The California Transparency in Supply Chains Act which is effective on January 1, 2012, requires companies doing business in California and exceeding a volume threshold, to disclose their efforts to eradicate slavery and human trafficking in its direct supply chain for tangible goods offered for sale.
Kate Spade & Company's Standards of Engagement include the prohibition of forced labor and child labor. Click here for the Company's Standards of Engagement.
The efforts that we have undertaken to verify the absence of forced labor and child labor in our supply chain include the following:
1. Verification - Factories that are added to our sourcing base must pass a human rights factory evaluation performed by our internal audit team, our agents audit team or third party auditors. Existing factories are then audited based on the amount of business with the Company and perceived risk based on previous audit findings and internal risk ratings for the country of manufacture, taking guidance from information provided by the U.S. State Department and U.S. Department of Labor on the topics of forced labor and human trafficking.
2. Supplier Audits - Since 1994, the Company has distributed its Workplace Standards of Engagement to direct suppliers. Direct suppliers are required to post these standards in the workers' native language at their factory sites. Factory audits are conducted using internal and independent monitors. In most cases, unannounced audits are also conducted to evaluate our supplier’s compliance with the Company’s forced labor and child labor standards. For more information on our auditing and monitoring protocols, please refer to the "Auditing and Monitoring" section on our website.
3. Certification - The Company's Supplier Agreements require suppliers to comply with applicable laws within the country of manufacture which includes laws on slavery and human trafficking. To highlight the concern for forced labor and human trafficking, the Company has sent to its direct finished goods suppliers educational information along with an affidavit for suppliers to attest that they will 1) review the laws related to the topic for all jurisdictions where our product are manufactured 2) routinely assess the risks within their supply chain 3) remediate any instances that may be found and take steps to prevent a reoccurrence 4) be prepared to demonstrate to our auditors that they have taken these steps. In addition, our suppliers must provide records that are sufficiently detailed to demonstrate that production is in compliance with the anti-slavery and human trafficking laws of the country, where they are manufacturing, to our company auditors upon request. Such records may include a) all employee personnel files, including registration forms, photocopies of ID cards and training records b) all employee time cards and payroll records c) all employee employment contracts d) health & safety policies and procedures e) child labor policy and procedure f) grievance policy, procedures, records, etc.
4. Accountability To Our Standards - We are aware that suppliers may not fully comply with our Standards at all times. However management must be willing to commit to improving in areas where we have found non compliance. If we see that improvements are being made, we generally continue to work with the supplier. If suppliers are not responsive, we will deactivate the supplier code, thereby restricting future business.
5. Training – Training on the Company’s Global Code of Conduct has been provided to our agent, sourcing teams and suppliers throughout the year with the objective of raising awareness on forced labor, child labor and mitigating risk within the supply chain. In addition, training focusing specifically on the signs of forced labor and human trafficking has been provided to all internal sourcing managers and quality field managers as well as sourcing agent’s staff.
Kate Spade & Company continues to be committed to doing our part in the eradication of slavery and human trafficking in our supply chain.