This statement is furnished pursuant to the California Transparency in Supply Chains Act of 2010 (SB 657) and the UK Modern Slavery Act (2015).
At Workwear Outfitters, we respect human rights in our operations and extended value chain, and conduct business ethically and sustainably. Workwear Outfitters supports human rights as defined by the Universal Declaration of Human Rights, which recognizes that “all human beings are born free and equal in dignity and rights.” We work to elevate human potential through our products, partnerships, and operations. We expect the same from our suppliers, and we focus on working with long-term, strategic suppliers that demonstrate a commitment to engaging their workers and providing safe working conditions. This includes working to combat risks of forced labor.
Pursuant to the California Transparency in Supply Chains Act of 2010 (SB 657) (“CTSCA”) and the UK Modern Slavery Act of 2015 (“MSA”), Workwear Outfitters publishes this statement to discuss our global business practices to address forced labor. As used in this statement, forced labor includes modern slavery, prison labor, indentured labor, bonded labor, human trafficking, or other similar conduct.
II. Policies on Modern Slavery and Human Trafficking
In 2010, the California legislature passed the California Transparency in Supply Chains Act (SB-657) with the goal of informing consumers and businesses about companies’ efforts to address slavery and human trafficking in their supply chains. In 2015, the UK implemented the UK Modern Slavery Act to also combat the issues of forced labor in supply chains. In compliance with both the CTSCA and MSA, this document outlines Workwear Outfitters’ stance and policies relating to forced labor. Workwear Outfitters takes seriously and fully supports national and international efforts to end forced labor.
Workwear Outfitters has adopted the following broad definition of slavery: “a person who is forced to work, without pay, under threat of violence, who cannot walk away,” as defined by the international non-governmental organization, Free the Slaves (see http://www.freetheslaves.net/about-slavery/faqs-glossary/). Additionally, Workwear Outfitters has adopted the following broad definition of human trafficking: “any recruitment, harboring, transportation, provision, or obtaining of a person for labor services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery” as defined in the Victims of Trafficking and Violence Protections Act of 2000.
Workwear Outfitters respects the ILO Core Conventions, the United Nations Universal Declaration of Human Rights, and the ten principles of the United Nations Global Compact. These standards are the foundation for Workwear Outfitters’ labor-related policies.
Workwear Outfitters operates under a Business Code of Conduct, which sets forth the key principles under which Workwear Outfitters, and any individual or entity working for or on behalf of Workwear Outfitters, is required to operate. The Business Code of Conduct expressly states that business conduct with employees, customers, consumers, suppliers, and all others shall be on an honest, fair, and equitable basis. It has been, and will continue to be, our company’s policy to obey the laws of each country and to honor our obligations to society by being an economic, intellectual, and social asset to each community and nation in which Workwear Outfitters operates.
Additionally, Workwear Outfitters operates under a Terms of Engagement, which sets forth the high standards with which Workwear Outfitters expects its contractors, suppliers, agents, facilities, and other business partners to operate. As part of these standards, Workwear Outfitters will only do business with contractors, suppliers, and agents who operate within a set of ethical standards compatible with Workwear Outfitters’ Business Code of Conduct and Global Compliance Principles. Additionally, Workwear Outfitters requires each contractor, supplier, and agent, working for or on behalf of Workwear Outfitters, to, at all times, comply with all applicable local, state, federal, national, and international laws, rules, and regulations, including those related to wages, hours, employment, labor, health and safety, the environment, and immigration. Workwear Outfitters requires each of its authorized facility to sign, as part of the Terms of Engagement, a statement which expressly prohibits the use of forced labor, including human trafficking.
Below, you will find additional specific steps which Workwear Outfitters takes to address human trafficking, slavery, and forced labor in our business and supply chain practices. For these reasons, Workwear Outfitters assesses our risk of slavery, forced labor, and human trafficking as low.
With the use of Workwear Outfitters’ Master Manufacturing Agreement, found within each individual Product Order, Workwear Outfitters requires all company owned facilities and Tier 1 suppliers to verify that their goods were not produced using forced labor. Further, and as mentioned above, Workwear Outfitters’, through the use of its Terms of Engagement, requires all company owned facilities and Tier 1 suppliers to verify, in a signed writing, that their facilities provide workers with a safe and healthy work environment and that the supplier is in compliance with all applicable occupational health, safety, and environmental protection laws. The Terms of Engagement is signed by each Tier 1 supplier when they are first set-up in Workwear Outfitters’ systems. Moreover, Workwear Outfitters partners with a 3rd party vendor in the further verification of our company owned facilities and Tier 1 suppliers regarding how products were produced in accordance with our Global Compliance Principles.
