Disclosures
In compliance with the regulations of the California Transparency in Supply Chains Act (SB 657), the United Kingdom (UK) Modern Slavery Act of 2015, the Australian Modern Slavery Act of 2018, and the Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act, the following (“Report”) discloses the policies and actions of Fruit of the Loom affiliated companies, including Fruit of the Loom, Inc.; Union Underwear Company, Inc. d/b/a Fruit of the Loom; Fruit of the Loom, Ltd.; Russell Corporation Australia Pty. Ltd.; Fruit of the Loom Canada, Inc.; Vanity Fair Brands, LP; and Russell Brands, LLC (collectively, “Fruit of the Loom,” “we,” or “our”) relating to “Modern Slavery” (as defined below) and “child labor” (as defined below) in our global supply chain (that is, exclusive of licensees). In order to prepare this joint Report, we engaged with each of the foregoing entities covered by this Report, and consulted the entities we own or control.
Through our Code of Conduct, Code of Conduct Benchmarks, and Supplier Guidelines (as further detailed below), Fruit of the Loom prohibits Modern Slavery in its supply chain. We define “Modern Slavery” broadly to include any form of servitude, forced or compulsory labor, and human trafficking. We define human trafficking as an act of recruiting, transporting, transferring, harboring, or receiving a person through the use of force, coercion, or other means, for the purpose of exploitation. We prohibit the employment of individuals in violation of the local mandatory school age or under the applicable legal employment age (“child labor”).
1. Fruit of the Loom is a commercial manufacturer doing business in California, Australia, Canada, and the UK. Fruit of the Loom provides a good or service, brings in annual, worldwide, "gross receipts" that exceed $100M US, $100M AUD, $40M CAN, and has an annual turnover that exceeds £36M.
Fruit of the Loom is classified as a private entity in all jurisdictions in which it operates. Fruit of the Loom does business in the apparel and sporting goods industries, manufacturing, marketing, and selling underwear, intimate apparel, activewear, and sporting goods.
Our supply chain is comprised of 85+ factories, located in 19 countries around the world, supplied by a global network of materials suppliers (primarily located in the U.S., Honduras, El Salvador, Morocco, and Vietnam). The bulk of our supply chain is located in the U.S., Honduras, El Salvador, Morocco, and Vietnam. In turn, we sell in multiple countries, with our primary markets being North America, China, Europe, and Australia.
2. Fruit of the Loom conducts regular risk assessments of our supply chain, considering all subsidiaries and other entities Fruit of the Loom owns or controls. Our risk assessment is conducted by an internal team comprised of members from our Internal Audit, Legal, Finance, and Operations departments. Specifically with respect to Modern Slavery and child labor, we evaluate all parts of our supply chain and allocate resources and mitigation efforts to the areas of greatest risk.
We contractually require our Tier 1 suppliers to comply with our company standards to prevent Modern Slavery and child labor in our supply chains. We also conduct audits of Tier 1 suppliers to evaluate compliance with our company standards to prevent Modern Slavery and child labor in our supply chains. Our audits are semi-announced and are performed by a qualified third party.
We utilize intelligence from a wide variety of sources, including the U.S. government (U.S. Department of Labor reports), the Social Responsibility Committee of the American Apparel & Footwear Association (AAFA), press reports, and advocacy groups that focus on human trafficking.
Fruit of the Loom is a signatory to the AAFA/FLA Commitment to Responsible Recruitment. Additionally, we are a Tier 3 member of the Customs Trade Partnership Against Terrorism (“CTPAT”) program, and also a CTPAT Trade Compliance member, in our supplier facilities, to determine the areas of highest risk in our supply chain
Fruit of the Loom identified actual findings of Modern Slavery in Taiwan and Malaysia at the Tier 1 level a number of years ago, as has been previously reported in the Reports for other countries in prior years. Those matters were remedied to our satisfaction and there have been no further findings since then.
Fruit of the Loom identified actual findings of child labor in China at the Tier 1 level. We documented 6 child labor findings in China, and 1 in Egypt between 2014 and 2017, but none since 2017. All matters were remedied to our satisfaction.
