(Revised October 3, 2018)
As a premium brand, Carhartt is committed to conducting business in a fair and ethical manner. Carhartt’s Social Compliance Department’s Mission is To serve and protect the hardworking people who make our products. Consistent with this Mission, Carhartt has established this Code of Conduct as a minimum set of standards for Carhartt suppliers. Carhartt’s Code is based on internationally accepted labor standards, including the International Labor Organization’s Core Conventions and the Universal Declaration of Human Rights. While this Code establishes minimum standards, Carhartt aspires to partner with companies that share Carhartt’s corporate values and are committed to continuous process improvements as it relates to social and environmental practices. Any questions or concerns, or any alleged violations, should be emailed to firstname.lastname@example.org.Scope
As used herein, the term
The consequences of non-compliance by suppliers with the standards outlined in Carhartt’s Code of Conduct may include, but are not limited to, cancellation of existing orders or loss of all future business with Carhartt. Carhartt’s process for approving and ensuring compliance to the Code of Conduct is outlined in Appendix A.Code of Conduct
1. Employment Relationship – Carhartt suppliers will adopt and adhere to the rules and conditions of employment that respect workers and, at a minimum, safeguard their rights under national and international labor and social security laws and regulations.
2. Compliance with Laws and Workplace Regulations – Carhartt suppliers will comply with laws and regulations in all locations where they conduct business including those relating to labor, social insurances/security, worker health and safety, and the environment. It is further expected that suppliers will cooperate fully with Carhartt in its compliance with laws applicable to Carhartt in countries where Carhartt does business. Where local law or standards differ or conflict, the highest standard shall apply.
3. Prohibition of Forced Labor – Carhartt suppliers will not hire any employees under the age of 15, or under the age interfering with compulsory schooling, or under the minimum age established by law, whichever is greater. Supplier must maintain official and verifiable age documentation for each worker.
4. Prohibition of Child Labor – Carhartt suppliers will not hire any employees under the age of 15, or under the age interfering with compulsory schooling, or under the minimum age established by law, whichever is greater. Supplier must maintain official and verifiable age documentation for each worker.
5. Prohibition of Harassment or Abuse – Carhartt suppliers will endeavor to establish workplaces where every employee is treated with respect and dignity. No employee shall be subjected to any physical, sexual, psychological or verbal harassment, abuse, corporal punishment, or monetary fines.
6. Prohibition of Discrimination – Carhartt suppliers will employ, pay, promote, and terminate workers on the basis of their ability to do the job, rather than on the basis of personal characteristics or beliefs. No person shall be subject to any discrimination in employment, including hiring, compensation, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group or ethnic origin.
7. Freedom of Association & Collective Bargaining – Carhartt suppliers shall recognize and respect the right of employees to freedom of association and collective bargaining.
8. Compensation and Benefits – Carhartt suppliers will pay at least the minimum total compensation required by local law, including all mandated wages, allowances, and benefits, as well as required pay for overtime and holiday work. Supplier must maintain adequate and verifiable payroll documentation and each employee must be provided with a clear, written accounting for each pay period.
9. Hours of Work – Carhartt suppliers will conform to hours worked each day, and days worked each week, that do not exceed the legal limitations of the countries in which they operate. At a minimum, Suppliers will provide at least one day (24 hours) off in every seven-day period, except as required to meet urgent business needs. Suppliers are encouraged to control total weekly hours to 60 or less for all employees. All overtime hours must be worked voluntarily.
10. Health and Safety – Carhartt suppliers must ensure that their employees are provided with a safe and healthy work environment, including any housing and cafeteria requirements, and are not subject to hazardous or unsanitary conditions.
11. Multi-Tenant – Carhartt production is prohibited in factories with more than one tenant unless Carhartt’s Multi-Tenant Policy is fully complied with (Appendix B)
12. Sandblasting – Unique challenges exist with working conditions and with worker health and safety in the denim finishing process in laundries and facilities. In view of health concerns related to the use of sandblasting in garment processing, sandblasting processes are not permitted at any facilities that produce Carhartt products.
13. Environmental – Carhartt suppliers will comply with environmental rules, regulations and standards applicable to their operations, and will adopt responsible measures to mitigate negative impacts that the workplace has on the environment. This includes hazardous waste disposal, waste management practices, air emissions, water treatment and other significant environmental risks.
14. Procurement Ethics – Carhartt’s business relationship with its suppliers is based solely on the supplier’s merits in the way of prices, excellent quality, prompt delivery and efficient services. Therefore, no payments, gifts, rewards or gratuities of any kind shall be made directly or indirectly to Carhartt employees or Carhartt’s buying agent or staff members in consideration of the business being placed with supplier.
15. Bribery and Corruption – Carhartt suppliers will not, in connection with any aspect of their business with Carhartt, directly or indirectly give or offer any bribe, kickback or other improper payment or benefit to influence another individual, company, organization, government official or body, or political party or candidate, regardless of whether it is officially tolerated or condoned.
