ABCDEFGHIJKLMNOPQRSTUVWXYZAAABAC
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Date10.16.21
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Company / Brand NameInditex
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Scope of EvaluationParent Company
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Impact AreaSub-categoryCriteriaQuestionsTips: Consider if the following publicly available. Can consumers researching your company find this information?Possible PointsPointsYes/NoScoreExplanation/ NotesLinks to Evidence
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1. Traceability:
Publicly sharing critical information about where products are made and the makers that make them. Ability to trace products and their components back through each step of the supply chain to the origin of raw materials.
1.1 Supply Chain Traceability: Public disclosure of what a company knows about where its products are made, the people who make them, and what conditions they live and work in.1.1.1 Supply Chain Disclosure: Company shares names and critical information about the factories and farms it sources from.1.1.1.i) Is the company publicly disclosing full supply chain traceability? 1. Company publicly discloses its Tier 1, Tier 2, Tier 3 and Raw Materials suppliers (including mines)
2. Factory list (w/names, locations, number of workers, photos/video, etc)

(1 point for tier 1 & 2 (cut and sew & fabric producers), 2 points for tier 3 (yarn producers) and 3 points for RM)
83No0Inditex states that it shares detailed information about its supply chains with key organizations and stakeholders.https://www.inditex.com/how-we-do-business/our-model/sourcing/traceability
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1.1.1.ii) Does the company publicly share the following information about existing labor conditions for Tier 1 workers and is it working towards full supply chain transparency?1. Lowest paid workers by country (1 pt)
2. Average wages by country (1pt)
3. Health and safety data violations (1 pt)
4. Hours worked/ overtime (1 pt)
5. Incidents of discrimination/ harassment / GBV (1 pt)
5No0p 362 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
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2. Wages & Well-being:
The extent to which makers and workers are empowered in their role in the fashion industry. This starts with the protection of basic labor rights (as defined by ILO Core Conventions), but goes beyond to ensure that makers and workers benefit from earning enough to invest in their well-being and futures and can gain access to skills and / or resources to help them and their communities advance.
2.1 Labor Standards: Policies and mechanisms in place to ensure that the basic rights and safety of makers and workers are being protected / respected.2.1.1 Labor Standards Oversight: Company uses a standard or product-level certification to assess factories' compliance with internationally accepted labor standards.
2.1.1.i) Does the company have a publicly available Code of Conduct / standard for assessing factories' compliance with international labor standards (and health and safety)?CoC is equivalent to or more stringent than (1pt):
-ILO Standards
-Fair Labor Association Code of Conduct

41Yes1https://www.inditex.com/documents/10279/241035/Inditex+Code+of+Conduct+for+Manufacturers+and+Suppliers/e23dde6a-4b0e-4e16-a2aa-68911d3032e7
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2.1.1.ii) Does the company publicly share full apparel factory audit and remediation reports, and does it make the reports and their findings available to garment workers, union leaders and garment maker committees (in their native languages) in audited factories?
1. Reports should be unredacted and include (1 pt):
-factory names
-buyer/brand names
-names of auditing partners

2. Company should have language specifying the frequency at which factories are assessed and if taking a risk-based approach (1 pt)

3. Company should disclose how audit information is shared (1 pt)
3Yes1No. 2https://www.inditex.com/en/our-commitment-to-people/our-suppliers/continuous-improvement
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2.1.2 Worker / Maker Voice: Makers have channels to voice concerns, issues and suggestions, or advocate for their rights so that they can be heard and addressed (while protecting their anonymity and safety, if necessary).2.1.2.i) Does the company take efforts to increase sourcing from factories that are unionized or are cooperatives? AND in environments where freedom of association is constrained, does the company have efforts / programs to promote trade union capacity building, or to strengthen worker-management cooperation?1. % of products sourced from unionized or cooperative factories (i.e. makers have representation and/or part ownership) is increasing, with the goal to reach 100% (1 pt)

2. Does the company disclose what % of workers are covered by collective bargaining agreements, with goals to increase? (1 pt)

3. Company uses its power to advocate for union capacity building in environments where FOA is constrained (1 pt)
33Yes1No. 3https://www.inditex.com/en/our-commitment-to-people/our-suppliers/shared-challenges
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2.2 Fair Wages & Social Programs: Ability of makers and workers, as a result of being able to earn a living wage, to improve their quality of life, and benefit from increased access to essential services, education, and investments in the well-being of their communities.2.2.1 Living Wage: Makers of the product earn (or are on their way to earning) a living wage.2.2.1.i) Does the company ensure that the majority (>50% by volume or number of factories) of garment makers in its entire supply chain earn a living wage (or significantly above minimum wage / industry average, with the goal of reaching a living wage)? 1. The company publicly discloses the percentage of garment workers receiving living wages (2pts)

2. Company is working with labor organizations to establish a living wage benchmark and is transparent about living wage benchmark methodology, i.e. the "basket of goods" a LW would need to cover (2 pts)

3. Publicly disclosed year-on-year wage data shows that the company is on track to provide 100% of makers with a living wage (2 pts)
126No0Still unclear what percentage, if any, of workers earn a living wage.p 214 -223 and p 362 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
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2.2.1.ii) Does the company ensure that the majority (>50% by volume or number of warehouses and stores) of all additional indirect employees in its entire supply chain (including drivers, models, and warehouse workers) earn a living wage (or significantly above minimum wage / industry average, with the goal of reaching a living wage)? 1. The company publicly discloses the percentage of additional indirect employees (delivery drivers, models, warehouse workers, etc.) receiving living wages (2pts)

