/crinkled
effect, Ice/potassium permanganate, stone washing, conventional electroplating , PFC’s in DWR treatments or
sandblasting.
Below are techniques that will help reduce water and energy consumption.
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Dyeing & Printing Standards (One of the below certifications is required )
Oeko-tex Standard 100
Ensures that chemicals used throughout the production process are not
harmful to human health of the end-user. All raw materials and
intermediate products are certified.
STeP by Oeko-tex
Continuous improvement strategies for environmental efficiency and social
compliance in all stages of textile production.
Made in Green by Oeko-tex
Combines Standard 100, STeP, and adds QR code to allow end users to trace
a product's supply chain.
Bluesign
A+ grade in reducing environmental impact concerning the entire textile
supply chain.
Global Organic Textile Standard - GOTS
Certify authentic organic fiber content and responsible textile processing.
GOTS approved dyestuffs are available with companies like DyStar, Clariant,
etc.
Global Recycled Standard -GRS
Certify recycled fiber content, chain of custody, social and environmental
practices, and chemical restrictions.
Zero Discharge of Hazardous
Substances
Roadmap aimed at zeroing hazardous chemical release from mills, fabric
processing and finishing facilities by following a Manufacturing RSL.
ISO 14001:2004 Environmental
Management Systems
Framework for EMS that does not specify levels of environmental
performance, but assures external parties that the company is in control of
practices that impact the environment.
Sustainable Green Printing Certification
Facility certification program for sustainable printers.
Preferred (But Not Required) Dyeing & Printing Techniques
Digital Printing, Sublimation, Waterless Dyeing (like AirDye and DryDye) and Printing, Block Printing, Screen Printing,
Closed loop dyeing systems (like DyeCoo, water recycling)
Preferred (But Not Required) Regional Certifications
DISHA (India), Ekolabel Indonesia, Hong Kong Green Label Scheme, Singapore Green Label Scheme, Thai Green Label
Scheme, China Environmental Labeling, German Blue Angel, Nordic Ecolabel
Our Finishing Standards
Ozone
Used for garment lightening: combines bleach, neutralize and rinse baths
Ozone mist
Garment decolorizing by spraying water mist is sprayed into the ozone machine
Combine desize and
stone/enzyme wash
A four bath process can be reduced to two baths by combining steps, and
reducing a rinse step.
Here are ten industry best practices for optimized operations:
1. Install meters and detect leaks
2. Collect and recover condensate
3. Reuse cooling water
4. Reuse process and waste water
5. Recover heat from hot water
6. Improve boiler efficiency
7. Main steam traps and system
8. Improve insulation
9. Recover heat from exhaust gas and heating
10. Optimize compressed air
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Combine desize, enzyme wash
and bleach
A seven bath process can be reduced to five baths by combining the desize,
enzyme and bleach step. Needs specific chemistry.
Combine enzyme and softener
Saves a rinse step and a softener step. Technique works well with non-denim.
Sky chlorine-free bleach/rag
bleach
Undiluted chlorine-free bleach solution applied to rags which are tumbled with
garments, without water in the machine.
Low liquor ratio reactive
garment dye
Education around lower water levels in both reactive dye bath and rinse bath.
Remove desize step
Use soluble synthetic starches that dissolve in any bath.
High fixation reaction dye
Use high fixation reactive dyes to reduce hydrolysis and over deposition.
Neutralize chlorine-free bleach
in one bath
Combining bleach and neutralization can save one bath.
Foam dye/tine
A concentrated dye solution applied as a foam instead of a typical wet dye bath.
Foam chlorine-free bleach
Applied in foam form with chlorine-free bleach maintaining a max 1:1 liquor ratio.
Combine resin and tint steps;
apply by dipping
Add tint to the resin solution and applying through spray or dip. Tint wet bath
(and sometimes the rinse bath) is removed.
Enzyme spray stonewash
Enzyme mixture is sprayed onto garments followed by tumbling the garments in a
washing machine with steam. Technique uses abrasion without water or stones.
Spray softener
Apply undiluted softener in a tumble dryer with a spray to avoid a softener bath.
Soft rigid
Use balls/bottle caps to soften the fabric without water
Combine fixing and softener
Combine to save one fixation bath. Ensure fixer and softener are compatible.
Low liquor ratio chlorine-free
bleach
Modern machine design and technology allow laundries to significantly lower the
liquor ratio.
Low liquor ratio for desize
Modern chemistry and modern machine designs allow for low liquor ratio desize.
Education is needed
Low liquor ratio for synthetic
stonewash
Abrasion is equally effective with less water
Best Practices: Commercial Garment Washing
Energy Star ® certified equipment, Dryer safety- eg. lint removal, Training dryer operators on cool down types for
different fabrics, Fire safety to avoid spontaneous combustion, Electrical safety, Health safety, NZI Laundry Risk
Management Guide
Better Materials
Reformation is deeply committed to sourcing environmentally conscious materials. Our suppliers may only use our
approved materials and finishing techniques. Prior written approval must be obtained before any portion of the
product is vendor-sourced or substituted from our list of approved articles and vendors.
Ref Fiber Standards
Our full fiber standards can be found on the next page and here for download with “Allstars” and “Better Than
Most” being our preferred fibers.
We do not permit fabrics in the “Never Use” column, with the exception of Spandex (<10%) if necessary for the
construction of the garment. We do not allow recycled synthetics in our Tops, Bottoms, Jeans and Dresses that are
machine washable. We do allow recycled synthetics in our outerwear, swim, accessories and bridal or any other
items that care is hand-wash or dry clean.
We have also listed certifications, standards, and industry practices for Reformation’s preferred fibers, finishing
techniques, as well as dyeing and printing processes. We know certifications can be expensive- so if you have taken
any alternate routes to sustainability, we’d like to know!
Lenzing Fibers
All Lenzing fibers listed below must be verified through Lenzing after bulk production is produced. This is a free
service from Lenzing and requires the mill to send a few meters of fabric to Lenzing headquarters to test. Once
tested, Lenzing will provide a Lenzing Verification Letter. This letter will need to be sent to Reformation or uploaded
to QuickBase (see “How to fill in/edit the Component Table” in this handbook ) for our recordkeeping prior to
shipment of goods.
● TENCEL™ Lyocell, TENCEL™ Modal, ECOVERO™, TENCEL™ x REFIBRA™ Lyocell
Correct Labeling and Fabric Detail Sheets (FDS):
● For Organic Cotton labeling, unless the CMT facility is GOTS certified, content labels and FDS’ should be
submitted as “___% Organically Grown Cotton” not “Organic Cotton”.
● Any FDS’ submitted must accurately represent the fibers used as per guidelines herewith and have the
correct trademarks and generic fiber information (Lenzing correct trademark information highlighted
above).
Deadstock Fabrics
We define deadstock as verified old, leftover, and over-ordered fabric from other designers and fabric warehouses.
Our deadstock verification letter is required for any deadstock materials that you are sourcing, you can download
the letter translated in different languages (English, Hindi, Mandarin, Spanish, Turkish) here . This helps us to
ensure that any deadstock materials are indeed deadstock and not stocked/running items.
● The deadstock verification letter is translated into many different languages. Please note that all forms
must be filled in and sent back for approval in English regardless of the language of the document.
● Deadstock materials do not need to meet the fiber requirements that are highlighted in our Fiber
Standards but they must meet our RSL requirements.
Leather
We have strict requirements when sourcing leather. Please view our requirements in the footwear section.
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Certification and Sourcing Learning Center
We created a certification toolkit that highlights the basics of the certification process and requirements for your
review. It has information on how certifications work and how to identify the next steps for a facility to begin
certifying products.
● Please note for every certification, the mill must present a scope certificate with the specific product code
of the article we are purchasing prior to any POs being placed. This must be presented for verification
prior to PO being placed . After a PO is placed, a Transaction Certificate (TC) needs to be issued from the
mill.
● Please see links to the common certifications that we use at Ref: Global Recycled Standard (GRS) , Global
Organic Textile Standard (GOTS), Organic Content Standard (OCS) , Leather Working Group (LWG), Bluesign ,
Oeko-Tex Standard 100 .
● Here are some helpful trainings on certifications and chain of custody.
Additional Policies:
Ethical Animal Welfare
Reformation is committed to the humane conditions and treatment of animals. All our suppliers must respect
humane animal welfare practices and work continuously towards implementing a comprehensive process that
includes capture, maintaining, breeding, raising, transportation, handling and slaughter to ensure ethical conditions
and treatments of animals. Here is our full Animal Welfare policy.
Sustainable Forests Commitment
Reformation has signed a policy with Canopy (please see Appendix L ) to drive for positive change for all our forest
products and ensure all our forest-based products come from sustainably managed forests.
Additionally, we have commited to the Changing Markets roadmap to ensure that all the fiber manufacturers in our
supply chain move to a closed-loop manufacturing system by 2023-2025 to ensure the majority of chemicals used
during production are recycled and prevent the production process from negatively impacting on human health
and the environment
Please see below for more information on Changing Markets and Canopy and more information on how it affects
our sourcing.
● Link to Canopy's website for more information on audit cost and process.
● Link to Canopy's Hot Button Report which supplies information that outlines viscose fiber producers
partners and their ranking. A "green shirt" is the highest ranking, then yellow, then red and then white
(not yet engaged). The ranking is in order as displayed on their website.
● Link to the Changing Markets roadmap.
Prohibited Sourcing from Xinjiang
Reformation is a signatory to the Call to Action to End Uyghur Force Labor and prohibits sourcing and production
(including direct and indirect sourcing of raw materials, inputs, or finished products) from Xinjiang. Please refer to
our policy and benchmarks on Forced Labor and Responsible Recruitment below.
Traceability and Transparency
Reformation’s goal is to have traceability into all levels of our supply chain so we can confidently stand by our
sustainable product claims. In order to achieve supply chain transparency and traceability, we require any facility
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involved in the manufacturing of Reformation products to be disclosed to the Reformation Sustainability team
regardless of the facility level and production process, this includes but is not limited to mills, dye houses and
printers. Any information that you disclose to Reformation related to raw material composition, dyeing and
printing processes and their applicable certifications and/or verifications and any and all related processes must be
true. In addition, we expect our direct suppliers to accurately represent all supply chain traceability disclosed
regardless of the facility level or production process.
Any updates to contact information or production process shall be provided to the Reformation Sustainability team
immediately. Suppliers are responsible for maintaining inventory and production records to document the origin
and place of production of incoming materials.
Trims & Other Product Specific Guidelines
Trims
We do not permit plastics. We do not permit genuine horn, animal feathers or animal fur. Please note this applies to
deadstock and new developments.
Here are some guidelines for sustainable accessories by specific product categories. Please refer to our material
guidelines for full sustainability criteria.
Footwear
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Preferred (But Not Required) Practices & Materials
Buttons: Corozo, recycled paper horn, shell, coconut, hemp, mother of pearl, recycled glass, recycled wood
Zippers (materials for all components): Recycled PET, recycled zinc and brass, recycled nylon
Thread (optional): bio-based yarn, recycled PET thread yarn, cellulosic yarn, other recycled yarn
Embellishments: faux feathers made from hemp or recycled materials
We also look for the above materials in hook and eye, ring and sliders and other trims
Best practices: Recycled materials and nickel free metal
Required Practices & Materials
Leather (includes all leather components in shoe i.e. lining, sole, outer, pig split, etc.)
● Leather Working Group (LWG) certified (rated Gold or Silver)
● Tanneries must source 100% of hides from slaughterhouses outside Amazon biome. Leather cannot be
sourced from the following States of origin:
○ Amazonas
○ Roraima
○ Amapa
○ Acre
○ Para
○ Rondonia
○ Mato Grosso
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○ Tocantins
○ Maranhao
○ For leathers sourced outside of Brazil, these leathers must not come from deforested or
converted lands in Easter Paraguay, Columbia or Indonesia in accordance with leather Impact
Accelerator DCF protocol A2.3.1
● Physical stamping required on skins for all hides.
○ Exception: haircalf and suedes
○ Haircalfs and suedes must be sourced from nominated slaughterhouses in RS State, or from an
approved source outside of Brazil
○ Slaughterhouse and Pre-Tanning facility locations information must be provided to
Reformation. (Not at batch level.)
● Tannery must agree to Ref traceability audit & corrective action plan process. See Leather Traceability
for more information.
● Stretch leather must have a backing with a cellulose fiber with under 10% spandex (i.e. organically
grown cotton, TENCEL™Lyocell) that meets our fiber standards
Materials for all components (sole, upper, insole)
● Require use of <50% virgin plastic in Critical Components:
○ 1-Block Heels
○ 2-Toplifts
○ 3-Insole Foams
○ 4-Rubber Outsoles
○ 5-Synthetic Leather
● Wood: Must be FSC certified (Must be able to provide FSC/ recycling certificate (including FSC FM codes)
● Zippers: (materials for all components): Recycled PET or nylon, recycled zinc and brass, nickel free
● Anti mold chip: Natural (i.e. clay)
● Shoe laces and ribbon: Must meet our full fiber standards (i.e. certified organic or recycled fiber)
● Fabrics: (i.e. satin, canvas, velvet, faux fur): Must meet our full fiber standards
● Embellishments: We do not permit plastics, animal feathers, or animal fur.
○ Instead use cork, recycled brass, reclaimed metals, recycled aluminium, recycled stainless
steel,, bio-resins, glass that meets all rsl requirements or deadstock embellishments
Packaging (shoe boxes, cartoon, and tissue paper)
● 100% recycled paper (90%+ total recycled content)
● Must be able to provide FSC/ recycling certificate (including FSC FM codes)
● Bleaching: Must be processed Chlorine Free (PCF) or Totally Chlorine Free (TCF)
Preferred* (But Not Required) Practices & Materials
Leather
● Slaughterhouses located in Rio Grande do Sul State
● Use of Reformation-nominated slaughterhouses/ pre-tanning facilities
● Traceability to Farm:
○ Ability to provide GTA paperwork to show farm location *preferred
○ OR ability to provide full list (state location) of farms that serve the nominated slaughterhouses
○ OR ability to provide full list (state location) of all farms for all slaughterhouses sourced from if
unable to nominate
● LWG Traceability score of >50%
Design
Design for disassembly, Cradle2Cradle design, durability, reuse/recycling/upcycling program in facilities to reduce
waste
*Preferred must be used whenever commercially available as long as:
● Passes all performance testing at the same standard as its non-preferred alternative
● Is locally available in market (does not require import)
● Does not increase bulk lead time by more than 5 business days
● Does not increase first cost the lower of 3% or $2
Recommended Vendors - Critical Components
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Materials for all non-leather components (sole, upper, insole)
● Prefer as low % virgin plastics as possible across all components, including not but limited to:
○ Stiletto/Skinny Heels
○ Zippers/Zipper Tapes
○ Elastics
○ Reinforcements
○ Ornaments
○ Outsoles, Toplifts and Sheet Stocks
● Post Consumer recycled contents are preferred over Post Industrial
● Natural/ Wild Rubber (FSC Certified)
● Recycled and/or Biobased ABS
Adhesives
● Natural latex, water based adhesives, soy-based adhesives, solvent-free adhesives.