3. Fruit of the Loom, on behalf of itself and on behalf of all subsidiaries and other entities we own or control, has set forth policies to address and remediate cases of Modern Slavery and child labor in our supply chain. We screen all of our owned facilities for child labor through our regular employment onboarding practices. We have a Code of Conduct, Code of Conduct Benchmarks, and Supplier Guidelines (https://www.fotlinc.com/sustainability/supply-chain/resources-for-suppliers/) we issue to our direct suppliers that state our prohibitions related to Modern Slavery and our policies related to child labor in our supply chain.
Our Code of Conduct states:
- Suppliers will not use forced labor, including, but not limited to, prison labor, indentured or slave labor, or bonded labor. Suppliers will adopt measures to ensure that facilities are not utilized in human trafficking and will monitor their supply chain for such practices.
Our Supplier Guidelines state:
- The Fruit of the Loom Code of Conduct mandates that suppliers monitor their own Supply Chain and adopt measures to ensure that their Facilities, and those Facilities within their Supply Chain, do not engage in Forced Labor or human trafficking practices. In other words, all suppliers, contractors, Subcontractors, licensees, and other designated business partners of Fruit of the Loom must prohibit Forced Labor and human trafficking in their own Supply Chains and provide evidence of compliance efforts upon request.
In furtherance of the above, we periodically send letters to our Tier 1 suppliers informing them of new legal or regulatory requirements, reminding them of their obligations, and requesting acknowledgement.
If evidence of Modern Slavery or prohibited child labor is identified in our supply chain and is not immediately remedied or otherwise appropriately addressed to our satisfaction, we will terminate the business relationship with the offending party. While we wish to aid in the resolution of incidences of Modern Slavery and prohibited child labor within our supply chain, it is not possible to effectively solve the issue of noncompliance without the cooperation of the supplier.
4. Fruit of the Loom has received certification from direct suppliers that materials comply with the slavery, human trafficking, forced labor, and child labor laws of the countries in which they are doing business. Our Supplier and Manufacturing Agreements are countersigned and commit our direct third-party suppliers and manufacturers to adhere to our Code of Conduct and Supplier Guidelines.
5. Fruit of the Loom, on behalf of itself and on behalf of all subsidiaries and other entities it owns or controls, maintains and enforces internal accountability procedures for employees and contractors who fail to meet company standards to prevent the incidence of Modern Slavery and prohibited child labor in its supply chain. Fruit of the Loom practices due diligence in maintaining these standards. Fruit of the Loom employees and employees of contractors have anonymous and confidential channels to report suspicion of slavery, human trafficking, forced labor, and child labor. Fruit of the Loom has a procedure to immediately act to investigate all allegations and work with stakeholders towards remedy.
6. Fruit of the Loom, on behalf of itself and on behalf of all subsidiaries and other entities it owns or controls, has taken action and has followed procedures to remediate the loss of income to the most vulnerable families that results from any measures taken to eliminate the use of forced labor or child labor in its activities and supply chains. For example, Fruit of the Loom has signed on to AAFA/FLA’s Commitment to Responsible Recruitment, which commits us to ensure that workers are reimbursed for all fees paid to obtain their job and has vowed to incorporate these protocols to our company’s social compliance standards. We have followed this commitment in those instances where a finding of child labor existed and our corrective action plan required the reimbursement of recruitment fees.
7. Fruit of the Loom, on behalf of itself and on behalf of all subsidiaries and other entities it owns or controls, conducts internal training on our Code of Conduct to ensure the necessary participants in supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including human trafficking, slavery, and child labor, with a particular focus on mitigating risks. We also encourage employees involved in our supply chain to participate in internal and external training programs and seminars on social compliance issues, human trafficking, slavery, forced labor, and child labor.
8. Fruit of the Loom is dedicated to continuously monitoring and improving the effectiveness of our policies and practices to eliminate any form of Modern Slavery and prohibited child labor in the factories producing goods for our family of brands. We recognize that our review and assessment of our actions to identify and address our risks in our operations and across our supply chain will be an ongoing and evolving process. To this end, we are committed to building upon our progress and will continue to establish goals to improve the effectiveness of our approach and inform our path forward. We have a yearly social compliance risk analysis that includes both the limitations of our controls and the impacts of those limitations. This informs our priorities for continuously improving our controls.
Jeff Cohen
Chairman and Chief Executive Officer
May 2024