California Transparency in Supply Chains Act (SB 657)

Corporate Responsibility California Disclosure Workplace Code of Conduct

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 Carhartt's responses to the five required disclosures outlined in the legislation:

  1. Verification -- All factories producing goods for Carhartt are required to comply with the Company's Workplace Code of Conduct, which includes a specific "prohibition of involuntary, prison, or forced labor - indentured, bonded or otherwise" and a methodology to verify compliance with labor standards. All suppliers also are expected to meet the standards of the US Customs-Trade Partnership Against Terrorism (C-TPAT), including recommended safeguards protecting against the introduction of non-manifested cargo. These expectations extend to all sub-contractors. Verification takes place through third-party assessment of responsible labor conditions, using the Worldwide Responsible Accredited Production (WRAP) protocol, or a similar third-party factory certification approach.
  2. Audit -Responsible labor practices are confirmed through third-party factory assessments, using the Worldwide Responsible Accredited Production (WRAP) social audit protocol, or a similar third-party factory certification approach. Supplier audits are conducted by reputable third-party assessment firms and are unannounced within a 30-day window. These audits evaluate present factory conditions as well as the policies, procedures and management systems which are necessary for ongoing compliance.
  3. Certification-- Carhartt's Workplace Code of Conduct requires all of our suppliers to comply fully with all local laws, including those related to slavery and human trafficking. In the event local laws are not robust, Carhartt's Workplace Code of Conduct further prohibits suppliers from using "involuntary, prison, or forced labor - indentured, bonded or otherwise." Suppliers certify that they understand and comply with these expectations before starting Carhartt production and periodically thereafter.
  4. Internal Accountability-- Responsible labor conditions have been a core value at Carhartt for more than 120 years. 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 and the Licensing Department for all license agreements. All Carhartt contractors and licensees must adhere to our Code and maintain appropriate third-party certifications.

    If an audit demonstrates that a contractor does not comply with Carhartt's Code of Conduct, we take appropriate remedial action. While we prefer to work with contractors to achieve improved conditions, violations involving human trafficking or slavery would be considered "zero tolerance" issues that must be immediately corrected or Carhartt would act to terminate the contractual relationship.
  5. Training-- With support from WRAP, Carhartt 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.