Printing, Finishes and Coatings
● Water-based inks
● Bluesign system approved printing & dyeing facilities
Packaging
● FSC certified
● Plant-based inks (i.e. soy-based, vegetable-based ink)
Component
Vendor
Reference #
Description
Natural/Recycled
Contents
Plastic
Contents
Injected Heel
Injetados
Bourscheid
TBC
Post-Consumer
Recycled ABS
~80% recycled
contents
~20% virgin
petro-based
ABS
Top Lift
Tacosola
MS 660
High Natural-
Content Rubber
~60% Natural
Rubber from Sao
Paolo State
20-23%
petro-based
SBR
Insole Padding
Tacosola
EVA 1023
Low-Density
Sugar-Cane EVA
Up to 55%
Sugar-Cane based
~20%
petro-based
Vinyl Acetate
Rubber Outsole
Tacosola
TC2090
Blend of Natural
and Recycled
Rubber
>45% Natural
Rubber, 15%
Recycled Rubber
12-16%
petro-based
SBR
Jewelry and Hardware
We prioritize the use of recycled metals and we want to know the metals and alloys used in our products as well as
the origin of any mined materials. We do not use plastics or other petroleum based products in our jewelry and
hardware.
Sunglasses
We do not permit the use of petroleum based components in our frames, lenses or screws.
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Required Practices & Materials
Metal
We require that our suppliers report the metals and specific metal alloys that they are using in products for
Reformation. We want to know the percentage of recycled metals in our components as well as if recycled
content is pre or post consumer. If recycled content, SCS certifications or like certifications should be provided.
Suppliers should have Environmental Management Systems in place to deal with toxic effluents that are as a
result of metal processing and finishing. Suppliers should be willing to explore finishing options outside of
conventional electroplating.
Affirm 2020 RSL compliant
Preferred (But Not Required) Practices & Materials
Metal
For hardware we prioritize recycled metal alloys that do not contain nickel. Prefered alloys include brass,
aluminum and stainless steel and zamac (price point) for hardware and some jewelry.
For fine jewelry- Sterling silver, Fairtrade Silver and Gold.
Mining level certifications
Metals - Standard for Responsible mining by Initiative for Responsible Mining Assurance (IRMA) candidate
(orange) or certified (red).
Fine Metals, Semi Precious and Precious Stones- Standard for Responsible mining by Initiative for Responsible
Mining Assurance (IRMA) candidate (orange) or certified (red), Fairmined certification Alliance for Responsible
Mining for small scale mining, Responsible Jewelry Council.
Additional material components
Nonmetal elements such as cork, biobased resins, cellulose acetate, glass that meets RSL requirements and
certified responsibly harvested shell. Semi precious and precious stones fairmined and confirmed non conflict.
Best practices
Toxic chemical free, nickel free and ZDHC MRSL compliant
Suppliers should have Environmental Management Systems in place to deal with toxic effluents that are as a
result of metal processing and finishing.
Preferred (But Not Required) Practices & Materials
Materials for all components
Recycled acetate, FSC®/Rainforest Alliance Certified wood, sustainable bamboo (optional certifications:
FSC®/Rainforest Alliance Certified, regional certifications, lightweight aluminium, stainless steel, cork, recycled
materials, reclaimed wood, reclaimed materials.
ACKNOWLEDGEMENT OF RECEIPT AND ACCEPTANCE OF TERMS
I acknowledge receipt of Reformation’s Sustainable Partners Guide, Version 3 (SGP V3). I have read, and
understand, the importance of the policies and procedures set forth herein and agree to comply with all the terms
and conditions set forth within the SGP V3. Failure to comply will result in a chargeback or cancellation of orders. If
Reformation does not receive a signed copy of acknowledgment within 14 days of the receipt of the manual, we
will assume that you accept the term of the Sustainable Partners Guide . Supplier and its employees and agents
shall not at any time, during or after the receipt of the SGP V3, disclose to others and take or use for its own
purposes or the purpose of others any trade secrets, confidential information, knowledge, designs, data,
know-how, or any other information reasonably considered by Reformation to be “confidential.” Supplier
recognizes that this obligation applies not only to technical information, designs and marketing, but also to any
business information that Reformation treats as confidential. Any information that is not readily available to the
public shall be considered to be a trade secret and confidential.
Please confirm your agreement to our terms of the Sustainable Partners Guide V3 by signing in the space
provided.
I represent and warrant that I have authority to sign on behalf of the company named below and to bind the
company named below to the terms of this Policy.
ACCEPTED AND AGREED TO:
Facility Name:
Name of Company Officer:
Title of Company Officer:
Signature of Company Officer:
Date:
Please be sure to complete, sign, scan and return this form via email*.
REFORMATION
Attn: Carrie Freiman
2263 E Vernon Ave
Vernon, CA, 90058
sustainability@thereformation.com
*Subject: Supplier name: Signed Acknowledgment of Receipt
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Sustainability Team Contact Information
Please see below contacts for the Sustainability Team:
Address:
2263 E Vernon Ave
Los Angeles, CA 90058
Kathleen Talbot
Chief Sustainability Officer & VP of Operations
Email: kathleen.talbot@therefomation.com
Carrie Freiman
Director of Sustainability
Email: carrie.freiman@thereformation.com
Mara Ley
Sustainability Coordinator
Email: mara.ley@thereformation.com
Priscilla Pacheco
Social Compliance Associate
Email: priscilla.pacheco@thereformation.com
For general inquiries, please contact sustainability@thereformation.com
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Appendix A: Chargebacks for Social and Environmental Compliance
Appendix B: Scheduling a Social Assessment with our Preferred Assessment Partners
Scheduling an Initial Assessment with Labor Law Monitoring (FOR CALIFORNIA SUPPLIERS ONLY):
● To schedule your initial assessment with Labor Law Monitoring, please contact David Fitzpatrick directly by
email at [email protected] or by phone at 714-904-2741.
● Assessments will be semi-announced (approx. 14-day window)
○ Please leave at least 3 weeks for scheduling.
● All new facilities must complete an assessment prior to the production of any Reformation goods unless a
mutual recognition assessment has been submitted and accepted.
● Assessment reports will be sent directly to Reformation.
● Please refer to Appendix C-F for all documents required for an assessment: Assessment Frequently Asked
Questions (FAQ), Document List, and Factory Code of Ethics (COE) Letter.
Scheduling an Ongoing Assessment with Labor Law Monitoring or Elevate (FOR CALIFORNIA SUPPLIERS ONLY):
● Dependent on the previous assessment rating, Reformation will either coordinate ongoing assessments
directly with Labor Law Monitoring or instruct the vendor to schedule through Elevate by following the
Reformation Guidance
● Assessments will be semi-announced (approx. 14-day window)
● A scheduling confirmation email will be sent to vendors, informing them of the upcoming assessment and
scope 2 weeks before their assessment window.
● A reminder will be emailed to the vendors 1 week before the assessment window to confirm the facilities'
understanding of their upcoming visit.
● Assessment reports will be sent directly to Reformation.
● If you have any questions about your scheduled upcoming assessment with Labor Law Monitoring or with
Elevate, please contact the Social Compliance Associate, Priscilla Pacheco,
priscilla.pacheco@thereformation.com .
● Please refer to Appendix C-F for all documents required for an assessment: Assessment Frequently Asked
Questions (FAQ), Document List, and Factory Code of Ethics (COE) Letter.
Scheduling an Assessment with Elevate (FOR ALL INITIAL ASSESSMENTS & ONGOING MONITORING):
● To schedule an assessment with Elevate, please follow the instructions in the Reformation Guidance .
● Assessments will be semi-announced (approx. 14-day window)
● Please leave at least 6 weeks for scheduling. All new facilities must complete an assessment prior to the
production of any Reformation goods unless a mutual recognition assessment has been submitted and
accepted.
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Infraction
Chargeback
Denied Inspection
The full cost of the assessment as billed by the
monitoring partner + all related costs to correct or
resolve the noncompliance
Bribe/Improperly Influenced Inspection
$10,000.00 or full value of PO whichever is less + all
related costs to correct or resolve the noncompliance
● Assessment reports will be sent directly to Reformation.
● If you have any questions about scheduling your assessment with ELEVATE, please contact the relevant
coordinator for your region/country with “The Reformation Audit: [Country]” in the email title:
(1) North Asia: Siren Liu, siren.liu@elevatelimited.com
(2) South & Southeast Asia: Nhi Ngo, nhi.ngo@elevatelimited.com (all countries except India & Vietnam)
● India: Kavita Verma, kavita.verma@elevatelimited.com
● Vietnam: Ana Nguyen, ana.nguyen@elevatelimited.com
(3) USA & Canada: Ceren Ermis, cermis@elevatelimited.com or Ayari Flores, aflores@elevatelimited.com
(4) Latin America: Magalli Sanchez, msanchez@elevatelimited.com
(5) Europe: Alessandra Fabbri, alessandra.fabbri@elevatelimited.com
(6) Bangladesh & Pakistan: Farzana Afrin, farzana.afrin@elevatelimited.com
● Please refer to Appendix C-F for all documents required for an assessment: Facility Assessment Frequently
Asked Questions (FAQ), Document List, and Factory Code of Ethics (COE) Lette
Appendix C: Facility Assessment Approach and Guidance, and Frequently Asked Questions (FAQ)
Elevate: Please download the facility assessment approach & guidance here .
Labor Law Monitoring: Please download the assessment frequently asked questions (FAQ) here .
Appendix D: Document List Required to Complete Assessment
Elevate: Please download the document list in your preferred language, here .
Labor Law Monitoring: Please download the document list here .
Appendix E: Self Assessment Questionnaire for Pre-Screening
Please download the Self Assessment Questionnaire here .
Appendix F: Factory Code of Ethics (COE) Letter
Please download the COE Letter in your preferred language, here .
Appendix G: Fair Trade Principles
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Artisan facility/Artisan Group
Artisan Rights and Wellbeing: Artisan production must be free of any form of discrimination, harassment or
abuse whether at home or in a central workshop. All production must be at will and must not be performed by
individuals who are forced, bonded, indentured or trafficked.
Artisans must have a clear documented means to voice their opinions and report concerns to management
without fear. In central production facilities, artisans’ lawful rights to freedom of association and collective
bargaining must be respected.
All production (including home based and piece-based) must be tracked and completed within cumulative hours
of work that are in full compliance with all local laws, with leeways of irregularity of the production calendar.
The Code and accompanying Company policies must be communicated to all artisans in a manner that is
intended to provide them with an understanding of their rights, in the local language and with provisions for
illiteracy. All managers and subcontractors within the supply chain are expected to uphold the principles
contained within this Code of Conduct.
Transparent Records and Legal Compliance: Artisan businesses must maintain honest and up-to-date records of
their policies, operations, wages, and production site locations. These records must be kept onsite and should
exist in digital format. Vendor must be in direct contact with the artisan group.
Artisan production elements must comply with all statutory requirements – including legal status when
Appendix H: Self Assessment Questionnaire for Fair Trade
Please download the Fair Trade Self Assessment from here .
Appendix I: Fair Labor Association (FLA) Workplace Code of Conduct and Compliance Benchmarks
Please find below benchmarks to serve as a basis for monitoring compliance with laws and regulations. For
translations of the Workplace Code of Conduct and Compliance Benchmarks in other languages please click here .
FLA WORKPLACE CODE OF CONDUCT AND COMPLIANCE BENCHMARKS
I. EMPLOYMENT RELATIONSHIP (ER)
WORKPLACE CODE PROVISION: Employers shall adopt and adhere to rules and conditions of employment that
respect workers and, at a minimum, safeguard their rights under national and international labor and social
security laws and regulations.
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required. Records from artisan production elements should clearly demonstrate the businesses’ operations,
employment, contractor processes, and appropriate use of funding and other resources.
All elements participating individuals should understand their role in the larger supply chain and the traceability
of their raw materials.
Worker Representation: Democratically elected worker representative(s) communicate with facility management
regularly.
Economic Development: Percentage of cost of goods sold is paid to worker body in a separate bank account.
Workers/worker committee decide the best way to use this cash pot.
Pay Promptly and Fairly by discussing costs and pricing openly so that producers are able to earn a fair wage that
is above the local minimum wage. Piece-rate payment must utilize time studies to ensure compliance. Guidelines
for deductions and overtime wages must be clearly defined and stated to the artisans. Where applicable,
artisans must be provided all statutory benefits.
Create Opportunities for economically and socially marginalized farmers and artisans through long term trading
partnerships. Build capacity of farmers, artisans, and their communities by providing shared learning lessons,
access to market and best practices, financial support and connecting producer groups.
Health and Safety: Artisan Production site – whether a central small workshop or home-based site – must be a
clean and safe working environment in compliance with applicable laws and regulations. Artisans must be
educated in the importance of safety; trained on proper procedures for machinery and chemical use when
warranted; and have access to PPE, safe machinery, sanitation, and emergency procedures.
Ensure the Rights of Children: Children under lawful age of employment, consistent with ILO guidelines, should
never participate in artisan production.
Respect Cultural Identity of the farmers and artisans and celebrate diversity. Fair trade products and production
methods respect the traditions of the local communities.
Continuous Improvement: Artisan business management demonstrates a commitment to improvement on any
areas not in compliance with Reformation’s Supplier Code of Conduct and Artisan Fair Trade criteria.
ER.1 Employment Management Systems / Human
Resources
ER.1.1 Employers shall have in place written policies
and practices and maintain proper and accurate
records governing all aspects of employment from
recruitment, hiring and probation, including written
terms and conditions of employment, job descriptions,
administration of compensation, and working hours for
all positions, through to retrenchment and termination
processes.
ER.1.2 Employers shall assign responsibility for the
administration of human resources to a clearly defined
and adequately qualified staff member or staff
members and ensure workers at all levels receive
communication and training about existing policies and
procedures or any revisions.
ER.1.3 Employers should implement an annual review
process with input from workers of all policies,
procedures and their implementation to ensure they
meet legal requirements and the FLA Workplace Code.
