On January 1, 2012, California enacted a law that requires certain retail companies and manufacturers doing business in California to disclose their corporate policies that aim to eradicate slavery and human trafficking in their supply chains. In alignment with the intent of the legislation, the following disclosure provides an overview of Justice’s human rights and social compliance initiatives, including the steps we take to mitigate the risks of slavery and human trafficking in our supplier base.
Vendor and factory information is managed by a dedicated team and supported by a database that includes mapping of all suppliers. Supplier profiles are collected with key attributes that are included in a risk assessment. The approval process for new vendors consists of 3 parts: risk assessment, pre-sourcing assessment and verification. Prior to approval, risk assessments are conducted by utilizing sources such as Dun & Bradstreet, Trafficking in Persons Report, and BSI SCREEN program. System intelligence includes analytic data that provides updated information on possible human trafficking sources and receiving countries, as well as alert notification when the level of risk changes. We require that third-party auditors review places of production including the facilities of many sub-contractors. These programs help our business understand the different factors that can contribute to the risk of human trafficking. Additional training is made available to vendors and factories that may be at risk for human trafficking in their supply chain.
Pre-sourcing and annual audits are conducted to assess compliance with all of our company standards. The audit approach includes announced, semi-announced, and unannounced audits based on risk assessment. Audit activities include worker interviews, review of documents, inspection of dorms and factory tours. Results are reviewed with factory management. Any severe risk is reported to upper management and additional training and education may be conducted to address such risk. Whenever serious issues are found, suppliers are expected to engage in remediation and training which includes a corrective action plan and a series of e-learning modules specifically designed to address the risk in their supply chain. Based on audit results, follow-up audits may be required to ensure factories are working towards continuous improvement. Any supplier that does not demonstrate a willingness to make improvements may face termination.
All Vendors are bound by contract, and do represent and warrant in our agreement, to abide by all applicable employment and human rights laws, as well as our Code of Conduct, which, among other things, prohibits the use of child labor and forced or involuntary labor, forced overtime, discrimination, or bonded or prison labor. The Code of Conduct emphasizes the importance of well-treated, fairly compensated workers. Our Integrated Compliance Monitoring program seeks to promote the maintenance of these standards in our manufacturing facilities and assesses compliance with our Code of Conduct.
Ascena Code of Business Conduct is a guideline for ethical business conduct and how we do business. This code, also available on our corporate website, is a summary of basic principles for working in a way that reflects our Company’s commitment to ethics and integrity. Associates are trained and required to report any suspected violations of the Code of Ethics, and such reports may be submitted in writing or made to the Corporate Governance Hotline that is available to all associates.
Relevant annual training is conducted for associates that engage regularly with vendors. These trainings include webinars and eLearning which address risks of forced labor, human trafficking and supply chain security. Vendors participate in training through our on-boarding process, and are trained more frequently when related risks are identified.