2. Company is working with labor organizations to establish a living wage benchmark and is transparent about living wage benchmark methodology, i.e. the "basket of goods" a LW would need to cover (2 pts)

3. Publicly disclosed year-on-year wage data shows that the company is on track to provide to 100% of indirect employees with a living wage, or partner with companies in these sectors that provide living wages (2 pts)
6No0No information on this.
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2.2.2 Well-being: Makers of the product benefit from well-being investments / programs. Well-being initiatives include those shown to increase access to essential services (financial, health, benefits, housing, energy, water, sanitation, etc.); employment / career advancement; education.2.2.2.i) Does the company produce a majority (>50% by volume or number of factories) in factories where well-being programs are implemented? Well-being programs can include (2 pts):

-adequate childcare facilities, maternity benefits and maternal facilities
-worker-driven/selected benefits, housing allowance, transportation, healthcare, education stipends
-access to financial services, energy, water, sanitation, etc.

WHAT DOESN'T COUNT: trainings, one-off donations
22No0
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2.3 Grievance Mechanisms: Company should have clear and transparent procedures for addressing worker complaints and grievances throughout its supply chain that workers feel confident using without fear of retribution.2.3.1. Grievance Mechanisms: Effective, adequately funded, and governed operational level grievance mechanisms are in place to receive and address the concerns and grievances of affected or potentially affected stakeholders.2.3.1.i) Does the company have clear and effective grievance processes made accessible for workers in each part of the supply chain?This means that (2 pts):

-The company has several access points for workers to share grievances
-The company publicly discloses, and guarantees workers' awareness of, the grievance process, including appeals
-Workers have the ability to escalate grievances up to the brand level without fear of retaliation
-The company shares data around worker satisfaction with grievance procedure and outcomes
-The company publicly discloses the number of grievances and actions taken to resolve them
22No0Company does not provide the level of detail necessary to get points here - does not share outcomes of grievance procedures etc.https://www.inditex.com/documents/10279/643554/Ethics+Line+Procedure.pdf/e5926530-dca2-65c2-c004-5bc4ddeb4f81
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3. Commercial Practices:
How brands relate to its factories and other suppliers with respect to contracting, pricing, placing and changing orders, addressing conflicts that arise, and terminating the relationship. Company takes action to ensure it is not doing business in a way that undermines human rights, and that it is creating purchasing practices that foster fair pay and a humane pace of work.
3.1 Commercial Practices - Public Commitment: Company publicly acknowledges how its purchasing practices impact ability of suppliers throughout the value chain to uphold interntional labor standards.3.1.1. Buyer Code of Conduct: Company shares contractual and financial responsibility with its suppliers and factories upholding international labor standards.3.1.1.i) Does the company publicly commit to insert a Buyer Code of Conduct in all purchase order contracts with all Tier 1 suppliers?A Buyer Code should include, at a minimum, commitments to (1 pt):
-Carrying out human rights due diligence, including responsible purchasing
-Selecting suppliers using both commercial and human rights standards
-Negotiating contracts fairly and agreeing to prices that cover all costs of production, including costs associated with responsible business conduct
-Engaging in ongoing dialogue with suppliers throughout the course of the contract to ensure that buyers’ requirements, including change orders, do not undermine human rights
-Participating in human rights remediation processes in collaboration with other buyers, where appropriate
-Exiting contracts responsibly, by giving reasonable notice, paying outstanding invoices, and mitigating adverse impacts

Please see this example published by the American Bar Association’s Business Law Section Working Group to Draft Model Contract Clauses to Protect Human Rights in International Supply Chains, developed in wide consultation with industry stakeholders.

-The Code is legally binding, i.e. inserted into contracts
-The Code is publicly available on the company's website
-The company measures progress against the Buyer Code, including compliance in company KPIs
11No0
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3.2 Commercial Practices - Due Diligence-Aligned Buyer-Supplier Agreements: The contracts that brands and retailers draw up with the manufacturers that supply their products protect human rights and support fair pay and humane working conditions. The commitments reflect the conditions covered in the Buyer Code of Conduct. The Buyer Code of Conduct when inserted into purchase order contracts is legally binding.3.2.1. Fair Pricing: The prices that companies pay to their suppliers for goods should foster fair pay, sustainable progress and high labor standards. This encompasses planning and forecasting; sourcing; design and development; and costing and payment terms. 3.2.1.i) Do the company’s purchasing practices ensure the suppliers' ability to guarantee/support social and environmental sustainability? This means that (2 pts):

-Company makes a public capacity commitment to all Tier 1 supplier factories (not relevant for small businesses)
-Company’s purchasing practices reward suppliers for safeguarding worker’s rights (higher prices, repeat business, higher values etc)
-Company publicly commits to set prices high enough to cover investments in sustainability, safety and other compliance demands at the supplier level
-Company publicly commits to putting down at least 30% upfront investment in orders, to even out the risk between buyers, suppliers and garment makers
-Company publicly commits to never asking suppliers for discounts on orders
82No0Nothing evidencing this.
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3.2.1ii) Does the company commit to responsible sourcing timelines, in order to protect worker rights and well-being?-Company publicly commits to negotiating order timelines, factory bookings and changes in orders with respect to human rights (1 pt)
1No0Unclear.
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3.2.1.iii) Do the company’s purchasing practices ensure the suppliers' ability to provide workers with a living wage? This means that (5 pts):