ER.2 Employment Management Systems / Special
Categories of Workers
Employers shall ensure that all legally mandated
requirements for the protection or management of
special categories of workers, including migrant,
juvenile, contract/contingent/temporary, probationary
workers, home workers, and pregnant or disabled
workers, are implemented. Where local laws and FLA
standards differ, the employer is expected to follow the
highest applicable standard
ER.3 Employment Management Systems / New
Employee Orientation
ER.3.1 Employers shall provide an orientation to new
employees at the time of hiring, which includes
explanations of the employers’ rules, compensation
package and policies for human resources, grievance
systems, industrial relations, including respect of the
right to freedom of association, workers’ rights and
responsibilities, FLA Code of Conduct, health and
safety, and environmental protection.
ER.3.2 Training should be updated on a regular basis,
and in particular, when any policies and procedures are
revised.
ER.3.3 Workers should be provided with written
documentation that substantiates all the issues
covered in orientation briefings.
ER.4 Employment Management Systems /
Communication
Employers shall inform workers about workplace rules,
environmental protection systems, health and safety
information, and laws regarding workers’ rights with
respect to freedom of association, compensation,
working hours, and any other legally required
information, and the FLA Code through appropriate
means, including posted in local language(s)
throughout the workplace’s common areas.
ER.5 Employment Management Systems / Supervisor
Training
ER.5.1 Employers shall ensure that all supervisors are
trained in national laws, workplace regulations, and the
FLA Code, workplace grievance systems, and the
appropriate practices to ensure compliance.
ER.5.2 Employers shall inform supervisors that they
should not use any form of harassment or abuse to
maintain labor discipline.
ER.5.3 Trainings should be updated on a regular basis.
ER.6 Employment Management Systems / Skills
Development Training
ER.6.1 Employers shall have written policies and
procedures and implement practices that encourage
ongoing training of all categories of workers with the
goal of raising or broadening skills in order to advance
in their careers within the workplace or beyond.
ER.6.2 The policies and procedures should include how
workers will be informed of training opportunities,
eligibility requirements for participation, if the training
will be compulsory or voluntary, if it will take place
during or after working hours, and if the training time
will be compensated.
ER.7 Employment Management Systems
/Performance Reviews
ER.7.1 Employers shall have written policies and
procedures with regard to performance reviews that
outline the review steps and process, demonstrate
linkages to job grading, prohibit discrimination, are
provided in writing and seek feedback and
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agreement/disagreement from employees in writing,
and that follow all local legal requirements.
ER.7.2 The performance review process should be
communicated to the workforce and reviewed
regularly.
ER.8 Employment Management Systems/Promotion,
Demotion and Job Reassignment
Employers shall have written policies and procedures
with regard to promotion, demotion, and job
reassignment that outline the criteria, demonstrate
linkages to job grading, and prohibit discrimination or
use of demotion or job reassignment as a form of
penalty or punishment, are provided in writing and
seek feedback from employees in writing, and follow
all local legal requirements
ER.9 Recruitment and Hiring / Contract, Contingent or
Temporary Workers
ER.9.1 Employers shall hire
contract/contingent/temporary workers only if such
hiring is consistent with the national law of the country
of production.
ER.9.2 Employers shall have in place written policies
and procedures regulating the recruitment and hiring
of contract/ contingent/ temporary workers.
ER.9.3 Contract/contingent/temporary workers shall
only be hired if one of the following conditions is met:
ER.9.3.1 the permanent workforce of the enterprise is
not sufficient to meet unexpected or unusually large
volume of orders;
ER.9.3.2 exceptional circumstances* may result in great
financial loss to the supplier if delivery of goods cannot
be met on time;
ER.9.3.3 work that needs to be done and is outside the
professional expertise of the permanent workforce.
ER.10 Recruitment and Hiring / Invalid Use of
Contract, Contingent or Temporary Workers
ER.10.1 Employers shall not hire contract/ contingent/
temporary workers as a means to support continuing
business needs on a long-term basis.
ER.10.2 Employers shall not renew contracts for
multiple successive short terms in lieu of providing
regular employment.
ER.11 Recruitment and Hiring / Terms for Contract,
Contingent, Migrant or Temporary Workers
Employers must ensure the following minimum terms
and conditions are met in the employment of contract/
contingent/ migrant /temporary workers:
R.11.1 The enterprise must define the job functions or
tasks that contract /contingent/migrant/temporary
workers are hired to perform and maintains
information on the use of contract/ contingent/
migrant/ temporary workers in relation to production
needs;
ER.11.2 Contract/contingent/migrant/temporary
workers shall be provided an employment agreement
in their native language setting out the employment
terms and conditions. For migrant workers, a copy of
their employment contract in their native language
shall be provided prior to departure from their country
of origin;
ER.11.3 Workplace rules and regulations apply to
contract/contingent/migrant/temporary workers the
same as for permanent workers;
ER.11.4 National laws governing
contract/contingent/migrant/temporary workers shall
be observed.
ER.11.1.5 Personnel files and all relevant employment
information for contract/ contingent/ migrant/
temporary workers shall be maintained and accessible
at the workplace site at all times;
ER.11.1.6 Contract/ contingent/ migrant/ temporary
workers who are hired on more than one occasion for
seasonal production and specialization shall sign a
separate contract for each new hire event. The
workplace must retain all relevant information in each
worker’s personnel file; and
ER.11.1.7 Contract/ contingent/ migrant/ temporary
workers shall be given priority when the enterprise is
seeking ‘new’ permanent employees.
ER.12 Recruitment and Hiring / Transition to
Permanent Employee
For any contract/contingent/temporary worker who
becomes a permanent employee, seniority and other
benefits eligibility must be dated from the first date as
a contract/contingent/temporary worker and not from
the first day of permanent employment.
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ER.13 Recruitment and Hiring / Apprenticeships and
Vocational Training
ER.13.1 Employers shall comply with all regulations and
requirements of apprentice or vocational education
programs, and shall be able to document to monitors
that these are legally recognized programs. Informal
arrangements of any kind are not acceptable.
ER.13.2 Apprentice and vocational training programs
shall be reserved exclusively for workers who lack
necessary training or experience and therefore cannot
yet be hired as regular workers.
ER.13.3 Apprentice and vocational training programs
shall be subject to workplace conditions as set by the
FLA Workplace Code and national laws and regulations.
ER.14 Recruitment and Hiring / Employers Agreement
with Employment Agencies
ER.14.1 Employers shall use standard contract
language with employment agencies or intermediaries
that specifically imparts power to employers to directly
pay wages to migrant/contract/contingent/temporary
workers and ensures equality of compensation and
workplace standards as set under the FLA Workplace
Code and national laws and regulations.
ER.14.2 Employers shall use standard contract
language with employment agencies or intermediaries
that specifically prohibits practices that restrict any
worker’s freedom of movement or ability to terminate
their employment.
ER.15 Termination and Retrenchment / Termination
Payouts
ER.15.1 Employers shall have in place a procedure for
determining termination payouts, including methods
for correct assessment of payouts for all modes of
termination/retrenchment, taking into account
national legal requirements.
ER.15.2 Employers shall establish channels for workers
to confidentially express any concerns or problems
they may be experiencing around legally owed
payment during a retrenchment process.
ER.15.3 Employers shall not demand that workers sign
any declaration of good health, waivers or releases of
other rights as a condition of receiving severance pay
or other legal benefits* from the company, and shall
not threaten to withhold benefits if workers do not
sign.
ER.15.4 Upon termination, severance shall be based
upon the worker’s current salary and seniority as
calculated from the initial date of hire.
ER.15.4.1 Where employers provide advance
termination payouts as allowed by law, these amounts
may be subtracted from the final severance payment
but must be included as itemized deductions in the
final severance calculation.
ER.15.5 Where employers provide annual
indemnization, original contracts should remain
without being terminated.
ER.16 Termination and Retrenchment / Policies and
Procedures
ER.16.1 Employers shall maintain proper and accurate
records in relation to termination and retrenchment.
ER.16.2 When employers are faced with major changes
in production, program, organization, structure, or
technology and those changes are likely to result in
temporary or permanent layoffs, employers shall
communicate any alternatives to retrenchment that
have been considered and consult any workers’
representatives as early as possible with a view to
averting or minimizing layoffs.
ER.16.3 Where temporary or permanent layoffs are
unavoidable, a plan should be developed and
implemented that mitigates the adverse effects of such
changes on workers and their communities.
ER.16.4 The plan should be clearly communicated and
posted, and include feedback channels for workers to
ask questions and provide feedback.
ER.16.5 Employers shall give retrenched workers
opportunity to transfer to other owned facilities in the
country at a comparable wage and make all efforts to
facilitate re-employment in other enterprises in the
country.
ER.17 Grievance System / Worker-Management
Communication
ER.17.1 Employers shall have a clear and transparent
system of worker and management communication
that enables workers to consult with and provide input
to management. This might include suggestion boxes,
35
worker committees, designated spaces for worker
meetings, union representatives, and meetings
between management and workers’ representatives.
ER.17.2 There shall be a mechanism that allows
workers to report harassment and grievances
confidentially, including any concerns or problems they
may be experiencing around legally owed payments
during a retrenchment process.
ER.17.3 Employers shall have in place written
procedures that allow a direct settlement of the
grievance by the worker and the immediate supervisor.
Where this is inappropriate or has failed, there should
be additional options for senior management review
and consideration, depending on the nature of the
grievance and the structure and size of the enterprise.
ER.17.4 Employers shall ensure that the grievance
procedures and applicable rules are known to workers,
and that workers are fully trained on their use.
ER.17.5 Employers shall have in place procedures to
track the number, types, and timing and resolution of
grievances, and to communicate the resolution of
grievances to the workforce.
ER.17.6 Employers shall have a system in place to
prevent retaliation against or discrimination towards
workers who are filing grievances, including grievances
regarding harassment, abuse, violations of factory
procedures, compensation*, or unsafe working
conditions.
ER.18 Work Conduct and Discipline / General
Principles
ER.18.1 Employers shall have written disciplinary rules,
procedures and practices that embody a system of
progressive discipline (e.g. a system of maintaining
discipline through the application of escalating
disciplinary action moving from verbal warnings to
written warnings to suspension and finally to
termination).
ER.18.1.1 The disciplinary system shall be applied in a
fair and nondiscriminatory manner and include a
management review of the actions by someone senior
to the manager who imposed the disciplinary action.
ER.18.1.2 Employers shall maintain written records of
all disciplinary actions taken.
ER.18.2 Employers shall ensure managers and
supervisors are fully familiar with the workplace
disciplinary system and in applying appropriate
disciplinary practices.
ER.18.3 Workplace Rules and policies, and disciplinary
procedures and practices shall be clearly
communicated to all workers in the language(s) spoken
by workers. Any exceptions to this system (e.g.
immediate termination for gross misconduct, such as
theft or assault) shall also be in writing and clearly
communicated to workers.
ER.18.3.1 Workers must be informed in writing when a
disciplinary procedure has been initiated against them.
ER.18.3.2 Workers have the right to participate and be
heard in any disciplinary procedure against them.
ER.18.3.3 Workers must sign all written records of
disciplinary action against them.
ER.18.3.4 Records of disciplinary action must be
maintained in the worker’s personnel file.
ER.18.4 The disciplinary system shall include a
third-party witness during imposition, and an appeal
process.
ER.18.5 Employers shall inform workers that any form
of harassment or abuse in the workplace shall be
subject to disciplinary measures.
ER.18.6 The workplace shall commit to non-retaliation
for all steps of the disciplinary process, including for a
worker requesting a witness and filing an appeal of
disciplinary action.
ER.19 General Compliance / Documentation and
Inspection
ER.19.1 Employers shall maintain on file all
documentation needed to demonstrate compliance
with the FLA Workplace Code and required laws.
ER.19.1.1 Employers shall make these documents
available to third-party assessors commissioned by the
FLA and shall submit to inspections without prior
notice.
ER.19.2 All notices that are legally required to be
posted in the workplace work areas shall be posted by
employers.
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II. NON-DISCRIMINATION (ND)
WORKPLACE CODE PROVISION : No person shall be subject to any discrimination in employment, including hiring,
compensation, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability,
sexual orientation, nationality, political opinion, social group or ethnic origin.
ND.1 General Compliance Nondiscrimination
ND1.1 Employers, employment agencies, and
intermediaries shall comply with all national laws,
regulations and procedures concerning
non-discrimination. Where local laws and FLA
standards differ, the employer, employment agency,
and intermediary is expected to follow the highest
applicable standard.
ND.1.2 If not provided by law, employers must provide
protection to workers who allege discrimination in any
form, including recruitment and employment practices,
compensation, marital, or health status.
ND.2 Employment Decisions
ND.2.1 All employment decisions shall be made solely
on the basis of a person’s qualifications, in terms of
education, training, experience, demonstrated skills
and/or abilities, as they relate to the inherent
requirements of a particular job.
ND.2.2 Employment decisions shall not be made on the
basis of gender, race, religion, age, sexual orientation,
nationality, political opinion, social group, ethnic origin,
marital status, or union affiliation or sympathy.
ND.3 Job Advertisements, Job Descriptions and
Evaluation Policies
Recruitment and employment policies and practices,
including job advertisements, job descriptions,
application and interview questions and job
performance/evaluation policies and practices shall be
free from any type of discriminatory bias.
ND.4 Disclosure of Personal Information
Employers may not request the disclosure of any
personal, non-job related information during the
application, recruitment, or hiring process, including
but not limited to gender, race, religion, disability,
sexual orientation, nationality, political opinion, social
group, ethnic origin, or marital status.
ND.5 Compensation Discrimination
There shall be no differences in compensation for
workers for work of equal value on the basis of gender,
race, religion, age, disability, sexual orientation,
nationality, political opinion, social group or ethnic
origin.
ND.6 Marital, Partnership, or Family Discrimination
ND.6.1 Employers shall not discriminate on the basis of
marital, partnership, or family status.
ND.6.2 Employers shall not threaten workers with
dismissal or any other employment decision that
negatively affects their employment status in order to
prevent them from changing their marital, partnership,
or family status (including getting married or becoming
pregnant.)
ND.6.3 Employers shall not, on the basis of a worker's
marital, partnership, or family status (including
pregnancy), make any employment decisions that
negatively affect employment status, including
decisions concerning dismissal, demotion, loss of
seniority, or deduction of wages.
ND.7 Pregnancy Testing
ND.7.1 Employers shall not require pregnancy testing
of workers, except as required by national law.
