ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
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CONTENTS ETHICAL SOURCING AT THE WAREHOUSE 2018 REPORT CONTENTS Ethical Sourcing at The Warehouse 2018 Report The structure and content of 4 // Introduction this report was informed by: 5 // The Warehouse and its supply chains The Warehouse Group Ethical Sourcing Policy (2017) 7 // Ethical sourcing programme structure The Modern Slavery Act 13// Policy Themes and 2017 commentary (UK) 2015 and its guidance 5.1 Management Systems on Transparency in Supply 5.2 Child Labour Chains. 5.3 Voluntary Labour Baptist World Aid Australia’s 5.4 Health & Safety ongoing series of “Behind 5.5 Wages and Benefits the Barcode“ reports on the 5.6 Working Hours Fashion industry. 5.7 Freedom of Association and Collective Bargaining Data within this report 5.8 Environment is derived from labour 5.9 Subcontracting audits undertaken for The Warehouse in calendar 5.10 Business Integrity year 2017 and from our internal purchase order 22// New Initiatives management systems. Apparel Supplier Survey & Tier 2 Discovery Customer Survey – New Zealanders views on Ethical Sourcing Where data or commentary ELearning – online resources for factory managers is derived from external sources these are Worker Voice - Integrated Audits referenced in the footnotes 30// Trending now on each page. Transparency The report was compiled Living wages and authored by our Ethical Bangladesh Sourcing Manager and reviewed and approved by Human Trafficking and Modern Slavery our Executive. 37// Appendices Factory Lists List of The Warehouse’s Private Label (“House”) Brands Country Working Hour and Wages table 3
INTRODUCTION INTRODUCTION The Warehouse Ltd is the largest subsidiary of The Warehouse Group1 – New Zealand’s largest publicly listed non-food retailer. The genesis of our Ethical Sourcing programme dates to the values and vision of our founder and cornerstone shareholder Sir Stephen Tindall. Sir Stephen’s and The Warehouse Group’s attention. We have provided disclosures organisation to tackle these challenges vision is to help communities throughout and commentary in relation to these alone – even in tiers of the supply New Zealand to flourish and to contribute NGOs’ expectations - even where they chain where there is direct contact and to a more sustainable country and planet. currently exceed our capabilities. This influence. We need further collaboration reflects our commitment to transparency between business, government, and At The Warehouse, with our extensive and continuous improvement. civil society. Consumers also have an direct sourced, private label merchandise important role to play by informing programme, we recognise that we have Our report also highlights several themselves about the ethical attributes a special duty to protect the welfare of new initiatives undertaken during of the choices available to them and workers in our supply chain. Since 2004 the year and for the first time a list continuing to support those businesses we have been on a journey to continually of our apparel factories along with improve and extend the scope and who are meeting their expectations. a comparative real wage and effectiveness of our programme. We aim to be one of those businesses, working hour table across different and look forward to informing you further source countries. This report is intended to inform the about our progress in the future. reader openly and transparently about Despite significant progress on our conditions “behind the barcode” in our Nick Grayston journey to date there remain many source factories. It describes how our Group Chief Executive Officer issues to address. Each year we reset Ethical Sourcing Programme functions, The Warehouse Group our strategy according to our learnings and how we work to ensure that the and emerging external expectations. Your feedback or questions are welcome profit in our enterprise and the value we It’s impossible for any single sourcing at ethical.sourcing@thewarehouse.co.nz deliver to customers is also functioning to protect and improve working conditions for those at the origin of our supply chain. The information in this report is presented through the lens of our January 2017 Ethical Sourcing Policy2 – so readers can see how we have implemented the policy in practice over the past year. We have also taken account of the “Transparency in Supply Chains” guidance3 provided by the UK Government to companies preparing public statements under the UK’s 2015 Modern Slavery Act. Although no such legislation exists yet in New Zealand it has attracted considerable interest in Government, NGO, and Academic circles. Closer to home, reports published by Baptist World Aid Australia and Oxfam addressing labour issues and setting expectations for apparel supply chains have also captured media 1. http://www.thewarehousegroup.co.nz/ 2. http://docs.thewarehouse.co.nz/red/pdfs/suppliers/ethical-sourcing/the-warehouse-group-ethical-sourcing-policy-01.17.pdf 4 3. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/649906/Transparency_in_Supply_Chains_A_Practical_Guide_2017.pdf