-Company publicly commits to set prices high enough to cover living wages
-Company publicly commits to increase prices paid to suppliers in order to reflect increases in cost of living and wages and benefits over time

WHAT DOESN'T COUNT: ACT
Outcomes from ACT are as of yet unclear, thus ACT membership does not yet fulfill this requirement
5No0
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3.2.2 Commitment to Remediation: Companies are responsible for rectifying and remediating issues, both which arise as a result of their actions and those which they did not directly contribute to. Remediation prioritises the needs of those harmed. 3.2.2.i) Does the company publicly commit to address concerns and grievances in a manner that prioritizes the human rights of supplier factory workers?This means that (2 pts):

-Where the company caused or contributed to the harm, it commits to resolve and addresses the root cause of the grievance
-In instances where its actions did not cause or contribute to the harm, the company commits to support remediation proportionate to the scale and significance of the impact before terminating the contract
22Yes2https://www.inditex.com/documents/10279/643554/Ethics+Line+Procedure.pdf/e5926530-dca2-65c2-c004-5bc4ddeb4f81
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3.2.3 Responsible Exits: The impact of buyer exits on the supplier and workers are considered and integrated into the supplier contract at the outset.3.2.3.i) Does the company publicly commit to responsible exits and works to honor contracts without delays in payments and discounts at all times, including during the pandemic or other unforeseen disruptions?This means that (4 pts):

-Force majeure clauses are not used to refuse payment on completed or in-process goods
- If brand cancelled orders during pandemic, they corrected actions within a short amount of time.
-Exits must involve negotiations with suppliers and implemented with a commitment to mitigate any adverse human rights harms
-The company ensures that when terminating a contract with a supplier/ factory, paying out workers' wages, severance and other benefits is first priority
-All products and materials are paid for at time of exit, whether completed or in-process

Company gets 1 point if it does not explicitly have a Responsible Exit policy but it acted responsibly towards its suppliers during the Covid-19 pandemic.
44Yes1https://payupfashion.com/project/zara-inditex/
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3.3 SPOTLIGHT ISSUE: BRAND BEHAVIOR DURING THE PANDEMIC3.3.1 #PayUp: When retail stores were shuttered and fashion sales were in freefall as a result of the Covid-19 pandemic, countless fashion brands and companies cancelled orders and refused to pay for an estimated $40 billion worth of finished goods, triggering mass layoffs without pay. Some brands honored commitments to suppliers, staving off the worst effects of these decisions. Others did not.3.3.1.i) Did the company deploy abusive commercial practices and shift the financial burden of the Covid-19 pandemic on to the most vulnerable individuals in its supply chain?-Company cancelled in-process or completed orders due to the pandemic OR
-Company refused to pay for orders, in-process or completed, due to the pandemic OR
-Company asked suppliers for discounts on orders or delays in payment due to the pandemic.
BONUS
MINUS 5 POINTS IF DID NOT PAY UP - NO POINTS IF DID PAY UP
BONUS
MINUS 5 POINTS IF DID NOT PAY UP - NO POINTS IF DID PAY UP
No-https://payupfashion.com/project/zara-inditex/
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4. Raw Materials:
The extent to which a company strives to use (and convert to) raw materials that are more sustainable and improve the lives of the growers and makers and animals in the supply chain.
4.1 Raw Materials Producers' Human Rights: Use of raw materials that are produced with assurance that growers and producers have their basic human and labor rights respected. 4.1.1 Raw Materials Producers: Raw Materials used were produced with respect for human rights (and investments in well-being / livelihoods of growers and their communities). 4.1.1.i) Does the company publicly commit to actively protecting the labor / human rights (and/or well-being) of raw material producers (through its own programs, multi-stakeholder initiatives, or certifications), ensuring that >50% of raw material is produced under such conditions, with a time-bound target to reach 100%?This means that (5 pts):

-Company can prove how its practices have a positive social impact on the communities where it sources its raw materials from
-Year-on-year data shows that the company is on track to meet its targets
-If relevant, company addresses Uyghur forced labor
55No0Workers at the Centre program, but unclear how many raw materials suppliers this initiative covered, nor are the outcomes of the program's impact on the lives of RM workers.p 370 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
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4.2 Raw Materials Environmental Sustainability: Use of raw materials that are more environmentally sustainable (e.g. inputs required, land conversion, soil health impact, deforestation, etc.) than conventional materials.4.2.1 Biogenic Materials: Materials made of or from life-forms (includes Manmade Cellulosic Fibers).4.2.1.i) Does the company ensure that >50% of biogenic materials sources are net positive (protects biodiversity, restores and regenerates land and ecosystems, avoids all land conversion to agriculture) for the environment by 2025, with a time-bound target to reach 100%?This means that, for example (4 pts):

-Year-on-year data shows that the % of regenerative agricultural materials used is increasing
-Year-on-year data shows that the % of recycled biogenic materials used is increasing
-Company can demonstrate through certifications that virgin MMCFs are sourced from responsibly managed forests
-Year-on-year data shows that company is on track to meet its net positive goals

44No0Self-certified "sustainable" materials...https://www.inditex.com/en/our-commitment-to-the-environment/closing-the-loop/sustainable-materials
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4.2.2 Non-biogenic Materials: Materials that are not made of or from life-forms.4.2.2.i) Does the company have a time-bound target to reduce all virgin polyester and virgin oil-derived synthetic materials in its value chain to the lowest feasible amounts?This means that (2 pts):

