Our Ethical Sourcing Program, which includes our 14 Rules to Trade, was implemented in 2009 and guides and governs the sourcing, manufacturing and supply of our products. This supplier code of conduct aims to protect workers’ rights and the environment, and strengthen our supplier relationships and commitment to traceability, transparency, cotton sourcing and sustainability.
The program has a robust testing framework, designed to provide assurances in areas such as fire and safety, electrical, structural or environmental issues, and workers’ rights. It also supports suppliers where necessary with corrective action and remediation. Forced labour, child labour and minimum wage are serious matters that are covered in our 14 Rules To Trade. We have a zero-tolerance stance on these matters and identified breaches are dealt with accordingly.
14 RULES TO TRADE
Before partnering with a supplier, we ensure that they understand how to adhere to our 14 Rules To Trade, which covers important issues like worker conditions, banned materials, the prohibition of child labour, environmental practices, bribery and corruption.
1. NO CHILD LABOUR
The supplier and their subcontractor shall not employ a worker under the age stipulated by the local/regional legal limit.
2. NO FORCED LABOUR
The supplier, manufacturer and subcontractor supplying goods to Cotton On Group shall not allow any form of forced, involuntary or prison labour.
3. NO DISCRIMINATION OR HARASSMENT
There shall be no discrimination in the hiring of workers; no physical, sexual or verbal harassment or abuse will be permitted in the work place.
4. RESPECT FOR FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING
All employees shall have the right of association, union membership and collective bargaining as well as adequate workers representation. Where the rights to either are restricted under law, the appropriate channels to ensure a reasonable and independent exercise of such rights must be designed.
5. WORKING CONDITIONS ARE SAFE AND HYGIENIC
Suppliers and subcontractors shall provide a safe and healthy workplace environment as per minimum requirements of the local and regional laws. All facilities must be structurally sound, hold a building safety certificate, and meet Cotton On Group compliance standards.
6. MINIMUM WAGES PAID
All suppliers and subcontractors shall ensure that wages paid for a working week must be at least the minimum national industry benchmark standards or collective bargaining agreement, should this latter be higher.
7. FAIR WORKING HOURS
Working hours for all workers shall comply with national / local laws and industry benchmark standards.
8. REGULAR EMPLOYMENT IS PROVIDED
Suppliers and subcontractors must ensure that, to every extent possible, work performed must be on the basis of recognized employment relationships established through national laws and practices.
9. RESPECT THE ENVIRONMENT
Suppliers and subcontractors shall be committed at all times to respect the environment and shall comply, at least, with the standards and requirements of the applicable local and international laws and regulations.
10. NO BRIBERY AND CORRUPTION
Under no circumstances will the Cotton On Group tolerate the practice of bribery and corruption in any shape or form in dealings with a supplier or subcontractor or any of their employees, or associated parties.
11. TRANSPARENCY IN AND FROM, ALL BUSINESS RELATIONSHIPS
Suppliers must disclose all subcontractors used for Cotton On Group production, and both suppliers and subcontractors must not refuse inspection from any Cotton On Group or third party auditor.
12. A VALID BUSINESS LICENCE MUST BE HELD
A permit to manufacture must be held by any Cotton On Group producing factory.
13. NO USE OF BANNED RAW MATERIALS OR BANNED PRACTICES
No factory is to use sandblasting as part of the production process, or use any banned raw material such as Uzbekistan cotton, Angora fur or Azo dyes in Cotton On Group products.
14. 14 RULES TO TRADE
All suppliers and subcontractors agree to implement and integrate, these ‘Rules To Trade’ and applicable laws into its business.
Auditing and corrective plan
In January 2014, in addition to the 14 Rules To Trade, we introduced an ethical sourcing audit to ensure our partners clearly understand and can meet our expectations. Each year we benchmark our audit process against international standards, which cover the areas of fire and safety, management practices, worker rights, factory conditions, waste management and the environment.
We actively encourage workers in our partnering factories to disclose serious matters to us – their rights are our primary concern. Worker interviews form a major part of the process, so we can make sure we are listening to our workers’ needs. We employ auditors to carry out independent checks of our supply partners.
In 2018, we conducted over 400 factory assessments, with 150 criterion to be satisfied in each audit. 2,500 worker surveys were also completed.
We identified serious failings against our 14 Rules to Trade across 57 factories. The failings identified included undisclosed subcontractors, record transparency and minimum hourly wages with remediation plans in place for each factory. In 2018, we had 461 approved factories and 48 conditionally approved factories.
We also provide training and education programs for owners, managers and factory workers to ensure they all understand the expectations and legal obligations to pay correct wages. Suppliers and buyers also have a self-check audit available, which enables them to conduct self-evaluation, undertake their own assessment and provide practical assistance to corrective action. In cases where remedial action is required, we work closely with suppliers to ensure improvements are made.MODERN SLAVERY AND TRANSPARENCY STATEMENT >