Apparel and Textiles - Human Rights - Policy, Targets and Due Diligence

C is a clothing company with a globally operating supply chain. C’s human rights policy covers the following aspects:

1. Commitment to the OECD Due Diligence Guidance for Responsible Supply Chains in the garment and footwear sector, covering:

1. its integration in the company’s risk assessment throughout supply chain,
2. and stakeholders engagement - roundtables with manufacturers.

2. Identification of the following salient issues in the supply chain, also included as zero-tolerance criteria in C’s Supplier Code of Conduct:

1. child and forced labour,
2. working hours, wages and work permits,
3. bribery and corruption,
4. workplace and living area safety (eg. fire protection),
5. wastewater treatment and discharge,

and the following most common issues:

1. compensation and working hours,
2. building and fire safety,
3. freedom of association,
4. undisclosed production.

C is also providing details on:

1. where in the supply chain the issues occur,
2. C's connection to the issue (volume of trade),
3. the affected people.

3. Measurable targets to mitigate all identified salient human rights issues, alongside the data on the progress towards meeting them:

• 100% of the product volume from A/B-rated suppliers by 2020 (details on the rating process are provided below),
• 100% of sustainably sourced cotton by 2020.
• Indicators to monitor progress towards targets include:

• a map of all of its suppliers’ tier-1 and tier-2 factories (companies are obliged to describe at minimum their high risk supply chain and C goes beyond the expected standard),
• supplier rating including sustainability criteria:

• units rated A and B have no serious violations,
• any discovery of zero-tolerance issue will automatically result in an E rating of the supplier (zero tolerance issues are also listed in the suppliers code of conduct),
• C publishes a graphic with overall ratings of all production units divided by country,

• own employees workforce data:

• workforce composition,
• gender diversity by contract type, job title and location,
• space for improvement:

• C should also disclose data on turnover,
• gender pay gap,
• % of workers with guaranteed living wage,
• % of workers covered by collective bargaining;

• workforce data concerning workers of C’s tier 1 suppliers, including

• vulnerable groups in workforce,
• % of workers with guaranteed living wage,
• % of workers covered by collective bargaining;

• and any data on purchasing policy implementation: e.g. % of contracts where wage costs are ring-faced.

Due diligence

1. general description of process to identify human rights risks, including:

1. audit of all of its suppliers at least once a year (audits are not announced and result in supplier rating and corrective actions);
2. what sources of information were used for the assessment (legal documentation, compliance hotlines, inspections in factories, warehouses, dormitories and canteens);
3. and with which suppliers C cooperates more closely on improvement (all suppliers with worse rating results and also with suppliers where the cooperation was terminated so it is possible to renew it in the future);
4. all new suppliers must demonstrate that they meet C’s sustainability criteria.

2. Actions taken to prevent or mitigate identified human rights issues (eg. where collective bargaining is restricted by law, C’s suppliers are obliged to establish alternative forms of worker representation, including grievance mechanisms and reinstate and compensate dismissed workers whose freedom of association was breached).
3. Description of how they involved affected people in the above steps, incl:

1. grievance mechanisms,
2. consultations with trade unions,
3. training of workers on their workplace in cooperation with local NGOs.

4. Space for improvement: Assessment of how the company’s purchasing policy and practices may contribute to the risks of adverse impacts on the workforce.

These human rights targets are included in C&A’s Global Sustainability Report 2019, available here: https://sustainability.c-and-a.com/uk/en/sustainability-report/fileadmin/pdf-sustainability/generate/globalsustainabilityreport2019/en/globalsustainabilityreport2019-en.pdf