Corporate Responsibility

we know words alone won’t help us build a better world, so here’s how we’re taking action.

When our company was founded in 1889, Hamilton talked about the role of a responsible business in doing, “the just and honest thing, gainful if possible”. These core principles have underpinned approach to business for more than 125 years and are as relevant today as they were in 1889.

Building on our roots as an American company, products are today manufactured and sold globally. Production is centered in company-owned factories in the U.S. and Mexico, and in a network of supplier and licensee factories around the world.

We are keenly aware of the environmental and human rights challenges presented by global sourcing and we have taken a number of important steps to help ensure that our principles are upheld throughout the global network of factories supporting our business. Key steps include:

* Adopting a Workplace Code of Conduct that establishes expectations for all of our supplier and licensee relationships. This Code provides key base line expectations for environmental protection, responsible working conditions, and fundamental human rights. It is based on the Core Conventions of the International Labor Organization and the UN’s Universal Declaration of Human Rights.

* As outlined in our Global Social Responsibility Supplier Manual, all facilities are required to be audited by 3rd party auditing companies under approved programs to ensure compliance to the principles outlined in the Workplace Code of Conduct. The facilities must maintain passing audits for the duration of their relationship.

In addition to the 3rd party audits, Global Social Responsibility team conducts on-site verification assessments of each facility to confirm the facility is fully compliant, and to partner with the facilities on any improvements that may be required to fully comply with the Workplace Code of Conduct.

* In addition to these assessments, sourcing and quality assurance personnel visit and work in supplier facilities on an ongoing basis. These individuals have been trained on responsible workplace conditions and expectations for suppliers. The regular presence of personnel at supplier facilities allows us to closely monitor day-to-day work conditions supplementing the periodic audits by third-parties or assessments by Global Social Responsibility team.

CALIFORNIA DISCLOSURE

Relevant Section of California Transparency in Supply Chains Act of 2010

(1) Every retail seller and manufacturer doing business in this state and having annual worldwide gross receipts that exceed one hundred million dollars ($100,000,000) shall disclose, as set forth in subdivision (c), its efforts to eradicate slavery and human trafficking from its direct supply chain for tangible goods offered for sale.

(c) The disclosure described in subdivision (a) shall, at a minimum, disclose to what extent, if any, that the retail seller or manufacturer does each of the following:

(1) Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.
(2) 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.
(3) 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.
(4) Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
(5) Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

In September of 2010, the state of California enacted legislation requiring all companies doing business in the state to disclose information on the actions being taken to address the risks of human trafficking and slavery in their global supply chains. Shown below are responses to the five required disclosures outlined in the legislation:

Verification – All factories producing goods for are required to comply with the Company’s Workplace Code of Conduct, which includes a specific prohibition of forced labor, which includes involuntary, prison or trafficked labor or labor otherwise obtained by force, fraud or coercion — indentured, bonded or otherwise. These expectations extend to all suppliers. Suppliers are expected to extend these standards to all of their suppliers and to initiate practices to assure that these standards are adopted throughout the global supply network supporting. Verification takes place through a two-pillar approach that involves a combination of 3rd party certification audits (e.g. WRAP, BSCI, Better Work, etc.) and Onsite Verification Assessments from Global Social Responsibility Team. More information on two-pillar approach can be found in Global Social Responsibility Supplier Manual.

Audit – Certification audits are conducted by reputable third-party assessment firms and are typically unannounced within a 15 to 30-day window. These audits evaluate present factory conditions as well as the policies, procedures and management systems that are necessary for ongoing compliance. Onsite Verification Assessments are conducted by Global Social Responsibility team (or contractors hired to act as representatives) and use a combination of announced and unannounced visits. These assessments are used to verify the information in the certification audits, assess the factory’s overall compliance to requirements, and work directly with factories on any needed improvements.

Certification – Workplace Code of Conduct requires all suppliers to comply fully with all local laws, including those related to slavery and human trafficking. In the event local laws are not robust, Workplace Code of Conduct further prohibits suppliers from using “involuntary, prison or trafficked labor or labor otherwise obtained by force, fraud or coercion — indentured, bonded or otherwise.” Suppliers certify that they understand and comply with these expectations before starting production and periodically thereafter.

Internal Accountability – Responsible labor conditions have been a core value at since it was established in 1889. Internal accountability resides with the leadership of the core business functions responsible for the relevant commercial relationships – e.g., the Sourcing function for all relationships with cut and sew suppliers, Product Development with raw material suppliers, and the Licensing Department for all license agreements. All suppliers and licensees must adhere to our Code of Conduct and maintain third-party certifications as outlined in the Global Social Responsibility Supplier Manual.

If any supplier is found to be out of compliance with Code of Conduct, appropriate remedial actions are taken. While we prefer to work with suppliers to achieve improved conditions, violations involving human trafficking or slavery are classified as “zero tolerance” issues that must be immediately corrected with long-term corrective actions implemented (approved and monitored) or would terminate the contractual relationship.

Training – With support from WRAP, we has conducted training on the Company’s Workplace Code of Conduct – including provisions related to human trafficking and slavery. Individuals completing this training include supply chain leadership from the Vice President through the manager level in our Sourcing and Quality Assurance activities. Select individuals in our Customs activity also have completed the training. We are presently in the process of extending the training to others within our organization.

Global Social Responsibility

We is committed to conducting business in a fair and ethical manner. Our Global Social Responsibility Department’s mission is to serve and protect the hardworking people who make our products. Consistent with this mission, we’ve established this Code of Conduct as a minimum set of standards for all suppliers based on internationally accepted labor standards, including the International Labor Organization’s Core Conventions and the Universal Declaration of Human Rights. While our Code of Conduct establishes minimum standards, aspires to partner with companies that share our corporate values and are committed to continuous improvements as it relates to social and environmental practices. Details of our Global Social Responsibility program, including policies, can be found in the Global Social Responsibility Supplier Manual.

GLOBAL FACTORY MAP

Our purpose is to build a better world for all hardworking people. This includes every person working to stitch, sew, and put the finishing touches on our products from inside the facilities located on this map. For this reason, all -owned factories and its partners around the world must be certified to uphold the standards for fair labor practices, safe working conditions, and environmental responsibility.

To ensure the requirements for social compliance are met, every facility is regularly audited, both through an approved third-party social compliance certification program, and by representatives from Social Compliance Team who physically visit every factory. In addition, we created our Workplace Code of Conduct to clearly define the expectations of our factories in order to only work with partners that share our desire to preserve the hardworking way of life and build a cleaner, safer, better world for everyone.

PRODUCT SAFETY AND REGULATORY COMPLIANCE

Product Safety and Regulatory Compliance

We is dedicated to the protection of our consumers. As we continue to expand into the global market, it is more important than ever. By focusing first and foremost on protecting consumers, we are in turn protecting the brand.​

Restricted Substances

We works hard to ensure that our garments are designed and manufactured responsibly, and that any chemicals in our finished goods comply with all applicable laws and regulations.

We uses a Restricted Substance List (“RSL”) as a product specification that all our suppliers must comply with. This list is currently maintained by the Apparel & Footwear International RSL Management Working Group (“AFIRM”) and is a publicly accessible document (AFIRM RSL).

The AFIRM RSL represents current global regulatory chemical compliance limits and goes beyond to include more chemicals and/or stringent limits. It is updated annually to ensure conformance with global consumer protection standards. The mission is to reduce the use and impact of harmful substances in the apparel and footwear supply chains. This list includes any relevant chemicals that are listed under California Proposition 65, Europe’s REACH Regulation, etc. All of products are designed and manufactured to comply with these requirements.