ND.7.1.1 Employers shall not under any circumstances
use pregnancy tests or the use of contraception in their
hiring or employment decisions, even in cases where
pregnancy tests are required by national law.
ND.8 Protection and Accommodation of Pregnant
Workers and New Mothers
ND.8.1 Employers shall abide by all protective
provisions in national laws and regulations benefitting
pregnant workers and new mothers, including
provisions concerning maternity leave and other
benefits; prohibitions regarding night work, temporary
reassignments away from work stations and work
environments that may pose a risk to the health of
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pregnant women and their unborn children or new
mothers and their newborn children, temporary
adjustment of working hours during and after
pregnancy, and the provision of breast-feeding breaks
and facilities.
ND.8.1.1 Where such legal protective provisions are
lacking, employers shall take all necessary measures to
ensure the safety and health of pregnant women and
their unborn children.
ND.8.1.2 Where legal protective provisions are lacking,
employers shall, at minimum provide paid leave for
regular pre-natal and post-natal doctor visits as well as
breast-feeding breaks.
ND.9 Health-Related Discrimination
Employers shall not, on the basis of a person’s health
status, make any employment decisions that negatively
affect the person’s employment status, including
decisions concerning recruitment, termination,
promotion, or assignment of work, unless such
decision is dictated by the inherent requirements of
the job or a medical necessity to protect the worker
and/or other workers.
ND.10 Medical Examination
Employers are allowed to require routine medical
examination to assess general fitness as a condition for
recruitment or continued employment but shall not
include testing for any disease or illness, such as
HIV/AIDS, that does not have an immediate effect on a
person’s fitness and is not contagious.
ND.11 Confidentiality of Health Status
Employers shall respect the confidentiality of workers’
health status and not undertake any action that could
lead to a breach of said confidentiality, including
screening, whether by direct or indirect testing (for
instance, by making an assessment of risk behavior), or
asking questions about previously taken tests or
medications.
ND.12 Reasonable Accommodation for Health
Reasons
Employers shall take measures to reasonably
accommodate workers with chronic illnesses, including
HIV/AIDS-related illnesses, which could include
rearrangement of working time, the provision of
special equipment, opportunities for rest breaks,
time-off for medical appointments, flexible sick leave,
part-time work and return-to-work arrangements.
ND.13 Reasonable Accommodation, Modifications,
and Adjustments
ND.13.1 Employers shall make all reasonable
modifications and adjustments to accommodate
specific religious, ethnic, gender, and disability-based
needs of all workers within the workplace as well as
within any employer- provided facilities such as
dormitories or transportation.
ND.13.2 Workers shall not be required to reimburse
the factory for the cost of these accommodations.
ND.14 Dress Codes and Uniforms
ND.14.1 Employers shall not impose any discriminatory
restrictions on the dress or appearance of workers.
ND.14.2 In cases where the workplace requires
uniforms or other specific clothing, accommodations
shall be made for religious practice or disability.
ND.14.3 In cases where a workplace dress code is in
place, the dress code shall not discriminate against or
set different standards for ethnic or cultural groups.
ND.15 Spoken Languages
ND.15.1 Employers shall not require specific languages
to be spoken in the work environment, nor shall they
prohibit the use of any languages among workers.
ND.15.2 Employers shall make every reasonable effort
to communicate to workers in their native language.
III. HARASSMENT OR ABUSE (H/A)
WORKPLACE CODE PROVISION : Every employee shall be treated with respect and dignity. No employee shall be subject
to any physical, sexual, psychological or verbal harassment or abuse.
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H/A.1 General Compliance Harassment or Abuse
H/A.1.1 Employers shall comply with all national laws,
regulations and procedures concerning discipline,
violence, harassment and abuse, including that which
is gender-based.
H/A.1.2 If not provided under law, employers must
provide protection to workers who allege harassment
or abuse violations.
H/A.1.3 If not provided under law, employers must
provide protection to workers who are victims of
domestic violence.
H /A.2 Discipline / Monetary Fines and Penalties
Employers shall not use monetary fines and penalties
as a means to maintain labor discipline, including for
poor performance, for broken or lost tools/machinery,
or for violating company rules, regulations, and
policies.
H/A.3 Discipline / Access to Facilities
Access to food, water, toilets, medical care or health
clinics or other basic necessities shall not be used as
either reward or as a means to maintain labor
discipline.
H/A.4 Discipline / Physical Abuse
Employers shall not use any form of – or threat of –
physical violence, including slaps, pushes or other
forms of physical contact as a means to maintain labor
discipline.
H/A.5 Discipline / Verbal Abuse
Employers shall not use any form of verbal violence,
including screaming, yelling, or the use of threatening,
demeaning, or insulting language, as a means to
maintain labor discipline.
H/A.6 Discipline / Psychological Abuse
Employers shall not use any form – or threat – of
psychological abuse, such as forcing workers to sign
letters of self-criticism or posting names of workers
subject to disciplinary measures as a means to
maintain labor discipline.
H/A.7 Discipline / Freedom of Movement
Employers shall not restrain the freedom of movement
of workers, including movement in canteens, during
breaks, using toilets, accessing water, or accessing
necessary medical attention, as a means to maintain
labor discipline.
H/A.8 Elimination of Violence, Harassment and Abuse
in the Workplace
H/A.8.1 Employers shall ensure that the workplace and
all workplace facilities (such as employer provided
transportation or dormitories) are free from any type
of violence, harassment or abuse, be it physical, sexual,
psychological, verbal, or otherwise.
H/A.8.2 Employers, in consultation with worker/union
representatives, shall assess specific hazards and risks
of harassment and abuse in the workplace, including
gender-based violence. This includes risks arising from
working conditions, work arrangements (such as night
shifts or other schedules,) work organization, and third
parties such as recruitment agencies, contractors, or
any other intermediaries.
H/A.8.3 Employers shall develop, implement and
monitor policy and procedures for eliminating the risk
of violence, harassment, and abuse in the workplace.
Policies and procedures shall include a clear statement
that violence, harassment, and abuse will not be
tolerated, procedures for the investigation of
allegations, and measures to protect any complainants,
victims, and witnesses.
H/A.8.4 Employers shall take all necessary precautions
to eliminate any action (by the employer, between or
among employees, or by third-parties who are retained
by the employer or whose work is connected with the
workplace) that would result in gender-based violence
and/or harassment, regardless of whether such actions
occur in or outside of the workplace and/or working
hours.
H/A.9 Sexual Harassment
H/A.9.1 Employers shall refrain from:
H/A.9.1.1 any act of sexual harassment, including
inappropriate remark, insult, joke, insinuation, and
comment on a person's dress, physique, age, family
situation, etc.;
H/A.9.1.2 a condescending or paternalistic attitude
with sexual implications undermining dignity;
H/A.9.1.3 any unwelcome invitation or request, implicit
or explicit, whether or not accompanied by threats;
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H/A.9.1.4 any lascivious look or other gesture
associated with sexuality; and
H/A.9.1.5 any unnecessary physical contact such as
touching, caresses, pinching or assault.
H/A.9.2 Employers shall not offer, or take any action
that may suggest an offer of, recruitment, continued
employment, promotion, improved working
conditions, preferential work assignments or other
preferential treatment in exchange for a sexual
relationship.
H/A.9.3 Employers shall not subject workers to
prejudicial treatment of any kind in retaliation for
refused sexual advances or corrected inappropriate
behavior.
H/A.10 Security Practices and Body Searches
H/A/10.1 All security practices shall be gender
appropriate and nonintrusive, so that the dignity of
workers concerned is protected when a search is
undertaken.
H/A.10.1.1 Searching of bags and other personal items
to prevent theft is acceptable.
H/A.10.1.2 Body searches and physical pat downs shall
only be undertaken when there is a specific, legitimate
reason to do so and upon consent of workers, unless a
state official with the power to do so (e.g. police
officer) has ordered the search.
H/A.10.1.3 Body searches shall not be undertaken in
public and the person who undertakes the search shall
be of the same sex as the person who is being
searched.
H/A.11 Punishment of Abusive Workers, Supervisors,
or Managers
Employers shall have a system to discipline supervisors,
managers or workers who engage in any physical,
sexual, psychological or verbal violence, harassment or
abuse, through measures such as compulsory
counseling, warnings, demotions, and terminations or
a combination thereof regardless of whether such
action was intended as a means to maintain labor
discipline with a view to preventing the reoccurrence
of violence and harassment, and facilitating their
reintegration into work, where appropriate.
IV. FORCED LABOR (F)
WORKPLACE CODE PROVISION: There shall be no use of forced labor, including prison labor, indentured labor, bonded
labor or other forms of forced labor.
F.1 General Compliance Forced Labor
F.1.1 Employers, employment agencies, and
intermediaries shall comply with all national laws,
regulations and procedures concerning the prohibition
of forced labor and human trafficking.
F.1.2 If not provided by law, employers must provide
protection to workers who allege violations of forced
labor.
F.2 Freedom in Employment
F.2.1 All workers shall have the right to enter into and
to terminate their employment freely.
F.2.2 Employment terms shall be those to which the
worker has voluntarily agreed, in as far as those terms
do not fall below:
F.2.2.1 provisions of national laws;
F.2.2.2 freely negotiated and valid collective bargaining
agreements; or
F.2.2.3 the FLA Workplace Code.
F.2.3 There can be no employment terms which allow
employers, employment agencies, or intermediaries:
F.2.3.1 to hold wages already earned; or
F.2.3.2 use earned back wages as penalties; and
F.2.3.3 in any way punishes workers for terminating
employment.
F.3 Debt / Bonded Labor
F.3.1 Employers, employment agencies, or
intermediaries shall not bind workers to employment
as a condition of fulfilling terms of a debt.
F.3.2 Employers, employment agencies, or
intermediaries may provide loans directly to workers
only if they are a component of a larger loan program
(e.g. housing or education loans) available to all
workers.
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F.3.2.1 Lending and savings programs provided to
workers by employers, employment agencies, or
intermediaries must comply with all national laws and
regulations for such programs.
F.3.3 The continuance of loans may not be dependent
on continued employment at the workplace, and no
penalties may be assessed on the loan for workers
ending employment at the workplace.
F.3.4 Interest may not exceed the cost of administering
the loan program and any tax liabilities incurred by the
program, and according to legal limits.
F.4 Freedom of Movement
F.4.1 If workplace entrances are locked or guarded to
prevent nonemployee access to the premises for
security reasons, workers shall have free egress at all
times,
F.4.2 No terms imposed by the employer or any
employment agencies or intermediaries shall confine
or restrict employees’ freedom of movement or free
transit
F.5 Employer Controlled Residence
Employers shall not require , or influence, workers to
live in employer-owned or -controlled residences as a
condition of recruitment, continued employment or to
receive the same terms of employment and working
conditions as other workers in the same position.
F.6 Freedom of Movement in Employer Controlled
Residence
The freedom of movement of workers who live in
employer-owned or -controlled residences shall not be
unreasonably restricted.
F.7 Threat of Penalty
F.7.1 Employers shall not utilize, nor shall they use
employment agencies or intermediaries that utilize,
practices that restrict any worker’s freedom of
movement, ability to terminate their employment, or
that create a threat of penalty. Examples of such
practices include, but are not limited to:
F.7.1.1 (the threat of) physical or mental coercion;
F.7.1.2 requiring deposits;
F.7.1.3 imposing financial penalties;
F.7.1.4 requiring workers to pay recruitment and/or
employment fees*;
F.7.1.5 providing precarious employment*;
F.7.1.6 using false information to recruit workers
F.8 Forced Overtime
The imposition of overtime where workers are unable
to leave the work premises constitutes forced labor.
F.9 Personal Identification and Other Documents
Workers shall retain possession and control of their
passports, identity papers, travel documents, work
permits, and other personal legal documents.
F.10 Storage for Employee Documents
F.10.1 Employers shall provide at employee request
secure storage for employee’s documents such as
passports, identity papers, travel documents, and other
personal legal documents. Such storage shall be freely
accessible to workers at all times.
F.10.2 Employers shall not withhold any such
documents or restrict workers’ access to them for any
reason, including ensuring that workers shall remain in
employment in the workplace.
F.11 Employment Fees
Fees and other costs associated with the employment
of workers, including
migrant/contingent/contract/temporary workers, shall
be the sole responsibility of the employer.
F.12 Free Disposal of Wages
F.12.1 Employers may not limit in any manner the
freedom of workers to dispose of their wages.
F.12.2 Workers must be free from any coercion to make
use of enterprise or employer-operated stores.
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V. CHILD LABOR (CL)
WORKPLACE CODE PROVISION: No person shall be employed under the age of 15 or under the age for completion of
compulsory education, whichever is higher.
CL.1 General Compliance Child Labor
Employers shall comply with all national laws,
regulations and procedures concerning the prohibition
of child labor.
CL.2 Child Labor
Employers shall not employ anyone under the age of
15 or under the age for completion of compulsory
education, whichever is higher.
CL.3 Government Permits and Parental Consent
Documentation
Employers shall abide by all relevant rules and
procedures where the law requires government
permits or permission from parents as a condition of
employment, and shall keep documentation on-site for
inspection at all times.
CL.4 Employment of Young Workers
Employers shall comply with all relevant laws that
apply to young workers (e.g. those between the
minimum working age and the age of 18), including
regulations related to hiring, working conditions, types
of work, hours of work, proof of age documentation,
and overtime.
CL.5 Hazardous Work for Young Workers
No person under the age of 18 shall undertake
hazardous work, i.e. work which, by its nature or the
circumstances in which it is carried out, is likely to
harm the health or safety or morals of persons under
the age of 18.
CL.6 Young Workers Identification System
Employers shall have a system for identifying
workstations and operations that are inappropriate for
young workers according to applicable laws.
CL.7 Apprenticeships and Vocational Training /
Minimum Working Age
Apprentices or vocational students shall not be under
the age of 15 or under the age for completion of
compulsory education, whichever is higher.
CL.8 Proof of Age Documentation
CL.8.1 Employers shall collect and maintain all
documentation necessary to confirm and verify date of
birth of all workers, such as birth certificates.
CL.8.1.1 Employers shall take reasonable measures to
ensure such documentation is complete and accurate.
CL.8.1.2 In those cases where proof of age
documentation is not readily available or unreliable,
employers shall take all necessary precautions which
can reasonably be expected of them to ensure that all
workers are at least the minimum working age,
including requesting and maintaining medical or
religious records of workers, or through other means
considered reliable in the local context.