Workwear Outfitters partners with a 3rd party vendor to conduct audits of company owned facilities and Tier 1 suppliers to evaluate supplier compliance with Workwear Outfitters’ standards for forced labor in supply chains. As mentioned above, Workwear Outfitters operates under a Business Code of Conduct, which sets forth the key principles under which our company, and any individual or entity working for or on behalf of our company, is required to operate. Our Business Code of Conduct states that factories must not use forced labor of any kind. For clarification, human trafficking and slavery fall under the categorization of “forced labor.”
Each of Workwear Outfitters’ contractors, suppliers, and agents agrees that, by accepting orders from Workwear Outfitters, it will abide by and implement the Workwear Outfitters Terms of Engagement, which expressly requires all authorized facilities or factories to maintain, on site, all documentation necessary to demonstrate compliance with Workwear Outfitters’ Global Compliance Principles. All factories or facilities, with whom we do business, must allow Workwear Outfitters and/or its representatives unrestricted access to conduct announced and unannounced on-site inspections of its facilities and permit unrestricted access to all relevant records at all times during regular business hours.
In accordance with Occupational Health and Safety Administration (“OSHA”) regulations and internally defined safety and health requirements, which may exceed OSHA requirements in some circumstances, Workwear Outfitters has implemented a program entitled the Ideal Plant Model (“IPM”), which defines the expectations for safety performance and other conservation standards. These expectations and standards can be used to objectively grade the safety and property conservation in specific areas. Each Workwear Outfitters owned location is subject to an IPM audit by a trained auditor and are graded on certain express criteria, which are divided into several performance issues for which specific standards are set. The main criteria to evaluate are: (1) General Guidelines, (2) Housekeeping, (3) Safety Committee, (4) Loss Review, (5) Ergonomics, (6) Lockout/Tagout, (7) Hazard Communication, (8) Occupational Health, and (9) Plant Safety Hazard Controls. These IPM audits are designed to ensure that our facilities are operating in accordance with applicable laws and internal Workwear Outfitters policies, including, but not limited to, laws and policies related to forced labor, employment, and facility safety.
Workwear Outfitters is a member of Worldwide Responsible Apparel Productions (“WRAP”). This organization is committed to the principles of fair treatment of workers and humane working conditions. These standards prohibit use of child labor, forced labor, harassment, or discrimination. Factories must adhere to all laws of the jurisdiction where the plant is located. Workwear Outfitters enforces these standards not only in its own factories, but in every factory which makes product on its behalf.
WRAP certification is achieved through a three-step process:
More information about WRAP can be found at the official WRAP web site: www.wrapparel.org.
Further, Workwear Outfitters mandates that all factories producing our products operate in full compliance with the laws of their respective countries, including those relating to forced labor. Any facility operating on behalf of Workwear Outfitters certifies its compliance with the Workwear Outfitters Terms of Engagement, which, as mentioned above, specifically prohibits forced labor and human trafficking in business and supply chain operations. With each Product Order, facilities and Tier 1 suppliers certify, through the use of our Terms of Engagement, that products are made in accordance with all applicable laws and regulations, as well as all internal Workwear Outfitters policies.
D. Internal Accountability
Workwear Outfitters maintains internal accountability standards and procedures for employees, contractors, and facilities who fail to meet Workwear standards regarding forced labor. Failure of a Workwear employee or contractor to abide by our Business Code of Conduct, Global Compliance Principles, or Terms of Engagement may result in corrective action, including termination of employment or contractor relationship. Failure of factories to abide by our Business Code of Conduct, Global Compliance Principles, or Terms of Engagement may result in corrective action, including termination of business.
Workwear is in the process of developing a comprehensive training program for its employees that have direct responsibility for supply chain management, training on human trafficking and forced labor. This training will focus particularly on mitigating risks within the supply chain of products.
III. Looking Ahead
Workwear Outfitters will continue to assess its business and supply chains to identify potential risks and target those areas with policies, procedures, and trainings to ensure it maintains appropriate safeguards against the mistreatment of persons.
This statement covers January 1, 2022 to December 31, 2022 and was approved and signed by the undersigned, a director of Workwear Outfitters, on January 18, 2022.
Chris Holcombe, CEO
Workwear Outfitters, LLC