THE WAREHOUSE AND IT’S SUPPLY CHAINS THE WAREHOUSE AND IT’S SUPPLY CHAINS The Warehouse is New Zealand’s largest general merchandise retailer with 92 stores throughout New Zealand and a large online presence at www.thewarehouse.co.nz Our customers represent a completely layers of margin capture, with the origins goods is China. Everyday consumables diverse group of New Zealanders. Our of manufacture usually invisible to the and grocery items tend to be sourced marketing, and wide ranges of general retailer if not the local wholesaler as well. closer to home in New Zealand and merchandise and apparel, are focused Australia. Recently we have seen a primarily on families, and shoppers Commencing with opening of our growth in home textiles and apparel being looking for great everyday bargains. own direct sourcing office in Shanghai sourced from India and Bangladesh. To in 2004 The Warehouse set about support this, we opened another sourcing At the time of The Warehouse’s listing revolutionising this model, flattening the office in New Delhi India in January 2017. on the New Zealand Stock exchange supply hierarchy, and securing direct in 1995 through to the early 2000s’ the access to manufacturing sources with an The most recent trend transforming dominant model for most large general attendant leap forward in traceability and retail everywhere is the advent of the merchandiser retailers was to source both transparency. For our customers, this has online giants such as Amazon offering branded and private label4 merchandise meant reduced prices for most product consumers efficient direct access to vast through a New Zealand network of local classes while maintaining our position in ranges of merchandise where ever they agents, manufacturers, wholesalers an increasingly competitive marketplace. might be. and importers. These enterprises in turn This trend has continued to accelerate in sourced merchandise through their own recent years to a point where at the end Fortunately, because of the work we have supply chains – additional networks of of 2017 more than a quarter of our already done flattening our supply chain, “middlemen” (trading companies) and merchandise is sourced direct through developing our direct sourcing expertise, factories predominantly in Asia5. our own sourcing offices. and investing in our online webstore The Warehouse is very well placed to meet This old model was characterised by By far our biggest source of general the challenges of an international and highly dispersed supply chains, multiple merchandise, apparel, and electrical digitised market place. THE WAREHOUSE PRODUCT SUPPLY CHAIN The Warehouse Diminishing levels of influence and control In recent years The Warehouse Top 20 Source Countries Share of Business External Tier 1 has been moving to much more CHINA 61.14% Agent Vendor Brand factory direct and concentrated sourcing relationships with attendant NEW ZEALAND MADE 11.17% improvements in traceability and AUSTRALIA 7.41% all forms of assurance. In 2017 UNITED STATES OF AMERICA 3.68% about 43% of our sales were No further Tier 1 Tier 2 derived from own branded BANGLADESH 1.67% Vendor merchandise. We can trace 99% UNITED KINGDOM 1.64% visibility factory supplier of our branded merchandise to its Tier 1 (final manufacture) source. DENMARK 1.48% In 2017 we had 1240 vendors INDIA 1.42% overall of whom 525 were THAILAND 1.37% Tier 1 Tier 2 Tier 3 supplying our own brands. Associated with these were 985 MALAYSIA 1.32% factory Supplier Supplier Tier 1 factories including 190 KOREA (SOUTH) REPUBLIC 0.94% apparel factories. All these are GERMANY 0.90% required to undergo and pass our quality, labour and environment VIETNAM 0.80% Tier 2 Tier 3 assessment before joining our ITALY 0.65% supply chain. supplier Supplier At present our traceability and FRANCE 0.48% assurance does not extend PAKISTAN 0.48% beyond the first Tier (final POLAND 0.32% Preferred more manufacture) factories but we Historical direct model have now begun mapping and INDONESIA 0.31% Model Tier 3 identifying the 2nd Tier of our CANADA 0.29% Supplier apparel supply chain. SWITZERLAND 0.28% Tier 1 = Final manufacture sites Tier 2 = Components and subsidiary processes Tier 3 = Raw materials 4. A retailer’s own brand versus a national or international brand owned by a supplier external to the retail enterprise. You can see List of The Warehouse private labels on page 41 5. During this and previous eras in NZ there remained a base of light manufacturing supplying retailers however this has declined significantly with the liberalisation of trade in the 6 1980s culminating in free trade agreements of the early 2000s.