-Year-on-year data shows that % of virgin polyester and oil-derived materials is decreasing
-Data shows that company is on track to meet its virgin oil-derived materials reduction targets
62No0Unclear whether or not the amount of virgin polyester sourced by the company is decreasing.p 52 and p 324 + https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/en/our-commitment-to-the-environment/closing-the-loop/sustainable-materials
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4.2.2.ii) Does the company have a time-bound target to ensure that the highest feasible amount of non-biogenic materials used in its products are recycled and that these materials are sourced responsibly?This means that, for example (4 pts):

-Year-on-year data shows that the ratio of recycled oil-derived materials to virgin oil-derived materials used is increasing OR that company is on track to reduce its use of oil-derived materials to the lowest feasible amount
-Company discloses where it sources its post-consumer PET, fishing nets etc.
-Company prioritizes sourcing from local waste-management systems rather than outsourcing collection of plastic waste for fabric production to developing countries
-Year on year data shows that the company is on track to phase out materials for which there is not currently fiber-to-fiber recycling technology within five years
4No0Goal to have all polyester be recycled polyester by 2025. While Inditex discloses that the amount (mass) of recycled polyester used is increasing, the ratio of recycled to virgin polyester is not given, thus it is unclear on exactly where the company is in terms of its progression towards this goal. p 326 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/en/our-commitment-to-the-environment/closing-the-loop/sustainable-materials
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4.3 Raw Materials and Animal Welfare 4.3.1 Animal Welfare: Welfare is respected in use of animal-sourced materials.
4.3.1.i) Does the company have a public commitment to guarantee the welfare of the animals in its value chain (that applies to materials derived from animals)? 1. Company's animal welfare practices reflect an animal welfare policy that is dated and revised at least every three years (1 pt)
2. The policy recognise/references the overarching requirements for animal welfare (1 pt)
i.e. The Five Freedoms or The Five Domains/Five Provisions
3. The policy recognise major species-specific animal welfare challenges (1 pt)
4. The company has a clearly defined policy against the use of furs and exotic skins (1 pt)
5. The policy includes clear, measurable targets for improvement, and year-on-year data shows company is on track to meet these targets (1 pt):
- volume of traceable product
- volume of certified products (material specific and
certification specification)

If the product was NOT made with animal-sourced materials, answer N/A here
55Yes41, 2, 3, 4.https://www.inditex.com/our-commitment-to-the-environment/closing-the-loop/sustainable-materials/animal-welfare
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5. Environmental Justice:
The intersection of both social justice and environmentalism, where the inequity in environmental degradation is also considered. The extent to which the company is taking action to eliminate the adverse social and environmental effects of its products and operations, particularly in the communities where its sourcing and manufacturing processes are having the most negative impact.
5.1 Commitment to Intersectional Environmentalism5.1.1 Intersectional Environmentalism: Company has commitment, plan, and resources dedicated to assess and reduce environmental impact, especially in communities most adversly affected - both by its operations and the climate crisis more generally.5.1.1.i) Does the company demonstrate a commitment to intersectional environmental sustainability (through environmental sustainability policies, goals, collections etc., especially in the geographical locations that are being most impacted by the climate crisis or where the company itself has an environmental impact)? This means that (2 pts):

-The company demonstrates its understanding of the relationship between social and environmental impacts
-There is language on the website about commitment to intersectional environmentalism and goals - particularly in the global South/ regions where the company is sourcing and manufacturing.
-Red flag: does the company have lawsuits against it by communities over environmental justice?
22No0
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5.2 Climate Change + Energy: Reducing greenhouse gas emissions from production.5.2.1 GHG Emissions Measurement & Disclosure: Company measures and discloses greenhouse gas emissions associated with manufacturing its products.5.2.1.i) Does the company publicly disclose CO2 emissions across its value chain? -CO2 emissions at product level from manufacturing stage only; company discloses aggregate Scope 3 emissions (1 pt)11Yes1p 320 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/en/our-commitment-to-the-environment/climate-change-and-energy
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5.2.2 GHG Emissions Reduction: Company is taking action to reduce GHG emissions from the manufacturing of its products.5.2.2.i) Does the company have absolute, time-bound science-based targets to reduce its GHG emissions across its entire value chain, that are in line with the 1.5 degree pathway? This means that (3 pts):

-Company is pursuing at least a 45% reduction in net C02 emissions by 2030 compared to 2020 levels
-Company is pursuing net-zero emissions by 2050
-Year-on-year emmissions data shows that company is directly reducing its emissions every year and is on track to meet its targets

WHAT DOESN'T COUNT: Carbon-offsetting
73No0Inditex has set ambitious SBTs for GHG emissions reduction. However, while its Scope 1 and 2 emissions reduction targets are in line with the 1.5 degree celsius pathway (which means we would avoid the worst effects of climate change), Inditex's Scope 3 goals only seek to align with the 2 degree celsius pathway.