VI. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING (FOA)
WORKPLACE CODE PROVISION: Employers shall recognize and respect the right of employees to freedom of association
and collective bargaining.
FOA.1 General Compliance Freedom of Association
FOA.1.1 Employers shall comply with all national laws,
regulations and procedures concerning freedom of
association and collective bargaining. national laws,
rules, and procedures protecting the rights of workers
to organize and bargain collectively. Where local laws
and FLA standards differ, the employer is expected to
follow the highest applicable standard.
FOA.1.2 If not provided by law, employers must provide
protection to workers who allege violations of freedom
of association.
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FOA.2 Right to Freely Associate
Workers, without distinction whatsoever, shall have the
right to establish and to join organizations of their own
choosing, subject only to the rules of the organization
concerned, without previous authorization. The right
to freedom of association begins at the time that
workers seeks employment and continues through the
course of employment, including eventual termination
of employment, and is applicable as well to
unemployed and retired workers.
FOA.3 Alternative Means of Association
When the right to freedom of association and
collective bargaining is restricted under law, employers
shall not obstruct legal alternative means of worker
association.
FOA.4 Anti-Union Violence, Harassment or Abuse
FOA.4.1 Employers shall not use any form of physical or
psychological violence, threats, intimidation,
retaliation, harassment or abuse against union
representatives and workers seeking to form, in the
process of forming, or who have joined an organization
of their own choosing.
FOA.4.1.1 Such practices shall not be used against
workers' organizations or workers participating or
intending to participate in formal or informal
organizing activities, including strikes.
FOA.5 Anti-Union Discrimination / Dismissal, Other
Loss of Rights, and Blocklisting
FOA.5.1 Employers shall not engage in any acts of
anti-union discrimination or retaliation, i.e. shall not
make any employment decisions which negatively
affect workers based wholly or in part on a workers’
union membership or participation in union activity,
including the formation of a union, previous
employment in a unionized facility, participation in
collective bargaining efforts or participation in a legal
strike.
FOA.5.1.1 Employers shall not use blocklists to restrict
freedom of association, for instance blocklists based on
union membership or participation in union activity.
FOA.6 Restoration of Workers Rights / Worker
Reinstatement
Workers who have been unjustly dismissed, demoted
or otherwise suffered a loss of rights and privileges at
work due to an act of union discrimination shall,
subject to national laws, be entitled to restoration of all
the rights and privileges lost, including reinstatement
and retroactive payment of wages, if they so desire.
FOA.7 Protection of Union Representatives
Employers shall comply with all relevant provisions
where national laws provide special protection to
workers or worker representatives engaged in a
particular union activity (such as union formation) or to
worker representatives with a particular status (such as
founding union members or current union office
holders).
FOA.8 Production Shift/Workplace Closure
FOA.8.1 Employers shall not (threaten to) shift
production or close a workplace site in an attempt to
prevent the formation of a union, in reaction to the
formation of a union, in reaction to any other
legitimate exercise of the right to freedom of
association and collective bargaining, including the
right to strike, or in an effort to break up a union.
FOA.8.2 If a workplace is closing and there is a dispute
that the closure was done to prevent or hamper the
legitimate exercise of the right to freedom of
association, employers shall provide proof that can be
assessed by a third party to determine the validity of
the reasons given for closure.
FOA.9 Severance Pay
Employers shall not offer or use severance pay in any
form or under any other name as a means of
contravening the right to freedom of association,
including attempts to prevent or restrict union
formation or union activity, including strikes.
FOA.10 Employer Interference
Employers shall refrain from any acts of interference
with the formation or operation of workers’
organizations, including acts, which are designed to
establish or promote the domination, financing or
control of workers’ organizations by employers.
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FOA.11 Employer Interference / Constitution,
Elections, Administration, Activities & Programs
FOA.11.1Employers shall not interfere with the right of
workers to:
FOA.11.1.1 Draw up their constitutions and rules;
FOA.11.1.2 Elect their representatives; or
FAO.11.1.3 Organize their administration and activities.
FOA.12 Employer Interference / Registration
Employers shall not attempt to influence or interfere in
any way, to the detriment of workers’ organizations,
with government registration decisions, procedures
and requirements regarding the formation of workers’
organizations.
FOA.13 Employer Interference / Favoritism
FOA.13.1 Employers shall not interfere with the right to
freedom of association by favoring one workers’
organization over another.
FOA.13.1.1 In cases where a single union represents
workers, employers shall not attempt to influence or
interfere in any way in workers’ ability to form other
organizations that represent workers.
FOA.14 Employer Interference / Police and Military
Forces
Employers shall not in any way threaten the use of or
use the presence of police or military, to prevent,
disrupt or break up any activities that constitute an
exercise of the right to freedom of association,
including union meetings, assemblies and strikes.
FOA.15 Facilities for Worker Representatives
Worker representatives shall have the facilities
necessary for the proper exercise of their functions,
including access to workplaces and office space where
required by law.
FOA.16 Right to Collective Bargaining / Good Faith
FOA.16.1 Employers shall recognize the rights of
workers to free and voluntary collective bargaining
with a view to the regulation of terms and conditions
of employment by collective agreements.
FOA.16.2 Employers and worker representatives shall
bargain in good faith, i.e. engage in genuine and
constructive negotiations and make every effort to
reach an agreement.
FOA.17 Right to Collective Bargaining / Exclusive
Bargaining & Other Recognized Unions
Employers shall bargain with any union that has been
recognized by law or by agreement between the
employer and that union, provided such agreement
does not contravene national law, as a, or the
exclusive, bargaining agent for some or all of its
workers.
FOA.18 Right to Collective Bargaining / Unorganized
Workers
Employers can only engage in collective bargaining
with representatives of unorganized workers when no
workers’ organization exists.
FOA.19 Right to Collective Bargaining / Compliance
with Collective Bargaining Agreement
FOA.19.1 Employers, unions and workers shall honor in
good faith, for the term of the agreement, the terms of
any collective bargaining agreement they have agreed
to and signed.
FOA.19.2 Worker representatives and workers shall be
able to raise issues regarding compliance with a
collective bargaining agreement by employers without
retaliation or any negative effect on their employment
status.
FOA.19.3 Where a union exists in the workplace,
employers shall make available a copy of the collective
bargaining agreement to all workers and other
interested parties.
FOA.20 Right to Collective Bargaining / Validity of
Collective Bargaining Agreement
FOA.20.1 Collective bargaining agreements that have
not been negotiated freely, voluntarily and in good
faith shall be considered not applicable.
FOA.20.2 Provisions in collective bargaining
agreements that contradict national laws, rules and
procedures or offer less protection to workers than
provisions of the FLA Workplace Code shall also be
considered not applicable.
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FOA.21 Rights of Minority Unions and their Members
Unions not recognized as a bargaining agent of some or
all of the workers in a facility shall have the means for
defending the occupational interests of their members,
including making representations on their behalf and
representing them in cases of individual grievances and
disciplinary actions, within limits established by
applicable law.
FOA.22 Right to Strike / Sanction for Organizing or
Participating in Legitimate Strikes
Employers shall not impose any sanction on workers
organizing or having participated in a strike in
accordance with ILO standards and jurisprudence.
FOA.23 Right to Strike / Replacement Workers
Employers shall not hire replacement workers in order
to prevent or break up a strike that is in accordance
with ILO standards and jurisprudence, or to avoid
negotiating in good faith.
VII. HEALTH, SAFETY, AND ENVIRONMENT (HSE)
WORKPLACE CODE PROVISION: Employers shall provide a safe and healthy workplace setting to prevent accidents and
injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of
employers’ facilities.
Employers shall adopt responsible measures to mitigate negative impacts that the workplace has on the environment.
HSE.1 General Compliance Health, Safety, and
Environment
Employers shall comply with all national laws,
regulations and procedures concerning health and
safety, and the environment.
HSE.2 Document Maintenance / Workers Accessibility
and Awareness
All documents required to be available to workers and
management by applicable laws (e.g. health and safety
policies, MSDS, environmental emergency procedures)
shall be made available in the prescribed manner and
in the local language and language spoken by the
workers, if different from the local language.
HSE.3 Notification and Record Maintenance
HSE.3.1 Employers shall notify the relevant national
and/or local authorities of all illnesses and accidents
and environmental emergencies as required by
applicable laws.
HSE.3.2 All illness, safety, accident, and emergency
reports shall be maintained on site for at least one
year, or longer if required by law.
HSE.4 Permits and Certificates
HSE.4.1 Employers shall at all times be in possession of
all legally required and valid permits and certificates
related to health, safety, and environmental issues,
such as:
HSE.4.1.1 Purchase and storage of chemicals;
HSE.4.1.2 Fire safety inspections;
HSE.4.1.3 Machinery inspections;
HSE.4.1.4 Waste disposal;
HSE.4.1.5 Environmental licenses/permits;
HSE 4.1.6 Sanitation permits, including those required
for canteens; and
HSE 4.1.7 Vehicle inspection and driver permits for all
employer provided transportation.
HSE.5 Evacuation Requirements
HSE.5.1 All applicable, legally required or
recommended elements of safe evacuation shall be
complied with, including all of the following elements:
HSE.5.1.1 posting evacuation plans;
HSE.5.1.2 installation and maintenance of fire alarms;
HSE.5.1.3 Installation and maintenance of emergency
lighting;
HSE.5.1.4 ensuring aisles/exits are not blocked and that
workers are not blocked within their workstations;
HSE.5.1.5 employee education and training; and
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HSE.5.1.6 evacuation procedures and fire drills.
HSE.5.2 Workers shall be trained in evacuation
procedures.
HSE.5.3 Alarm systems shall be regularly tested and
evacuation drills shall be undertaken at least annually.
HSE.5.4 The emergency evacuation procedure (EEP)
includes procedures for notifying local community
authorities in case of accidental discharge or release of
chemical/waste products or any other environmental
emergency.
HSE.6 Safety Equipment and First Aid Training
HSE.6.1 All safety and medical equipment (e.g.
fire-fighting equipment, first aid kits) shall be available
in sufficient numbers throughout the workplace,
maintained and stocked as prescribed, and easily
accessible to workers.
HSE.6.2 A sufficient number of workers shall be trained
in first aid and firefighting techniques. Training shall be
upon hire and with periodic refresher training.
HSE.7 Personal Protective Equipment
Workers shall be provided at no cost with all the
appropriate and necessary personal protective
equipment (e.g. gloves, eye protection, hearing
protection, respiratory protection) to effectively
prevent unsafe exposure (e.g. inhalation or contact
with solvent vapors, noise, dust) to health and safety
hazards, including medical waste.
HSE.8 Use of Personal Protective Equipment
Workers shall be provided with training on the use and
maintenance of personal protective equipment.
Training shall be upon hire with periodic refresher
training offered to all workers. Management will
ensure use of PPE as necessary.
HSE.9 Chemical Management and Training
HSE.9.1 All chemicals and hazardous substances shall
be properly labeled and stored in secure and ventilated
areas and disposed of in a safe and legal manner, in
accordance with applicable laws and international
standards.
HSE.9.1.1 Labels shall be placed in the local language
and the language spoken by workers, if different from
the local language.
HSE.9.2 Workers shall receive training, appropriate to
their job responsibilities, concerning the hazards, risks
and the safe use of chemicals and other hazardous
substances.
HSE.10 Material Safety Data Sheets/Workers Access
and Awareness
HSE.10.1 Material Safety Data Sheets (MSDS) for all
chemicals and hazardous substances used in the
workplace must be available at the usage and storage
sites of the chemicals and hazardous substances, in the
local language and the language spoken by workers, if
different from the local language.
HSE.10.2 Workers shall have free access to MSDS.
HSE.11 Chemical Management / Pregnant Women
and Young Workers
To prevent unsafe exposure to hazardous chemicals
and hazardous substances, appropriate
accommodations shall be made for pregnant women
and workers under the age of 18, as required by
applicable laws or the provisions of the FLA Workplace
Code, in a manner that does not unreasonably
disadvantage workers.
HSE.12 Protection Reproductive Health
Employers shall ensure that women are not engaged in
work that constitutes a substantial risk to their
reproductive health.
HSE.13 Ventilation/Electrical/Facility Installation and
Maintenance
All necessary ventilation, plumbing, electrical, noise
and lighting services shall be installed and maintained
to conform to applicable laws and to prevent or
minimize hazardous conditions to workers in the
facility.
HSE.14 Machinery Safety, Maintenance and Workers
Training
HSE.14.1 All production machinery, equipment and
tools shall be properly guarded and regularly
maintained.
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HSE.14.2 Workers shall receive training in the proper
use and safe operation of machinery, equipment and
tools they use.
HSE.14.3 Employers shall ensure safety instructions are
either displayed or posted near all machinery or are
readily accessible to the workers in language(s) spoken
by workers.
HSE.15 Proper Use of Machinery
Employers shall not use negative incentives like
monetary penalty schemes to ensure workers use
machinery, equipment and tools safely and properly.
Rather, training on risk awareness, proper machine
use, as well as positive incentives like bonuses should
be used.
HSE.16 Workers Refusal to Use Unguarded or Unsafe
Machinery
Workers shall not suffer any negative consequences for
refusing to work with machinery, equipment or tools
that are not properly guarded or reasonably
considered unsafe.
HSE.17 Ergonomics
HSE.17.1 Workstations, including seating and standing
arrangements and reach required to obtain tools, shall
be designed and set-up in such a manner as to
minimize bodily strains.
HSE.17.2 Employers shall train workers in proper lifting
techniques, and items such as lifting belts shall be
provided.
HSE.18 Medical Facilities
HSE.18.1 Medical facilities shall be established and
maintained in factories as required by applicable laws.
HSE.18.2 Medical staff shall be fully licensed and
recognized under applicable national rules and
regulations.
HSE.18.2.1 An appropriate number of medical staff
shall be on duty during all working hours, including any
type of overtime, as required under national law.
HSE.18.3 An appropriate stock of medical supplies shall
be maintained at all times.
HSE.18.3.1 Medicines of which the expiration date has
passed must be replaced immediately and disposed of
in a safe manner.
HSE.19 Sanitation in Workplace Facilities
All facilities including workplace buildings, toilets,
canteens, kitchens, and clinics, shall be kept clean and
safe and be in compliance with all applicable laws,
including relevant sanitation, medical, and safety and
health regulations.
HSE.20 Toilets
Employers shall establish the number of toilets
required under applicable laws within reasonable
distance of the workplace. In addition, the following
should also be considered: number of toilets based on
number of workers, privacy for each individual and
gender, accessibility and hygiene.