ETHICAL SOURCING PROGRAMME STRUCTURE ETHICAL SOURCING PROGRAMME STRUCTURE The Warehouse’s Ethical Sourcing programme contains the three elements of policy, due diligence, and remediation or corrective action described in the United Nations Guiding Principles on Business and human rights.6 Our policies, and a description of our due Once a factory is qualified and development workshops and training diligence and remediation processes are manufacturing for one of our private for factories who need help to improve published on The Warehouse Supplier labels we maintain visibility of standards their labour management practices. In website.7 In practice our due diligence through an ongoing monitoring and addition, from December 2017, we have is implemented through supplier continuous improvement (remediation) made an online library of eLearning pre-qualification processes (for new cycle. Monitoring is achieved either via courses, focused on common corrective factories), ongoing factory monitoring our own commissioned follow up audits action themes, available to factories (for active factories), and continuous or via a desktop review of improvement in their local language to support their improvement initiatives and training. actions evidence submitted by the remediation and improvement initiatives. Through these activities we strive to factory. Face to face support from our Our prequalification processes are ensure that only factories which meet internal Ethical Sourcing specialists is intended to screen out poor performing or exceed our standards can supply available to assist factories with their factories before they enter our supply goods bearing one of The Warehouse’s remediation path. We hold regular chain, however should a zero-tolerance private labels. To qualify new candidate factories (from an Ethical or Labour Standards perspective) we first invite the factory to submit any existing labour standard credentials they may have in the form of a recent audit report undertaken for another customer. This is to avoid unnecessary duplication and to minimise audit fatigue for factories. However, we are very conservative in our approach to such mutual recognition and reject about half of such desktop submissions. In these cases, the factory must undergo our own audit8 if they wish to qualify. These audit findings are then assessed against our policy, especially for zero tolerance standards like child labour, voluntary labour, or non-transparent audit practices. The overall pass rate for new factory submissions in 2017 was 60%. 6. Page 16 http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf 7. https://www.thewarehouse.co.nz/c/suppliers/ethical-sourcing 8 8. Executed by 3rd parties according to our policy and audit protocol
ETHICAL SOURCING PROGRAMME STRUCTURE The Warehouse Group Chief Executive Nick Grayston with our New Delhi sourcing team issue be encountered within an active array of Tier 2 suppliers - manufacturing Ethical Sourcing team for further review, factory we suspend business and call for components, and undertaking subsidiary analysis, and eventual response to the an immediate rectification of the issue. manufacturing processes. Below this level supplier. Our three main service providers If this is not achieved, we permanently still lie the (Tier 3) raw material suppliers at present are Elevate12, Taos Network13, discontinue trading.15 active factories – natural and synthetic fibers in the and Asia Inspection Services14. Our own were discontinued for standards failure case of apparel; plastic resins, minerals, internal Ethical Sourcing staff travel in 2017. For less critical issues, training timber, leather and so on in the case of regularly with these auditors in the field, and support is provided for the factory general merchandise products classes. exchange reciprocal training, and draw to demonstrate improvement within an At present, we can’t make any assurance on their expertise to inform our policies agreed time frame. statements about these levels of our and gain deeper insight into actual supply chain (Tier 2 & 3) except for FSC practices in factories. We prioritise the Programme Scope and Scale deployment of these resources based certified timber products10 and products Although our Ethical Sourcing policy is on a historical risk profile for the factory, containing certified sustainable palm oil.11 directed to all suppliers, our monitoring region or industry. In 2017 22% of audits and enforcement work is focused on However, in 2017 we began to map the were undertaken on an unannounced factories manufacturing our private characteristics of the second tier of our basis. Each audit includes an label merchandise.9 As we are primarily Apparel supplier base and to capture the anonymously captured record of worker an “own brand” retailer this is a very identity and location of the various fabric interviews and a wage and working significant share of our product range mills, dye and wash houses, print shops hour table which clearly illustrates any – about 43% of purchases in 2017 – and accessory suppliers associated with variances in a sample of workers’ pay equivalent to NZD $500 million. This was our garment factories. You can read from legal entitlements. In a small sourced from 985 factories represented more about the outcome of this work in number of cases we supplement the by 525 vendors. We can trace 99% of this the feature on our Apparel supply chain audit findings with offsite observations business back to its (Tier 1) factory of on page 23. and worker interviews. We don’t publicly origin. The largest 300 of these account share our audit reports but this report Audits for about 80% of private label purchases. discloses our audit findings and activity All our labour audits are undertaken by At present our programme is focused third party audit firms that specialise at an aggregated level. the first Tier of the supply chain – i.e. the in labour standards and worker rights Our audit traverses five sectors of a final manufacture sites. This is where auditing. They have many years’ factories Labour and Environmental we have the most control and influence, experience working in this way on behalf management performance: Employment and our progressive improvements of international brands. Each audit report Policies, Compensation & Hours, Health in transparency and traceability over is subject to an internal quality assurance & Safety, Dormitory, and Environment. time have been significant. However, review by the service provider before Each audit report generates an overall beyond Tier 1 there exists a complex being submitted to The Warehouse score, highlights any core standards or 9. See current list of our private labels on page 41 10. http://docs.thewarehouse.co.nz/red/pdfs/suppliers/product-quality/wood-product-sourcing-policy-mar15.pdf 11. http://docs.thewarehouse.co.nz/red/pdfs/suppliers/product-quality/palm-oil-product-sourcing-policy-may16.pdf 12..http://www.elevatelimited.com/ 13. http://taosnetwork.org/ 9 14. https://www.asiainspection.com/