We believe that the company's Scope 3 SBTs need to more ambitious. Unclear if the company is even on track to meet the Scope 3 targets it does have in place.

p 288 and p 294-295 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/en/our-commitment-to-the-environment/climate-change-and-energy
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5.2.2ii). Does the company provide financial incentives to suppliers implementing low carbon processes?Could be in the form of (2 pts):
-Better prices
-Preferred Supplier Status
-Extension of Credit
-Better contract terms
2No0Cannot find evidence of this.https://www.inditex.com/documents/10279/242114/Inditex+Global+Energy+Strategy/606a5ac4-1381-4672-9ad0-a192032479a2

https://www.inditex.com/en/our-commitment-to-the-environment/climate-change-and-energy
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5.2.2.iii) Does the company invest in eliminating negative health impacts of pollution along its value chain?-The company can demonstrate that it is working to improve the health of both human beings and ecosystems along its value chain, as it relates to emissions pollution (2 pts)2No0Cannot find evidence of projects relating directing to company's own value chain.
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5.3 Water Stewardship: Contributing to sustainability of water resources.5.3.1 Water Stewardship Disclosure: Company discloses its water footprint and water stewardship strategy associated with manufacturing its products.5.3.1.i) Does the company publicly disclose its water footprint and water risks throughout the value chain?-All the way up to raw material and animal by-product (cotton, leather etc.) (1 pt)11No0These figures appear to be for the company's own operations only.p 305 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
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5.3.2 Sustainable Water Management: Company is taking action to responsibly and sustainably source water used in its products.5.3.2.i) Does the company have time-bound targets to ensure that water is sustainably managed on a local level by 2030?This means that (3 pts):

-Targets focus on water-stressed areas
-Targets are context-based; taking into account local ecological limits
-Year-on-year data shows the company is on track to meet its water stewardship targets
53No0"As a new objective, Inditex aims to cut by 25% the water used on the whole supply chain by 2025."

Unclear how the company is progressing towards this goal at present.
https://www.inditex.com/en/article?articleId=670453&title=Pablo+Isla+underscores+%E2%80%9Cthe+strength+of+Inditex%E2%80%99s++integrated%2C+digital+and+sustainable+model%2C++thanks+to+the+work+and+commitment+of+every+employee%E2%80%9D
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5.3.2.ii) Does the company invest in local programs and provide financial inventives to farmers and suppliers to implement water-efficient technologies and processes?-Company is invseting in local programs and providing financial incentives to suppliers to increase water efficiency/use-reduction (2 pts)

Could be in the form of:
-Better prices
-Preferred Supplier Status
-Extension of Credit
-Better contract terms
2No0Unclear.
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5.3.3 Water Quality: Company is avoiding the discharge of hazardous chemicals from manufacturing.5.3.3.i) Does the company publicly publish their wastewater guidelines and test results which are in line with ZDHC wastewater guidelines?-Test results show year-on-year reduction in water pollution
(2 pts)
22No0In 2020, 75% of the suppliers and 86% of the factories under the scope of Inditex's Green to Wear environmental standard, meet the Foundational level of ZDHC in its direct discharges. Also, in line with its commitment to ZDHC, 75% of suppliers and 86% of factories comply with ZDHC limits applicable to the substances included in ZDHC Wastewater Guidelines v.1.1 in its direct and indirect discharges.

Cannot find year-on-year data.
p 572 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/our-commitment-to-the-environment/water
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5.4 Health + Environmental Hazards: Avoiding chemicals and manufacturing processes that are harmful to human health and the environment.5.4.1 Avoidance / Ban of Hazardous Chemicals: Company avoids the use of hazardous chemicals.5.4.1.i) Does the company have time-bound targets to eventually eliminate the use of hazardous chemicals throughout the entirety of its supply chain?1. Publicly shared metrics show a reduction in hazardous chemicals year-on-year (that applies to all suppliers) (1 pt)
2. The company uses and enforces a Manufacturing Restricted Substances List (MRSL) that is equivalent to or more stringent than the ZDHC MRSL, and this MRSL is updated regularly (1 pt)
3. The company also discloses a list of chemicals that ARE used along the value chain (1 pt)
63Yes12. MRSLp 331 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/documents/10279/241804/Green+to+wear+supporting+documents.pdf/9ac0a3cf-1bc6-8aa0-ef3f-523f31ab3264
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5.4.1.ii) Is the company actively working to reduce chemical pollution in garment supply chains more generally?This meanst that (1 pt):

-Company is supporting suppliers to implement new technologies that reduce chemical usage OR
-Company is involved in R&D to develop cleaner, safer chemistry and less-chemical intensive processes
1Yes1p 7 https://www.inditex.com/documents/10279/241820/Global+Water+Management+Strategy_Inditex.pdf/a128125c-4874-47cf-beab-7e65385b923e

p 331 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/documents/10279/241804/Green+to+wear+supporting+documents.pdf/9ac0a3cf-1bc6-8aa0-ef3f-523f31ab3264
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5.4.1.iii) Does the company seek to eliminate negative health impacts of chemical pollution along its value chain?-The company can demonstrate that it is working to improve the health of both human beings and ecosystems along its value chain, as it relates to the impacts of chemical pollution (2 pts)2No0
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5.5 Product Life Cycle Stewardship: Taking responsibility for the product and its social and environmental impact throughout the upstream and downstream value chain. 5.5.1 Product Design: The company prioritizes decreasing product output, increasing product quality and reducing enviornmental impact right from product inception.5.5.1.i) Does the company have a time-bound target to eliminate both pre- and post-consumer textile waste to landfill through innovative design techniques?1. Year-on-year data shows that the amount of textile waste throughout the product manufacturing process is decreasing
(1 pt)
2. Data shows that the company is on track to meet its textile waste elimination targets (1 pt)
82No0No substantive evidence that company is out-designing textile waste. Rather company appears to have initiatives to deal with textile waste once it has already come into existence.p 270