16. Transparency – Honesty and transparency is critical for a relationship with Carhartt. Supplier is required to provide accurate and truthful answers to any questions or documents requested by Carhartt. The use of falsified records, double books or similar documents, or coached/instructed employee interviews can and will result in the disqualification of the Supplier from future business with Carhartt.
17. Subcontracting – Carhartt will not tolerate the unauthorized subcontracting of any or all production operations associated with the manufacture of Carhartt products. Carhartt suppliers must disclose any subcontracted processes prior to production and receive written approval from Carhartt for the use of subcontracted services; including, but not limited to, laundry, screen print, embroidery or other embellishments or processes. Carhartt also specifically prohibits the practice of “Home Work” as a means of producing its product. Subcontractors will be required to meet the same Carhartt Workplace Code of Conduct as primary Carhartt suppliers. Approval is specific to individual subcontractor locations. Any unauthorized subcontracting may result in the immediate cancellation of all open orders or other business relationships between Supplier and Carhartt.
18. Migrant Labor – Any supplier using Migrant Labor is required to adopt the Carhartt Policy on Migrant Labor (Appendix C), or draft their own policy that includes the Carhartt policy requirements as a minimum, no later than March 31, 2019. Any violations found related to migrant workers hired after March 31, 2019 will require the supplier to reimburse all inappropriate fees charged to the migrant worker. The policy includes the following critical requirements, in addition to other guidance.
● All employment contracts and other work related information must be truthful, clearly written and provided in the worker’s native language
● Workers must be provided with contracts and wages that equal or exceed those of local workers per the policy, and must be treated equally in the workplace.
● Workers should not pay any recruitment fees or other related employment fees from country of employment or home country – including transportation to and from the host country per the policy.
● Workers shall retain possession and control of their personal identity documents, such as passports, identity papers, travel documents, and other personal legal documents at all times
19. Animal Welfare – Carhartt believes that every animal deserves to be free from hunger and thirst, discomfort, pain, injury or disease, fear and distress. The belief is that this should last for an animal's entire lifetime, including birth, growth/rearing/breeding, feed/water/shelter, transport and slaughter. No animal used for the production of Carhartt products should be intentionally harmed or exposed to pain. Taking the lives of animals should be conducted using the quickest and the least painful and non-traumatic methods available. Carhartt may request specific information on the Supplier’s supply chain related to the conditions imposed on animals used for certain materials (e.g. down, leather, wool).
20. Source of Cotton Fiber – Due to Uzbekistan and Turkmenistan’s ongoing use of forced labor and child labor in growing and harvesting cotton, Carhartt has joined with many other brands in pledging to not knowingly use Uzbek and/or Turkmen sourced cotton in products. Suppliers are required to ensure that Uzbek and/or Turkmen cotton is excluded from the supply chain. Carhartt will periodically request suppliers to attest that cotton fiber is not Uzbek and/or Turkmen sourced (Appendix D). In some cases, suppliers may not know where cotton is grown and, in those cases, suppliers will be asked to provide information on their sources for fabrics, yarns and threads.
21. Customs Compliance – Carhartt suppliers will comply with applicable customs law and, in particular, will establish and maintain programs to comply with customs laws regarding illegal transshipment of apparel products.
22. Security – Carhartt suppliers will maintain facility security procedures to guard against the introduction of non-manifested cargo into outbound shipments (e.g. drugs, explosives, biohazards, and/or other contraband). Suppliers are further expected to cooperate with Carhartt in meeting C-TPAT and other supply chain security requirements established by U.S. Customs and Border Protection or other governmental security requirements.
23. Right to Audit – Carhartt reserves the right to visit the production or other facilities where Carhartt product is produced or handled at any time. These visits may be conducted by Carhartt employees or by third-party auditors retained by Carhartt. Visits may be announced, semi-announced or unannounced. Any denied access to a facility will be considered a Zero Tolerance violation.
24. Visibility of Carhartt Code of Conduct – A copy of Carhartt’s Workplace Code of Conduct (first 4 pages) must be posted in strategic locations at the supplier’s place of business (i.e. lobby, near time clocks, bulletin board, etc.) so that each member of the supplier’s organization has access to the policy. The policy should be translated into the native languages of all workers and be located so that employees can read and understand Carhartt’s policy. Supplier is to provide Carhartt with a copy of any translation.
As noted in this Code of Conduct, Carhartt aspires to partner with companies that share its corporate values and are committed to continuous improvement of social and environmental practices. It is our intent that the standards outlined in this Workplace Code of Conduct be applied throughout the global network of vendors involved in the development, manufacture and transport of Carhartt products. Vendors with which Carhartt has a direct contractual relationship are expected to extend these standards to all sub-tier suppliers and to initiate practices to assure that aligned standards are adopted throughout the global supply network supporting Carhartt.