CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
Disclosure for Gildan’s Genuine Stewardship website
In 2010, the California Legislature passed a new law, The California Transparency in Supply Chain Act of 2010 (SB 657), which requires manufacturers and retailers of goods with annual worldwide gross receipts over $100 million to provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains.
Human trafficking can take many forms, including forced and child labour, as defined in the following ILO Conventions:
- ILO Convention on Forced Labour, No. 29;
- ILO Convention on Abolition of Forced Labour, No. 105;
- ILO Conventions on the Worst Forms of Child Labour, No. 182.
Gildan’s current Code of Conduct, which was launched in 2005 and updated in 2012, guides our activities at each of our operating locations and clearly states our position on a wide range of labour practices.
This Code is based on the ILO conventions and its associated compliance benchmarks, which address forced labour, child labour, wages and benefits, working hours, harassment and abuse, as well as health and safety.
We monitor working conditions each year at all owned and contracted facilities manufacturing our products. As a company whose labour compliance program is accredited by the Fair Labor Association (FLA), Gildan facilities and the facilities of our manufacturing contractors are subject to the FLA’s rigorous monitoring, remediation and verification system. The FLA accredits monitors and uses internal auditors to conduct unannounced verifications.
Please read below for details on how Gildan complies with each points of the California Transparency in Supply Chain Act.
1. Company engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery.
Gildan evaluates the risks associated with its supply chain by evaluating contractors through its pre-sourcing assessment, which guides our business decisions and relationship with the manufacturing contractors we use.
These assessments are designed to ensure that, at a minimum, all facilities manufacturing our products comply with our own strict internal Code of Conduct, local and international laws, and the codes which we adhere to, including those of Worldwide Responsible Accredited Production (WRAP) and the FLA. All the aforementioned code and standards include strict provision with regards to forced and child labor such as human trafficking and slavery. When external suppliers are used, they must also adhere to these codes. This is a requirement for conducting business with Gildan.
To ensure that we meet or exceed our strict Code of Conduct requirements, we conduct a series of independent internal and third party audits each year, ensuring our commitment to responsibility for our employees, customers and other stakeholders. In 2012, 142 monitoring audits were performed. Of these, 90 were conducted by Gildan's internal auditors or by external auditors on Gildan's behalf, and 52 were conducted by external auditors or assessors for WRAP, the FLA, Better Work or by customers. For more information regarding Gildan’s auditing process, please refer to point 2 below.
2. Company conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.
Gildan audits all of its owned and contracted manufacturing facilities yearly. All Gildan audits are unannounced. The majority of the audits are conducted by our trained internal auditors and we also use independent third party auditors in some instances. We are also subject to audits from some of our customers.
Gildan audits its contractors’ facilities according to its Code of Conduct. Assessments are based on the standards in the Gildan Vendor Guidebook, which is provided to all our contractors. Our auditing and monitoring tools include:
- Facility self-assessment questionnaire
- Audit guidelines and management action plan
- Management interview form
- Monitoring guidelines
- Worker interview guidelines
Gildan uses a sampling methodology, based on the Sedex Members Ethical Trade Audit (SMETA) guidelines, to determine the number of documents to be reviewed and the number of individuals to be interviewed.
Additionally, some of our contractors have been participating in the ILO Better Work Programme. Gildan’s manufacturing facilities, as well as its contractors, are also audited by the FLA, WRAP and customers. Please read the Social Compliance section of our website for more information.
3. Company requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
To ensure that Gildan’s major contractors and suppliers respect and enforce the Gildan Code of Conduct, we include a clause in the commercial agreement governing our contractual relationship which stipulates that contractors must abide by our Code.
Gildan requires all business partners to confirm, by means of a signed statement, that they do not use or procure any cotton fiber, originating from Uzbekistan in any supplies of yarn to our organization or in the manufacturing of our products.
4. Company maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Non-compliances with the Gildan Code of Conduct can result in corrective action or termination, depending on the number of non-compliances found and their severity. Although Gildan will always first seek for sustainable remediation, we may terminate a business relationship with a contractor if it is deemed necessary. Our team of internal auditors work with contractors to develop action plans to resolve any instances of non-compliance.
5. Company provides company employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within supply chains of products.
All Gildan direct employees are trained on the key elements of our Code of Conduct. At our Haitian third party sewing contractors, training on our Code of Conduct is provided on an ongoing basis to all new employees. Our internal monitoring teams continuously receive different types of training on social compliance and human rights issues. They also work closely with our management team and our contractors to ensure they are knowledgeable of our Code requirements and understand the issues linked to social compliance.
In 2012, Code of Conduct training sessions for supervisors, managers and compliance staff took place at four major contractors (two in China and two in Mexico) as well as two sourcing agencies in Korea. The presentation included information about the Code of Conduct provisions and examples of non-compliances to the Code, as well as remediation examples. Similar training sessions are planned during the course of 2013 at other contractors in Asia.