https://www.inditex.com/en/our-commitment-to-the-environment/closing-the-loop
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5.5.1.ii) Does the company prioritize creating durable, high-quality products, made to last, over more low-quality garments?1. The % of the company's products that are designed for ease of mainentance and repair is increasing year-on-year (1 pt)
2. Year-on-year data shows that discard rate of company's products is decreasing (1 pt)
2No0No evidence of this.
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5.5.1.iii) Does the company design for minimal environmental impact (minimal energy, water, material use) during product's "use phase"?1. Year-on-year data shows that an increasing % of the company's materials and products are designed in such a way that minimises shed of synthetic microfibers during washing
(1 pt)
2. Year-on-year data shows that an increasing % of the company's materials and products are designed such that minimal washing, or only less environmentally impactful washing methods are required (1 pt)
2No0R&D stage.p 268 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
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5.5.1.iiii) Does the company design with the post-consumer phase in mind?Products are designed with recycling ease in mind:

1. As blended fibers are still challenging to recycle, brand shows that year-on-year % of mono-material garments is increasing (1 pt)
2. Year-on-year data shows that % of products designed for ease of dissassembly is increasing (1 pt)
2No0"In 2020, we conducted scheduled training to ensure that our designers have been trained in the Principles of the Circular Economy, in line with the commitment we made to the Global Fashion Agenda."

Part of sustainability roadmap. No substantive evidence of progress or current implementations.
p 264, p 269 and p 324 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
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5.5.2 Product Life Extension: The company is prioritizing implementation of repair, rental, or resale initiatives above the production of new garments5.5.2.i) Does the company provide repair and upcycling services AND does it provide incentives to encourage consumers to prioritize use of these services over purchasing new products?1. Company discloses % of brick-and-mortar stores in which these services are available (1 pt)
2. Company can prove that it is increasing consumer accessibility to its repair and upcycling services (2 pts)
3. Company can prove that it is increasing consumer awareness about these services AND that it is incentivizing use of them (1 pt)
74No0
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5.5.2.ii) Does the company have rental initiatives to increase product lifespan and reduce reliance on the production and consumption of new garments?This means that (1 pt):

-For garments that tend to have shorter consumer phases (i.e. baby and children's clothing, maternity wear, occasion wear, work wear) company prioritizes rental over new production and consumption AND
-Company has initiatives in place to reduce carbon and energy impacts of rental:
- Company prioritizes renting and shipping locally/
regionally
- Company uses brick-and-mortar stores
- Company actively educates consumers about more
sustainable rental behaviour, i.e. longer renting periods
vs one-time wears and sending clothes back and forth
1No0
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5.5.2.iii) Does the company have resale initiatives to increase product lifespan and reduce reliance on the production and consumption of new garments?This means that (1 pt):

-Company is transparent about its resale initiatives, including where clothes that aren't resold end up (exported, sold to shredding companies, etc.)
-Resale stock is pre-owned and not unsold products
-Company prioritizes the resale of its own products
-Garment makers and supply chain workers financially benefit from the resale of company's own products
1No0https://www.inditex.com/en/our-commitment-to-the-environment/closing-the-loop/collect-reuse-recycle
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5.5.2.iiii) Does the company acknowledge that circularity must be used to replace linear production, not merely run parallel to the production of new goods?-Company is transparent about its circularity commitments and how they plan to replace their linear business model with circular business models (1 pt)1No0No evidence that company is displacing virgin production with use-phase extending circularity initiatives.p 262-281 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
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5.5.3 Post-Consumer Phase: The company takes full responsibility for its downstream value chain.5.5.3.ii) Is the company transparent about what happens to garments once they have been collected via take-back schemes? Company publicly discloses (1 pt):

-quantity of items collected via takeback scheme annually
-quantity or % of items recycled
-quantity or % of items exported for resale in a secondhand
market in the global south
-quantity or % of items sent to landfill
-quantity or % of items incinerated
21No0Company discloses how many tons of clothing is collected through take back schemes and provides some information about who it collaborates with to deal with the garments, but it does not dibulge enough information about WHERE this clothing is donated to or HOW it is recycled, or WHAT it is recycled into.p 20 and 275 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/en/our-commitment-to-the-environment/closing-the-loop/collect-reuse-recycle
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5.5.3.iii) Is the company transparent about both its non-profit and for-profit clothing donation programs?This means that (1 pt):

-Company publicly discloses its takeback partners and whether they are non-profit or for-profit
-Company publicly discloses quantities of clothing sent to each country
-Company makes consumers aware of this data (i.e. company does not greenwash its takeback schemes)
-Company is transparent about its use of profits from resale
1No0https://www.inditex.com/our-commitment-to-the-environment/closing-the-loop
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5.5.4 Packaging: Company is reducing the environmental impact of its packaging.5.5.4.i) Does the company have time-bound targets to reduce the amount of packaging sent to landfill AND to source packaging raw materials sustainably/responsibly?This means that (1 pt):