HSE.21 Toilets/Restrictions
Employers shall not place any undue restrictions on
toilet use in terms of time and frequency.
HSE.22 Food Preparation
HSE.22.1 All food made available to workers shall be
prepared, stored, and served in a safe and sanitary
manner in accordance with all applicable laws and
international standards.
HSE.22.2 All workers handling food must be trained
and/or certified to work in the facility preparing or
serving food.
HSE.23 Drinking Water
HSE.23.1 Safe and clean drinking water shall be freely
available at all times, within reasonable distance of the
workplace.
HSE.23.1.1 Drinking water shall be of a reasonable
temperature.
HSE.23.1.2 The means to drink water (e.g. cups) must
be safe and sanitary and available in an appropriate
number.
HSE.24 Drinking Water/Restrictions
Employers shall not place any undue restrictions on
drinking water in terms of time and frequency.
HSE.25 Dormitory Facilities
HSE.25.1 Dormitory facilities, including those provided
by employment agencies or intermediaries associated
with the employer, shall meet all applicable laws and
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regulations related to health, safety, and environment,
including fire safety, sanitation, risk protection and
electrical, mechanical, and structural safety.
HSE.25.1.1 All dormitories shall be kept secure, clean,
and have safety provisions (e.g. fire extinguishers, first
aid kits, unobstructed emergency exits, emergency
lighting).
HSE.25.1.2 Emergency evacuation drills shall also be
conducted at least semi-annually.
HSE.26 Dormitories Separate from Production
Facilities
All dormitory facilities must be structurally sound, in
good repair, and located separately from production,
warehouse and hazardous chemical storage areas.
HSE.27 Childcare Facilities/Children on Premises
HSE.27.1 Childcare facilities shall not physically overlap
with production areas and children shall not have
access to production areas.
HSE.27.2 Children under the minimum working age
shall not be allowed in workplace areas at any time,
unless they are part of a guided school tour or other
such unusual event.
HSE.27.3 All childcare workers must be fully trained
and licensed to provide the level of care necessary at
the factory. Where local legal requirements are
missing, childcare workers must have at least some
vocational training for childcare.
HSE.27.4 Childcare facility hours must match the
working hours of the factory shift schedule, following
any regulations provided by local law.
HSE.28 External Contractors
Employers shall create a system to ensure that all
necessary Health and Safety protections are provided
for external contractors; including protection when
working within confined spaces, maintenance issues,
and general Health and Safety Issues.
HSE.29 High-Risk Areas
Employers shall provide all necessary protection for
workers when working at heights, confined spaces, and
other high-risk areas.
HSE.30 Health, Safety & Environmental Management
System, Policies & Procedures
HSE.30.1 Employers shall develop, maintain, and
regularly review health, safety, and environmental
policies to ensure that they comply with all national
laws, regulations and the FLA Workplace Code
concerning health, safety, and environmental
standards, regulations and procedures.
HSE.30.2 The health, safety, and environmental policies
shall contain the framework for a comprehensive
health, safety, and environmental management system
including a HS&E risk assessment within which the
following are clear and regularly tested and reviewed:
HSE.30.2.1 employers’ responsibilities;
HSE.30.2.2 workers’ rights and duties;
HSE.30.2.3 responsibilities of designated personnel;
HSE.30.2.4 procedures that enable workers to raise
health, safety, and environmental concerns;
HSE.30.2.5 procedures for reporting death, injury,
illness and other health and safety issues (for instance,
near-miss accidents) and environmental emergencies;
HSE.30.2.6 protections to workers who allege health,
safety, and environmental violations;
HSE.30.2.7 conducting root cause analysis on
workplace accidents and taking proactive action to
prevent future accidents.
HSE.30.3 Environmental policies shall include
procedures to minimize environmental impacts with
respect to energy, air emissions, water, waste,
hazardous materials, and other significant
environmental risks.
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VIII. HOURS OF WORK (HOW)
WORKPLACE CODE PROVISIONS: Employers shall not require workers to work more than the regular and overtime
hours allowed by the law of the country where the workers are employed. The regular work week shall not exceed 48
hours. Employers shall allow workers at least 24 consecutive hours of rest in every seven-day period. All overtime work
shall be
consensual.
Employers shall not request overtime on a regular basis and shall compensate all overtime work at a premium rate.
Other than in exceptional circumstances*, the sum of regular and overtime hours in a week shall not exceed 60 hours.
HOW.1 General Compliance Hours of Work
HOW.1.1 Employers shall comply with all national laws,
regulations and procedures concerning hours of work,
public holidays and leave.
HOW.1.2 If not provided by law, employers must
provide protection to workers who allege violations of
laws governing work hours.
HOW.2 Rest Day
Workers shall be entitled to at least 24 consecutive
hours of rest in every seven- day period. If workers
must work on a rest day, an alternative consecutive 24
hours must be provided within that same seven-day
period or immediately following.
HOW.3 Meal and Rest Breaks
Employers shall provide reasonable meal and rest
breaks, which, at a minimum, must comply with
national laws.
HOW.4 Protected Workers (Women and Young
Workers)/Regulations on Hours of Work
The workplace shall comply with all applicable laws
governing work hours regulating or limiting the nature,
frequency and volume of work performed by women
or workers under the age of 18.
HOW.5 Protected Workers (Women and Young
Workers) / Record Keeping
Employers shall maintain necessary records identifying
all women workers and all workers under the age of 18
entitled to legal protection concerning work hours.
HOW.6 Maintenance of Reasonable Levels of Staff
Employers' personnel practices shall demonstrate an
effort to maintain a level of staffing that is reasonable
in view of predictable or continuing fluctuations in
business demand.
HOW.7 Overtime Calculation over Period Longer than
One Week
Employers are allowed to calculate regular hours of
work as an average over a period of longer than one
week, where national laws, regulations and procedures
provide for such a possibility, but only when all formal
and procedural requirements attached to such
calculation (for instance, obtaining official permission
from the relevant authorities or limits to the period
during which such calculations can be made) are met.
However, the basis for such calculation shall not exceed
48 hours per week.
HOW.8 Forced Overtime
HOW.8.1 Employers shall not require or permit workers
to work more than the overtime hours allowed by the
law of the country where the workers are employed.
HOW.8.2 All overtime work shall be consensual, and
employers shall enact a voluntary overtime system,
including for overtime utilized in exceptional
circumstances*.
HOW.9 Explanation for Overtime in Exceptional
Circumstances
HOW.9.1 Employers shall be able to provide
explanation for all periods when the exceptional
circumstances exception has been used.
HOW.9.2 Employers shall take reasonable steps to
inform workers about the nature and expected
duration of the circumstances sufficiently in advance to
allow workers to make alternative plans.
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HOW.10 Public Holidays
HOW.10.1 Employers shall provide workers with all
official public holidays as required under national laws,
regulations and procedures.
HOW.10.2 If not prohibited by local law, any
replacement of official holidays with alternative days
off must be voluntary and agreed upon in writing by
the worker in advance.
HOW10.3 When using replacement holidays, all legal
and FLA requirements regarding overtime and hours of
work apply.
HOW.11 Annual Leave
HOW.11.1 Employers shall provide workers with paid
annual leave as required under national laws,
regulations and procedures.
HOW.11.2 Even where national laws allow employers
to pay extra compensation in lieu of paid annual leave,
employers shall ensure that this option is not utilized.
HOW.12 Annual Leave Determination
HOW.12.1 Employers shall not impose any undue
restrictions on workers’ use of annual leave.
HOW.12.2 The time at which annual leave is taken is
determined by employers in consultation with workers,
taking into account work requirements and the
opportunities for rest and relaxation available to
workers.
HOW.13 Annual Leave Procedures
HOW.13.1 Any workplace procedures regulating the
timing of annual leave (e.g., requiring a minimum
period of service before being allowed to use annual
leave, written requests to be submitted a certain time
before the annual leave) must be in line with national
laws, regulations and procedures.
HOW13.2 Workplace procedures regulating the timing
of annual leave must be communicated in full to all
workers.
HOW.14 Annual Leave Wage Payments
Employers shall provide workers taking annual leave
their normal or average wages for the full period of
annual leave in advance, unless specified differently
under national laws, regulations and procedures.
HOW.15 Retaliation for Taking Leave
Employers shall not impose any sanction on workers
for requesting or taking any type of leave, such as
annual, sick, or maternity, in line with all applicable
rules and procedures.
HOW.16 Sick Leave
Employers shall provide workers with sick leave as
required under national laws, regulations and
procedures.
HOW.17 Sick Leave Restrictions
Employers shall not impose any undue restrictions on
sick leave. Any workplace procedures regulating sick
leave (e.g. informing the employer as soon as possible,
the provision of medical certificates,) must be in line
with national laws, regulations and procedures and
must be communicated in full to all workers.
HOW.18 Calculation of Absences
Absences from work for reasons beyond the control of
workers, such as sick leave or periods during which
workplace operations are suspended, shall not be
counted as annual leave nor shall they be deducted
from calculations concerning length of service, unless
specified differently under national laws, regulations
and procedures.
HOW.19 Suspension of Work
HOW.19.1 Employers can only suspend work in
accordance with national laws, regulations and
procedures.
HOW.19.2 Workers shall be paid in full during periods
of suspension, unless national laws stipulate otherwise,
workers and their representative organizations agree
otherwise, or the relevant national authorities
authorize the alternative arrangement.
HOW.19.3 Conditions of suspension should be
communicated in full to all workers.
HOW.20 Excessive Hours Reduction
Employers shall have in place practices that conduct
regular analysis of hours of work in their workplaces
and procedures that demonstrate a commitment to
progressively reducing excessive hours of work.
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HOW.21 Overtime Hours
Other than in exceptional circumstances, the total
weekly work hours (regular work hours plus overtime
including any alternative shifts such as 4x4 or 3x3) shall
not exceed 60 hours per week.
HOW.22 Time Recording System
HOW.22.1 Employers shall have in place policies for
managing all working hour, overtime, and leave records
in normal and exceptional circumstances.
HOW.22.2 Accurate time records shall be maintained
by employers, including overtime, breaks, and leave.
HOW.22.3 Time worked by all workers, regardless of
wage system, shall be fully documented by timecards
or other mechanical or electronic recording systems.
HOW.22.4 Employers shall not maintain multiple
time-keeping systems and/or records.
HOW.22.5 Time records maintained shall be authentic
and accurate.
HOW.22.6 If not provided by law, employers must
provide protection to workers who allege existence of
multiple time-keeping systems or falsification of work
time records.
IX. COMPENSATION (C)
WORKPLACE CODE PROVISIONS: Every worker has a right to compensation for a regular work week that is sufficient to
meet the worker’s basic needs* and provide some discretionary income*. Employers shall pay at least the minimum
wage or the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages, and provide
any benefits required by law or contract. Where compensation does not meet workers’ basic needs and provide some
discretionary income, each employer shall work with the FLA to take appropriate actions that seek to progressively
realize a level of compensation that does.
C.1 General Compliance Compensation
C.1.1 Employers shall comply with all national laws,
regulations and procedures concerning the payment of
compensation to workers.
C.1.2 In any case where differences or conflicts in
national law and FLA Workplace Code arise, employers
are expected to apply the highest standard.
C.1.3 In any case where national laws, regulations and
procedures do not address the payment of
compensation to workers, employers shall follow all
standards in the FLA Workplace Code that apply to
administration and payment of compensation and shall
provide an employment contract that includes
stipulation of compensation payment to workers.
C.2 Minimum Wage
Employers shall pay workers at least the legal minimum
wage or the prevailing industry wage, whichever is
higher, for regular working hours (not including
overtime). Workers should also be informed about the
legal minimum wage.
C.3 Wage & Benefits / Probationary Status
C.3.1Where probationary employment is legally
allowed, workers shall:
C.3.1.1 Receive at least the minimum wage for regular
workers or the prevailing industry wage for regular
workers, whichever is higher;
C.3.1.2 Receive all legally mandated benefits;
C.3.1.3 No workers shall work more than three months
in this employment category.
C.4 Wage & Benefits / Apprenticeship or Vocational
Training
C.4.1 For the time-period during which they receive
training, apprentices and vocational trainees shall:
C.4.1.1 receive at least the minimum wage for regular
workers or the prevailing industry wage for regular
workers, whichever is higher; and
C.4.1.2 Receive all legal mandated benefits.
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C.4.1.3 If local law allows for a lower minimum wage
for apprentices/trainees, this lower minimum wage
may only be applied for the first 30 days, if that time is
dedicated primarily to training and not to production
or other essential tasks.
C.5 Wage & Benefits / Contract, Contingent or
Temporary Workers
C.5.1 Contract/contingent/migrant/temporary workers
shall:
C.5.1.1 Receive at least the minimum wage for regular
workers or the prevailing industry wage for regular
workers, whichever is higher;
C.5.1.2 Receive all legally mandated benefits; and
C.5.1.3 Receive at least the same compensation as
regular workers performing the same job functions or
tasks with similar levels of experience or seniority.
C.6 Timely and Direct Payment of Wages
All wages, including payment for overtime, shall be
paid directly and in full within legally defined time
limits. When no time limits are defined by law,
compensation shall be paid at least once a month.
C.7 Accurate Calculation, Recording, and Payment of
Wage
All payments to all workers, including hourly wages,
piecework, benefits and other incentives, shall be
calculated, recorded, and paid accurately.
C.8 Accurate Length of Service Calculation
All workers shall be credited with all-time worked for
an employer for purposes of calculating length of
service and determine the benefits to which workers
are entitled.
C.9 Calculation Basis for Overtime Payments
C.9.1Employers shall compensate workers for all hours
worked.
C.9.2 The factory shall comply with all applicable laws,
regulations and procedures governing the payment of
premium rates for work on holidays, rest days, and
overtime.
C.9.3 Employees shall be compensated for overtime
hours at such premium rate as is legally required in the
producing country.
C.9.3.1 In those countries where there is no legally
established overtime premium, employees shall be
compensated for overtime hours at the prevailing
industry premium rate or at the internationally
recognized overtime rate*, whichever is higher.
C.10 Overtime Wage Awareness
Workers shall be informed, orally and in writing, in
language(s) spoken by workers about overtime wage
rates prior to undertaking overtime.
C.11 Nonpayment of Incentives
Regardless of any production quotas, incentives shall
not be reduced or not paid if the result shall be wages
below the legal minimum wage or the prevailing
industry wage, whichever is higher.
C.12 Deposit of Legally Mandated Deductions
C.12.1 All legally mandated deductions for taxes, social
insurance, or other purposes shall be deposited each
pay period in the legally defined account or
transmitted to the legally defined agency. This includes
any lawful garnishments for back taxes, etc.