-Year-on-year data shows that the amount of packaging produced is decreasing
-Year-on-year data shows that company is on track to eliminate virgin plastics in its packagaing
-Year-on-year data shows that % of fiber-to-fiber recycled and recyclable packaging is increasing
-Year-on-year data shows that company is on track to eliminate packaging raw materials sourced from endangered forests
11Yes1p 272-273 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/our-commitment-to-the-environment/closing-the-loop/collect-reuse-recycle
52
6. Governance:
The company's corporate strategy and commitment to retaining, and investing in, employees (supportive of unions, living wages and DEI at the corporate and retail levels).
6.1 Growth: Business strategy acknowledges that the pursuit of exponential growth of material goods, which ultimately outstrips all environmental sustainability efforts, is incompatible with the 1.5 degree pathway.6.1.1 Growth and Production: Company's financial philosophy and production trajectory takes into account the climate crisis and finite planetary boundaries.6.1.1.i) Does the company publicly disclose how many items it produces every year?-The company discloses the actual number of garments, not, for example, the total mass of the garments produced annually (1 pt) 71No0450 146 tonnes in 2020. We are looking for an actual number of garments not the mass so Inditex does not get points here.p 212 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
53
6.1.1.ii) Does the company recognize that the pursuit of exponential growth of products, virgin resources and energy is incompatible with the 1.5 degree pathway?This means that (3 pts):

-Given the climate crisis and our finite planetary boundaries, the company needs to demonstrate that it's producing fewer new products year-over-year (not relevant to small businesses)
-For companies of all sizes: The company demonstrates that it recognizes that limits come with opportunities
3No0
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6.1.1.iii) Does the company have a time-bound strategy in place to move away from a linear growth model? This means that (3 pts):

-For companies of all sizes: the company has identified, and begun to pursue, ways to make revenue in sustainable and resilient ways
-The company does not have plans to increase its virgin product offering or the number of brick-and-mortar stores (not relevant to small businesses)
-Year-on-year data shows that the company is on track to reduce its overall environmental impacts, a.k.a its net impact
3No0Company is not taking steps to transition to a truly circular business model.
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6.1.2 Changing Business Models and Just Transitions: Company is rethinking its business models while considering the wages and employment of the workers along its value chains.6.1.2.i) Does the company place the well-being of its employees and the workers along its value chains at the center of its business model transition plans?This means that (2 pts):

-The company prioritizes the needs and voices of employees and factory workers in its business model transition plans
-The company has a responsible transition plan including paying living wages and a humane pace of production
22No0Company is not taking steps to transition to a truly circular business model.
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6.2 Diversity, Equity and Inclusion:
The company takes a "top down and bottom up" approach to investing in historically marginalized communities.
6.2.1 Hiring Policies: The company's hiring policies take into account regional histories and recognize that traditional methodologies may be limiting.6.2.1.i) Is the company investing in the communities where it operates in terms of its hiring practices, taking into account class, gender and race? -The company is building relationships with local communities and HBCUs to create career pipelines and opportunities for historically marginalized communities? (2 pts)42No0More information needed on what kinds of jobs people are hired into after completing the Salta program.p 402 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
57
6.2.1.ii) Do the company's job descriptions and requirements take into account local/ regional history? -The company recognizes that a pool of uniquely qualified candidates may not meet the criteria usually sought out in traditional job descriptions (2 pts)2No0
58
6.2.1.iii) Does the company's board and leadership reflect the region's population? -The demographic of the company's board/ leadership team is reflectIve of that of the region (4 pts)

WHAT DOESN'T COUNT: Tokensim
44No0169 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/en/about-us/our-board
59
6.2.2 Retaining and Investing In Employees: DEI goes beyond "box-ticking" - the company is invested in setting all of its employees up for success throughout their career trajectories.6.2.2.i) Does the company provide all of its direct employees with a living wage?1. The company publicly discloses the percentage of direct employees receiving living wages (1 pts)
2. Company is transparent about living wage benchmark it uses i.e. MIT Living Wage Calculator (1 pts)
3. Publicly disclosed year-on-year wage data shows that the company is on track to provide 100% of direct employees with a living wage (2 pts)
104No0Not clear whether or not these constitute as a LIVING WAGE.p 185 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
60
6.2.2.ii) Does the company actively support and promote the participation of its direct employees in trade unions and other collective bargaining associations? 1. Does the company disclose what % of direct employees are covered by collective bargaining agreements, with goals to increase? (1 pt)
2. Company uses its corporate power to advocate for union capacity building in environments where FOA is constrained (1 pt)
2Yes1No. 2https://www.inditex.com/en/our-commitment-to-people/our-employees/equality-diversity and https://www.inditex.com/en/article?articleId=638481&title=Inditex+and+UNI+Global+Union+celebrate+the+tenth+anniversary+of+their+Global+Framework+Agreement
61
6.2.2.iii) Does the company have the infrastructure in place to be able to welcome and retain employees from diverse backgrounds?The company incentivizes employees, removes hurdles and sets them up for success (4 pts):
-paid a living wage and can demonstrate year-over-year improvements on wages that keep pace with the cost of living
-investment in employee education
-job training
-travel stipend
-mutual aid
-employees have the right to unionize and their collective bargaining rights are protected
-employees can air and escalate grievances without fear of retaliation/ retribution
4No0This is not made explicitly clear.p 176 onwards:
https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab

https://www.inditex.com/en/our-commitment-to-people/our-employees/equality-diversity
62
6.2.3 Investment in BIPOC and Marginalized Communities:6.2.3.ii) Does the company invest in the same communities it extracts value from? This means that (3 pts):

-Company reinvests the profits it extracts from marginalized communities back into those communities
-Company does not exploit, wokewash or co-opt movements and cultures for profit

DOES NOT COUNT: selling product, merch around BLM, Pride etc. simply because it is trending
33Yes3p 382 - 415 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
63
6.3. Corporate Strategy and Environmental Justice6.3.1 Corporate Strategy: The company's long term policies and frameworks center around social and environmental justice.6.3.1.i) Does the company have an overall environmental justice strategy to address community impacts where their biggest supply chain footprint is?This means that (2 pts):