C.12.2 Employers shall not hold over any of these funds
from one pay period to the other unless the law
specifies that deposits are to be made less frequently
than pay periods (e.g. monthly deposits, weekly pay).
C.12.3 If the law does not specify, then deposits shall
be made before the next pay period in all cases.
C.13 Voluntary Wage Deductions
C.13.1 Voluntary wage deductions, including for
savings clubs, loan payments, union membership dues,
or any other union fees, can only be made with the
express and written consent of individual workers
unless (in the case of union dues and fees) specified
otherwise in freely negotiated and valid collective
bargaining agreements. In all cases, voluntary wage
deductions must fall within the limits and conditions
specified by law.
C.13.2 Written consent for voluntary wage deductions
shall be documented in employee files.
C.13.3 All such voluntary deductions shall be credited
to proper accounts and employers shall not hold funds
illegally or inappropriately.
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C.14 Voluntary Wage Deduction / Workers Access to
Information
Workers shall have access to regular and full
information concerning the status of relevant accounts
and the status and level of their payments thereto.
C.15 Pay Statement
C.15.1 Employers shall provide workers a pay
statement in languages understood by workers each
pay period and not less frequently than once a month,
which shall show:
C.15.1.1 earned wages,
C.15.1.2 wage calculations,
C.15.1.3 total number of hours worked,
C.15.1.4 regular and overtime pay,
C.15.1.5 bonuses,
C.15.1.6 all deductions, and
C.15.1.7 final total wage.
C.16 Compensation Receipt
C.16.1 All compensation records, including wages and
benefits whether in cash or in-kind, must be properly
documented and their receipt and accuracy must be
confirmed by the relevant worker in writing (e.g.
signature, thumbprint).
C.16.2 No one can receive wages on behalf of a worker,
unless the worker concerned has, in full freedom,
authorized in writing for another person to do so.
C.17 Record Maintenance
Employers shall ensure that all legally required payroll
documents, journals and reports are available,
complete, accurate and up-to date.
C.18 False Payroll Records
C.18.1 Employers shall not use hidden or multiple
payroll records in order to hide overtime, to falsely
demonstrate hourly wages, or for any other fraudulent
reason.
C.18.2 Payroll records maintained shall be authentic
and accurate.
C.19 Workers Awareness and Understanding of
Compensation
C.19.1 Employers shall make every reasonable effort to
ensure workers understand their compensation,
including:
C.19.1.1 the calculation of wages,
C.19.1.2 incentives systems,
C.19.1.3 benefits, and
C.19.1.4 bonuses they are entitled to at the workplace
and under applicable laws.
C.19.1.5 Employers shall communicate orally and in
writing to all workers all relevant information in the
local language or language spoken by the workers, if
different from the local language.
C.20 Employer Provided Benefits
C.20.1 All workers have a right to use or not to use
services provided by employers, such as housing or
meals.
C.20.2 Deductions for services to workers shall not
exceed the cost of the service to employers.
C.20.3 Employers must be able to demonstrate the
accuracy or reasonableness of these charges.
C.21 Legally Mandated Benefits
C.21.1 Employers shall provide all legally mandated
benefits, including holidays, leave, bonuses, severance
payments and 13th month payments to all eligible
workers within legally defined time periods.
C.21.2 All benefits shall be calculated correctly.
C.22 Compensation Disputes
Employers must establish a system through which
workers can dispute compensation and receive
clarifications in this respect in a timely manner.
C.23 Fair Compensation / Basic Needs
Where compensation for a regular workweek is not
sufficient to meet workers’ basic needs* and provide
some discretionary income*, each employer shall work
with the FLA to take appropriate actions that seek to
progressively realize a level of compensation that does.
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C.24 Piece Rate/Minimum Wage
C.24.1 Employers shall not set production targets,
piece rates or any other incentive or production system
at such a level that workers need to work beyond
regular working hours as set under the FLA Workplace
Code, excluding overtime, in order to make at least the
minimum wage or the prevailing industry wage,
whichever is higher.
C.24.2 Employers shall not set production targets,
piecework, or any other incentive or production system
at such a level that the payment for overtime work
performed is less than the premium pay required by
law or the FLA Workplace Code.
C.25 Wage Advances
C.25.1 Wage advances shall not exceed three months'
pay or legal limits, whichever is less.
C.25.2 Advances shall only be made following clearly
established rules which have been communicated to
workers.
C.25.2.1 Advances must be properly documented and
their receipt and accuracy must be confirmed by the
relevant worker in writing (e.g. signature,thumbprint).
C.25.3 No interest may be charged for wage advances.
Appendix J: Forced Labor and Responsible Recruitment Benchmarks
Please find below benchmarks to serve as a basis for establishing and monitoring performance indicators.
FORCED OR INVOLUNTARY LABOR
● Company policies and practices express a clear prohibition of forced, compulsory, bonded, indentured,
and prison labor that applies to all enterprises in its supply chain, including those involved in the
recruitment, selection, and hiring of workers.
● Clear and transparent human resource practices on recruitment, contracts, wages and working hours are
adopted by the company and its subcontractors to minimize the risk of forced labor and human trafficking.
● The company, or subcontractors acting on its behalf, comply with all relevant local laws and regulations
concerning the prohibition of forced labor and human trafficking in each jurisdiction in which they
operate.
● The workplace is free of any form of forced, compulsory, bonded, indentured, or prison labor.
● Workers enter into employment freely and employment terms and conditions are agreed to voluntarily,
without deception or threat of penalty.
● All work is voluntary.
● Workers have the freedom to terminate their employment at any time without penalty, given notice of
reasonable length.
RECRUITMENT FEES
● The company has a written policy declaring that workers shall not pay any amount to secure a job in their
facility.
● The job advertisements from the company include the statement that no fees shall be charged at any
phase in the recruitment and hiring process.
● The employer covers all recruitment and processing fees, costs, and expenses, including those associated
with securing identity cards, medical certificates and examinations, skills testing, and travel.
● The company has mechanisms to ensure that workers are not charged any amount to secure a job in their
facility.
● The company only engages recruiters, agents, and sub-agents who do not charge fees to jobseekers.
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● The company, or subcontractors acting on its behalf, has means of informing jobseekers at the point of
recruitment that workers do not pay fees or costs for any services directly related to temporary
assignment or permanent placement.
● The company or receiving country recruiter has a verification process to ensure that workers are not
charged any fees.
● Workers found to have been charged fees are repaid, and contracts with recruiters found to have charged
fees are terminated.
CONTRACTS OF EMPLOYMENT
● All candidates are clearly informed of the terms and conditions of employment, and successful candidates
are provided a copy of the contract prior to departing their home country.
● All workers are provided a signed copy of their original contract, in a language they understand, prior to
departing their home country.
● The company explains the terms and conditions of the contract, and has means to verify that said terms
are clearly understood and fully agreed to by the workers.
● Employment contracts clearly specify the rights and responsibilities of workers with regard to wages;
hours of work, including regular hours and overtime requirements; days off and annual leave; and
disciplinary and other procedures that can lead to termination, as well as appeal procedures consistent
with local law.
● The details of working conditions described at the point of recruitment are consistent with the details
contained in the employment contract at the time of hiring, and with actual job conditions and
responsibilities.
● Company policy prohibits the substitution of original contract provisions with those that are less favorable
to the worker. Any amendments made to improve conditions are made with the knowledge and the
informed, written consent of the worker.
● Changes to working conditions are made with the knowledge and consent of the worker. Consent is
obtained voluntarily and without the threat of penalty. No changes are made that in any way diminish the
worker’s originally anticipated wages, benefits, or other conditions of work; or place the worker in a
position of physical or mental risk or peril, or other form of disadvantage or vulnerability.
● Employment contracts clearly stipulate the rights and responsibilities of each party regarding the
termination of employment.
● Employment contracts clearly specify the circumstances in which a worker can terminate his or her
contract without penalty, given reasonable notice, and in accordance with national law.
DOCUMENT RETENTION
● Applicants’ or workers’ passports, residency or work permits or other personal documents, such as bank
books or automatic teller machine (ATM) cards, are not kept or withheld for any reason.
● In the event that personal documents are held by the employer or subcontractor due to legal
requirements or upon request by the worker, these are immediately returned to the worker upon demand
and without any preconditions. In such circumstances, the employer or subcontractor:
○ Provides workers with an exact copy of personal documentation when not in their possession;
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○ Develops written policies and procedures to prevent abuse;
○ Nominates a responsible person to ensure workers have unhindered access to their documents
upon demand; and
○ Notifies workers of these procedures.
● Lengthy or otherwise burdensome prerequisites for accessing one’s passport or other personal
documents, such as written requests, monetary deposits or waiting periods, are strictly prohibited.
● Migrant workers are provided with a locked, secure storage space, accessible without permission or notice
24 hours a day, 7 days a week, for personal documents and valuables.
DEPOSITS
● Workers are not required to post a bond at the time of recruitment or at any other time during the
employment relationship.
● The company policies strictly prohibit the collection of deposits or security payments.
● The company, or subcontractor acting on its behalf, withholds portions of workers’ pay only where it is
legally required.
● In those cases where migrant workers have opted to participate in voluntary savings schemes facilitated by
their employer, such workers have unhindered access to and full control over all savings and monies owed
at the time of contract termination.
HUMANE TREATMENT
● Company policies and procedures prohibit sanctions that impose work or wage deductions as a means to
discipline workers.
● No form of compulsory labor is imposed on any worker.
● The policy of the company, or subcontractor acting on its behalf, strictly prohibits the use or threat of
physical or sexual violence, harassment and intimidation, and senior management has expressed clear
commitment to this policy.
● Effective measures are in place to implement, monitor, and ensure company-wide compliance with this
policy.
● There is no evidence of complaints, grievances, or actions taken against the company, its managers or
supervisors with respect to violence, intimidation, or harassment in the workplace. In cases where a
complaint or grievance has been raised, evidence should show that swift and transparent action was taken
to address it.
WORKPLACE EQUALITY
● All workers, regardless of their national origin, ethnicity, race, or legal status, are treated equally in the
workplace.
● Migrant workers are treated no less favorably than country nationals with respect to:
○ Remuneration, hours of work, overtime arrangements, and holidays with pay;
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○ Membership in labor unions;
○ Accommodation; and
○ Benefits and social insurance, including social security, maternity and sick leave, disability and
employment injury insurance.
● The company, or subcontractors acting on its behalf, explicitly prohibits the abuse of vulnerability of
migrant workers, including the threat of denunciation to authorities as a means of coercion.
WAGES AND BENEFITS
● The freedom of workers to dispose of their wages is not limited in any way.
● Wages specified in employment contracts meet legal or industry minimum wage standards in the country
of employment, and wage calculations are equitable and objective.
● Wage payments are not deferred, delayed, or withheld as a means of binding workers to employment.
● Non-cash or “in-kind” payments are not used as a means to create a state of dependency of the worker on
the employer.
● Wage rates and payments are calculated with full transparency.
● The calculation and payment of wages, including legal wage deductions, are clearly explained to workers,
and undertaken preferably with written worker consent.
● No unlawful or unauthorized deductions are made from workers’ wages.
● Wage deductions levied for tardiness or absence are not excessive and are commensurate to the time
missed on the job, for example 10 minutes worth of pay for 10 minutes tardiness.
● Wage advances or loans provided to workers, along with related interest rates, comply with the law.
○ Interest rates and repayment terms are fair, such that loans can be repaid in a reasonable amount
of time in short installment or financing periods not exceeding the remaining term of the
contract;
○ Provision of loans or advances, the calculation of interest rates and wage deductions made for
their repayment are made with complete transparency to the worker;
○ The terms of wage advances and their repayment are agreed to by both parties in advance and in
written form.
● Jobseekers, applicants or workers are not required to participate in any form of forced or mandatory
savings in order to recoup costs associated with recruitment or other services.
● Where the company, or subcontractors acting on its behalf, is required or requested to remit workers’
earnings to a third-party, this is only done with workers’ prior knowledge and full and voluntary consent,
and with provision of receipt for full amount remitted.
● If migrant workers are required by law to pay for room and board, such charges:
○ Do not exceed market rates or the rate paid by local workers;
○ Should not aid companies or subcontractors in earning a profit at workers’ expense; and
○ Are not part of efforts to reclaim placement fees or other fees paid by employers for worker
recruitment.
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WORKING HOURS
● Workers are not forced to work more than the number of hours allowed by national law, or, where the law
is silent, working hours do not exceed eight per day and forty-eight per week, and total working hours
including overtime does not exceed 60 hours in a week.
● Effective workplace and company-wide measures are adopted to ensure full implementation and
compliance with this policy.
● All overtime work is purely voluntary, unless specifically stated otherwise in a legally recognized collective
bargaining agreement.
● Workers are free to refuse overtime work without threat or fear of punishment or reprisal.
● For those that agree to work overtime, a system is in place to obtain their written consent at the time of
the request.
● In cases where remuneration is based on productivity targets, for example piece rate, workers are not
forced to work more overtime hours than allowed by national law in order to achieve their production
quota.
FREEDOM OF MOVEMENT AND PERSONAL FREEDOM
● Workers enjoy reasonable freedom of movement within their work and living environments. Any
legitimate constraints on such movement in the workplace are specified prior to the signing of the
employment contract.
● The presence of security personnel or other security measures in the workplace or employer- or
recruiter-operated residences are not used as a means to restrict worker freedom of movement.
● No other coercive means are used to restrict migrant workers’ freedom of movement or personal
freedom, including confiscation of personal documents, levying of financial penalties or security deposits,
or use of deception in wage payment and deductions.
● Workers are not required to live in employer- or recruiter-operated residences as a condition of
recruitment or continued employment.
● Migrant workers are free to return to their home country during paid leave, without any penalty, or threat
of termination.
GRIEVANCE PROCEDURES
● Supplier and recruiter policy and practice reveals a functioning and effective grievance procedure available
to local and migrant workers.
● Effective measures are in place to ensure that migrant workers know how to use this procedure and feel
safe and free from potential retaliation if doing so.
● Where grievances are raised, effective and appropriate procedures are in place to ensure a rapid and
mutually agreed settlement.
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PRIVATE EMPLOYMENT AGENCIES AND LABOR RECRUITERS
● The supplier should hire migrant workers directly whenever possible.
● When the recruitment, selection, and hiring of workers is undertaken by a private employment agency or
other third-party, suppliers shall have the responsibility to ensure that the agencies operate legally, are
certified or licensed by the competent authority, and do not engage in fraudulent behavior that places
workers at risk of forced labor or trafficking for labor exploitation.