-There is a board level policy in place
-A system exists by which to consult stakeholder communities
-There are investments to address impacts
22Yes2https://www.inditex.com/en/corporate-ethics
64
6.3.2 Board and Executive-Level KPIs and Remuneration: Environmental Justice is embedded in KPIs6.3.2.i) Does the company link the compensation of its executives and key teams to the achievement of publicly disclosed social and environmental targets along its value chain? This means that (4 pts):

-There is board/leadership-level accountability for human and environmental rights in the supply chain
-Compensation of C-suite, Buying teams etc. is tied to the meeting of social and environmental targets
-Performance targets are made public
44Yes4"Payment of variable remuneration at Inditex, both annual and multi-year, is tied to the achievement of sustainability objectives (environmental, social and corporate governance-related). These objectives are aligned with the Group’s sustainable strategy, wherein all stakeholders are considered, and allows rewarding its implementation. Namely, in the financial year 2021 the weight of sustainability objectives on aggregate variable remuneration is 15%, at least."p 10 https://www.inditex.com/documents/10279/284661/INDITEX+IAR+2020_EN.pdf/28b599f7-794f-91b0-d487-62a58893f04b

p 50 and 320 https://www.inditex.com/documents/10279/664163/2020+Inditex+Annual+Report.pdf/cb184fcc-d1d5-a691-1ee3-8e46871615ab
65
6.4 Worker-Driven Advocacy + Enforceable Agreements: The company recognizes that brand-driven voluntary efforts and unenforceable agreements and codes of conduct have been ineffective in reforming the fashion industry and empowering garment workers. The company will work to adopt binding contractual agreements and legislation that centers people and planet over profit.6.4.1 Give Workers Center Stage: Garment maker representation must extend to the governance structures of brand-funded multi-stakeholder initiatives and major conferences and events that shape the ethical and sustainable fashion agenda.6.4.1.i) Does the company ensure representation of women garment worker voices in its conversations about worker's rights?-When the company hosts any kind of public-facing event on its ethics or supply chain performance, including webinars and IG Lives or attending major conferences, it includes garment workers from its own supply chain in those discussions (2 pts)22No0
66
6.4.2 Sign Enforceable Contracts and Help Pass Laws: Brands must commit to worker-driven binding agreements and support legal reforms that hold companies accountable for preserving human and labor rights in their supply chains.6.4.2.i) SPOTLIGHT ISSUE: Has the company signed the International Accord, the extended and expanded Accord on Fire and Building Safety in Bangladesh?-Was the brand an initial signatory to the 2013 Accord, did the brand resign?
-If the brand sources from Bangladesh but was not a part of the original Accord, has it signed onto the new agreement?
BONUS
MINUS 5 POINTS IF ANSWERED NO TO EITHER OF THESE QUESTIONS
BONUS
MINUS 5 POINTS IF ANSWERED NO TO EITHER OF THESE QUESTIONS
Yes-https://payupfashion.com/project/zara-inditex/
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6.4.2.ii) Does the company support brand accountablity for garment makers in legislation and private regulatory schemes, such as bans?This means that (4 pts):

-The company does not lobby against, or pay dues to, industry groups that advocate against labor and human rights regulations that hold brands accountable to their supply chain
-The company endorses national and international labor and human rights policies/ regulations that hold brands accountable for their supply chains
- Endorsed SB62
- Endorses Mandatory Human Rights Due Diligence
- Endorses End Uyghur Forced Labor Call to Action
44No0Caving to pressure from the Chinese government, ZARA deleted a statement on its condemning the use of forced labor in the XInjiang Province.

Endorses MHRDD in the EU.
https://qz.com/1988896/under-pressure-in-china-zara-deleted-a-statement-about-xinjiang/

https://www.business-humanrights.org/en/latest-news/list-of-large-businesses-associations-investors-with-public-statements-endorsements-in-support-of-mandatory-due-diligence-regulation/
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6.4.2.iii) SPOTLIGHT ISSUE: Did the company oppose SB62, the California Garment Worker Protection Act?For brands that produce in California OR are on the board or a member of an industry association that lobbied against SB62 (including the American Apparel and Footwear Association, the California Retailers Association or the California Chamber of Commerce):

-Prior to it being signed into law, did the company fail to support, or did it publicy oppose the Bill?
BONUS
MINUS 5 POINTS IF ANSWERED YES TO THIS QUESTION
BONUS
MINUS 5 POINTS IF ANSWERED YES TO THIS QUESTION
N/A-
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TOTAL POINTS15015024
70
1.Traceability80
71
2. Wages & Well-being233
72
Labor Standards73
73
Fair Wages and Social Programs140
74
Grievance Mechanisms20
75
3. Commercial Practices153
76
Public Commitment10
77
Due Diligence-Aligned Buyer-Supplier Agreements143
78
PayUp00
79
4. Raw Materials 204
80
Producers' Human Rights50
81
Environmental Sustainability100
82
Animal Rights54
83
5. Environmental Justice424
84
Committment to Intersectional Environmentalism20
85
Climate Change and Energy81
86
Water Stewardship80
87
Health and Environmental Hazards62
88
Product Life-Cycle Stewardship181
89
6. Governance4210
90
Growth90
91
Diversity, Equity and Inclusion214
92
Corporate Strategy and Environmental Justice66
93
Worker-Driven Advocacy and Enforceable Agreements60
94
95
96
97
98
99
100