● The company signs a formal contract with the subcontracted agency and performs due diligence on the
agency and its partners involved in the hiring and placement of migrant workers.
● Effective measures are established by the company to ensure the legal compliance of sub-contractors in
each jurisdiction in which they operate.
● The subcontracted agency has an up-to-date license or permit to operate in all countries of operation, and
any partners or agents working on its behalf also have up-to-date permits or licenses.
● The subcontracted agency has not been cited, suspended, or otherwise sanctioned for non-compliance
with any laws in any country of operation; or, where a citation for non-compliance exists, the agency can
demonstrate that it has rectified the non-compliance.
● The company has mechanisms to ensure that no deception, fraud and/or coercion in the recruitment,
placement, transport or management of migrant workers take place.
○ The company, or subcontractors acting on its behalf, provides jobseekers with accurate details of
working conditions at the time of recruitment, including the nature of work, wages, benefits and
duration of contract.
○ Details of working and employment conditions are communicated to jobseekers in a language
they understand.
○ False promises are not made to applicants or workers regarding employment conditions, job
locations, employment or contract duration, or anticipated earnings.
○ Training is provided to workers both before departure and upon arrival to ensure that they
understand their own rights and employer obligations and responsibilities.
○ Pre-departure orientation is conducted to review contractual obligations, terms and conditions of
work and other matters including but not limited to living conditions, company policies, and any
grievance mechanisms that may be in place for workers.
● The subcontracted agency has an implementing structure, an accountable officer, and clear procedures to
ensure that all policies are compliant with all relevant legislation and regulations. This includes a current
registry of laws for all countries of operation; and a mechanism that ensures the company is regularly
informed of new legislation/regulations or changes in legislation/regulations.
● The subcontracted agency has a code of conduct that prohibits forced labor and human trafficking and
sets out protective measures for migrant workers. The code covers principles elaborated in relevant ILO
Conventions and the Code of Conduct of the International Confederation of Private Employment Agencies
(CIETT), and applies to all parties in the chain of recruitment. The code is supported by an institutional
structure that ensures its effective implementation.
● The subcontracted agency has established a mechanism for confidential reporting of noncompliance, a
grievance mechanism, procedures of investigation and reporting on grievances, and protection for
whistleblowers.
● The subcontracted agency has established effective remediation procedures in case of verified reports of
noncompliance, including mechanisms to ensure the reimbursement of workers for any recruitment fees
charged.
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● The company, or subcontractors acting on its behalf, does not use any means to restrict migrant workers’
freedom to terminate employment, for example by levying excessive recruitment fees, requiring deposits,
or withholding personal documentation.
Appendix K: QuickBase Handbook Instructions
Please refer to this handbook to see instructions on various actions that can be done in QuickBase. This includes
onboarding, uploading documents (Garment Registration, WCC, Deadstock Verification letters), updating
traceability information, etc.
Appendix L: Sustainable Forests Commitment
Reformation is deeply committed to sourcing environmentally conscious materials and engaging suppliers to gain
traceability into all levels of the supply chain so we can confidently stand behind our stuff. We are a proud member
of the CanopyStyle Initiative to help drive positive change for our forest products and ensure that all our
forest-based products come from sustainably managed forests. This includes the sourcing of cellulosic fibers such
as viscose, modal, and lyocell, as well as paper and paper-based packaging products. Along with commiting to
conserving, protecting and restoring natural resources, our Sustainable Forest Commitment outlines our
requirement for our suppliers to work with fibre manufacturers who are committed to implementing the Changing
Markets Roadmap, including moving to a closed-loop system by 2023-2025.
Conservation of Ancient and Endangered Forests and Ecosystems
Reformation is committed to eliminating fibers sourced from ancient and endangered forests[1]. If we discover that
fabrics, paper or packaging we are using contain virgin raw material from ancient or endangered forests, we will
work with our suppliers to shift fiber sourcing to meet our forest policy requirements. We support the CanopyStyle
initiative and the collective effort to source only fabrics free of ancient and endangered forests by 2020.
Reformation will continue to:
1. Assess our existing use of forest fibers and eliminate sourcing from endangered species habitat and
ancient and endangered forests[2].
2. Work to eliminate sourcing from companies that are logging forests illegally[3], engaged in deforestation,
or from areas being logged in contravention of indigenous and local peoples’ rights, or from other
controversial suppliers.
3. Work with Canopy and our suppliers to support collaborative and visionary solutions that protect
remaining ancient and endangered forests.
4. Should we find that any of our fibers are being sourced from ancient and endangered forests, endangered
species habitat or illegal logging, we will engage our suppliers to change practices and/or re-evaluate our
relationship with them.
Recognizing, respecting and upholding human rights and the rights of communities
Reformation will request that our suppliers respect the Universal Declaration of Human Rights and acknowledge
indigenous and rural communities legal, customary or user rights to their territories, land, and resources.[8] To do
so, we request that our suppliers acknowledge the right of Indigenous People and rural communities to give or
withhold their Free, Prior and Informed Consent (FPIC) before new logging rights are allocated or plantations are
developed. We request that our suppliers resolve complaints and conflicts, and remediate human rights violations
through a transparent, accountable, and agreeable dispute resolution process.
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Reduce greenhouse gas footprint
As part of our ongoing leadership on climate Reformation supports initiatives that advance forest conservation to
reduce the loss of high carbon value forests. We encourage suppliers to avoid harvest in these areas and give
preference to those that use effective strategies to actively reduce their greenhouse gas footprint.
Forest certification for fibers
Reformation will continue to request that any fibers that must be sourced from forests are from responsibly
managed forests, certified to the Forest Stewardship Council (FSC) certification system, and where FSC certified
plantations[9] are part of the solution.
Shift to more environmentally and socially beneficial fibers
Reformation is committed to conserving, protecting and restoring natural resources. Reformation will collaborate
with Canopy , innovative companies and suppliers to encourage the development of fiber sources that reduce
environmental and social impacts, with a focus on agricultural residues[10] and recycled fabrics and fibers.
In 2020, Reformation will put in place a preference for purchasing man-made cellulosics with a minimum of 50% of
innovative fiber sources and develop a 2025 procurement target for these closed-loop solutions, based on viscose
fiber producer innovation.
Where virgin fiber is necessary, Reformation will work with suppliers and Canopy to explore and encourage the
development of agricultural residues and fibers such as wheat straw as a commercially viable fiber source for
paper-based packaging.
Further, Reformation also commits to continue maximizing our use of papers and packaging with high
post-consumer recycled and agricultural residue content. We use Canopy’s Ecopaper database and The Paper
Steps as a guide for paper sourcing.
Support best processing practices
Reformation requires that our man-made cellulosic suppliers use best available environmental practices for
processing, such as ‘closed-loop’ processing of water and chemicals and adhere to our RSL and MRSL . We require
our suppliers to work with fibre manufacturers who are committed to implementing the Changing Markets’
Roadmap , which includes moving to a closed-loop system to ensure emission controls of chemical recovery rates by
2023-2025.
Paper manufacturing is a resource-intensive process that can lead to air and water emissions that impact overall
environmental quality. Therefore we give purchasing preference to paper that is chlorine free and has been
processed utilizing responsible bleaching technologies such as chlorine free (PCF and TCF is preferred with ECF as a
minimum) bleaching as per The Paper Steps . We also give preference to suppliers that monitor and reduce overall
emissions by adopting the latest technologies and practices to minimize air and water pollution.
Design and prioritization and reduction and reuse
Reformation understands that the reduction and re-use of paper and packaging is of paramount importance for the
protection of the world’s limited forest resources. Over the next 3 years, with the support of Canopy, we will
continue to:
1. Source or design reusable/refillable shipping boxes to reduce corrugated paper and paperboard
2. Design and implement e-commerce, shipping, display and wrapping systems that minimize the use of
paper
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3. Utilize reusable packaging systems for intra business applications
4. Increase the use of digital communication, marketing and accounting systems
5. Adopt best practices including researching and applying emerging and circular economy innovations.
Promote industry leadership
Reformation looks to create a positive impact together with our suppliers, partners and customers. As
implementation progresses, Reformation will work with suppliers, non-governmental organizations, other
stakeholders and brands that are part of the CanopyStyle initiative to support the protection of ancient and
endangered forests and forward solutions to reduce demand on our forests. We will also seek opportunities to
educate and inform the public on these issues and solutions through our marketing and communications.
[1] Ancient and endangered forests are defined as intact forest landscape mosaics, naturally rare forest types, forest types that have been made
rare due to human activity, and/or other forests that are ecologically critical for the protection of biological diversity. Ecological components of
endangered forests are: Intact forest landscapes; Remnant forests and restoration cores; Landscape connectivity; Rare forest types; Forests of
high species richness; Forests containing high concentrations of rare and endangered species; Forests of high endemism; Core habitat for focal
species; Forests exhibiting rare ecological and evolutionary phenomena. As a starting point to geographically locate ancient and endangered
forests, maps of High Conservation Value Forests (HCVF), as defined by the Forest Stewardship Council (FSC), and of intact forest landscapes
(IFL), can be used and paired with maps of other key ecological values like the habitat range of key endangered species and forests containing
high concentrations of terrestrial carbon and High Carbon Stocks (HCS). (The Wye River Coalition’s Endangered Forests: High Conservation Value
Forests Protection – Guidance for Corporate Commitments. This has been reviewed by conservation groups, corporations, and scientists such as
Dr. Jim Stritholtt, President and Executive Director of the Conservation Biology Institute, and has been adopted by corporations for their forest
sourcing policies). Key endangered forests globally are the Canadian and Russian Boreal Forests; Coastal Temperate Rainforests of British
Columbia, Alaska and Chile; Tropical forests and peatlands of Indonesia, the Amazon and West Africa.
[2]A good source to identify endangered, threatened and imperiled species is NatureServe’s Conservation Status rankings for imperiled species
that are at high risk of extinction due to very restricted range, very few populations (often 20 or fewer), steep declines in populations, or other
factors .
[3]Legal forest management is management that complies with all applicable international, national, and local laws, including environmental,
forestry, and civil rights laws and treaties.
[4]Coastal temperate rainforests are rare and only ever covered 0.2% of the planet. On Vancouver Island only 10% of Vancouver Island’s
productive old growth rare coastal temperate rainforest remains. These stands of 1,000-year old trees continue to be harvested despite their
immense value to local communities for tourism. Their accessibility and beauty is a remarkable global asset and Canopy is working to see these
last stands protected.
[5]Conservation solutions are now finalized in the Great Bear Rainforest. On February 1st, 2016 the Government of British Columbia, First
Nations, environmental organizations and the forest industry announced 38% protection in the Great Bear Rainforest and an ecosystem-based
management approach that will see 85% of this region off limits to logging. Provided these agreements hold – sustainable sourcing has been
accomplished in this ancient and endangered forest. We encourage ongoing verification of this through renewal of Forest Stewardship Council
certification.
[6]Protection of Boreal Forests where the largest remaining tracts of forests are located worldwide is critical and dissolving pulp is becoming an
increasing threat. Canada’s Boreal Forest contains the largest source of unfrozen freshwater worldwide and is part of the world’s largest
terrestrial carbon sink – equivalent to 26 years worth of global fossil fuel use. Canopy is committed to working collaboratively on the
establishment of new protected areas, the protection of endangered species and the implementation of sustainable harvesting in Canada’s
Boreal Forest.
[7]Indonesia experiences the second highest rate of deforestation among tropical countries, with the island of Sumatra standing out due to the
intensive forest clearing that has resulted in the conversion of 70% of the island's forested area (FAO Forest Assessment 2010; Margono, B.A. et
al. 2012). Canopy and our NGO partners are focused on forwarding lasting protection of the Leuser Ecosystem. Asia Pulp & Paper (APP) and Asia
Pacific Resources International Ltd. (APRIL) have been identified as the primary cause and have been criticized by local and international groups
for being implicated in deforesting important carbon rich peatlands, destroying the habitat for critically endangered species and traditional
lands of indigenous communities, corruption, and human rights abuses (Eyes on the Forest. 2011.
https://www.eyesontheforest.or.id/news/pada-bulan-ini-di-tahun-2010-eof-menghimbau-app-dan-april-untuk-menepati-janji-mereka ). APP and
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APRIL have both put in place forest policies, tracking implementation closely will be key to understanding if either company offers lasting
solutions for Indonesia’s rainforests. Cellulosic fibre producer Sateri, is part of the Royal Golden Eagle Group along with APRIL.
[8] http://www.un.org/en/universal-declaration-human-rights/
[9] Plantations areas that have been “established by planting or sowing using either alien or native species, often with few species, regular
spacing and even ages, and which lack most of the principal characteristics and key elements of natural forests”. Plantations prior to 1994 are
often FSC certified. Source FSC: FSC® and Plantations - Forest Stewardship Councilic.fsc.org › file-download.fsc-and-plantations.a-1723.pdf
[10]Agricultural Residues are residues left over from food production or other processes and using them maximizes the lifecycle of the fibre.
Fibres used for paper products include cereal straws like wheat straw, rice straw, seed flax straw, sugarcane bagasse, and rye seed grass straw.
Where the LCA (life cycle analysis) shows environmental benefits and conversion of forest land to on purpose crops is not an issue, kenaf can
also be included here. Depending on how they are harvested, fibres for fabrics may include flax, soy, bagasse, and hemp. (Agricultural residues
are not from on purpose crops that replace forest stands or food crops.)
References
AFIRM GROUP
www.afirm-group.com/afirm-rsl
AMERICAN APPAREL & FOOTWEAR ASSOCIATION (AAFA)
www.aafaglobal.org/AAFA/Solutions_Pages/Restricted_Substance_List
APPAREL IMPACT INSTITUTE
https://apparelimpact.org/
BLUESIGN®
https://www.bluesign.com/en
GLOBAL ORGANIC TEXTILE STANDARD (GOTS)
https://www.global-standard.org/
HIGG INDEX
https://apparelcoalition.org/the-higg-index/
ILO CONVENTIONS
www ilo org/global/standards/introduction-to- international-labor-standards/conventions-and-
recommendations/lang--en/index htm
LEATHER WORKING GROUP (LWG)
https://www.leatherworkinggroup.com/
NRDC CLEAN BY DESIGN
www.nrdc.org/resources/clean-design-apparel-manufacturing-and-pollution
OEKO-TEX®
https://www.oeko-tex.com/en/
TEXTILE EXCHANGE
https://textileexchange.org/
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