ETHICAL SOURCING PROGRAMME STRUCTURE transparency issues and contains extensive contextual commentary from the auditors along with a record of any corrective actions agreed with factory management at the time of the audit. The average overall audit score in 2017 was 84.25% Programme Management and Accountability Within our management structure accountability for the strategy and operational outcomes of The Warehouse ethical sourcing programme lies with the Executive General Manager of Sourcing and the CEO of Sourcing Support for The Warehouse Group. The execution of our strategy is monitored through a typical plan-act-review cycle and our quarterly reporting meetings are also attended by the Head of Risk and Audit for The Warehouse group. Operations are Average overall score overseen by our Ethical Sourcing manager 84.25 and team based in Auckland and Shanghai. All sourcing and merchandise personnel based in Asia or New Zealand receive an orientation and ongoing updates to our policies Employment Dormitory Policies and programme. One of the strengths of our 92.66 94.58 programme is its close engagement with our senior sourcing personnel who have full visibility of the programme’s progress and the status of all supplier factories. They regularly lend their commercial support to the Ethical team’s efforts to motivate and engage factories in improvement initiatives. An internal protocol dictates that all zero tolerance issues such as underage labour, Environment bribery attempts, or involuntary labour are 85.64 Compensation immediately escalated to the CEO of Sourcing & Hours 66.18 Support for review to secure an Executive mandate for any consequential actions. Health & Safety 90.98 10
POLICY THEMES AND 2017 COMMENTARY 11 Fabric processing Fuijian China
Policy POLICY themes THEMES and AND2017 2017commentary COMMENTARY 5.1 MANAGEMENT SYSTEMS Adequate Management The average audit score for policies in 2017 was 94.5% Systems are deployed. “Suppliers should maintain all necessary policies, Within the first section of every audit bonded labour, and non-discrimination management and information we undertake, there is a comprehensive on grounds of pregnancy or other systems, facilities and human series of twenty seven checkpoints reasons. resources needed to ensure which examine the factories policies The policies section typically scores they comply with all applicable and management systems. highly within audits – its relatively easy local laws and regulations These address wages, benefits and for a factory to assemble the requisite and the requirements of hours, overtime rates, discipline and policy documents required by various this policy.” termination, grievance procedures, customer codes. A common failure in - Policy extract harassment and abuse and written factories however is in deploying the contracts. Also included are age requisite management and information identification, freedom of association systems needed to give effect to policies and collective bargaining rights, – for example when it comes to tracking prohibitions on: child labour, forced or and controlling working hours. Fabric Sizing, Dhaka, Bangladesh 12
Policy POLICY themes THEMES and AND2017 2017commentary COMMENTARY 5.2 CHILD LABOUR This is a core or zero tolerance issue within our due diligence Child labour shall not be used. approach. Our auditors carefully review identity records for any “Suppliers shall not employ evidence of underage workers or falsified identity records along with workers younger than the national minimum working age. Juvenile careful observation of workers during interviews and the factory tour. or young workers are employed in accordance with local law and In 2017 we had just one incident of confirmed underage labour. shall not be required to participate in night work or hazardous work. Children are not permitted in Footwear factory Zheijiang China July 2017 the workshop areas of the factory. This factory was undergoing a follow 5) Contact the parents and legal Where underage workers are up audit. Two underage workers were guardians and provide transportation detected during a compliance found onsite. They were proximate to and meals package to assist them to audit, the factory shall take working age -16 and working during the return home safely. All the cost should responsibility for repatriating the school holidays. The factory followed be paid by the factory; bus/train child and enduring the continuity all the auditors recommendations and tickets should be kept on files. of their education and welfare provided documented evidence that until they attain legal working age.” 6) Review all personnel files and take these actions had been taken : all possible measures to identify the - Policy extract real ages of the current employees, 1) “These underage labourers should especially those workers who are Whatever the cultural tolerance or stop their work immediately. young-looking. rationale present in these instances, 2) Terminate the employment they are violations of local laws and 7) Establish age-verification process relationship with these two workers in every case, we issue the factory a for all new workers and conduct immediately and pay their wages warning along with a requirement that personnel file screening regularly according to the hours they had they take steps to help the underage through self-monitoring to prevent already worked. worker leave the workplace while the employment of child labour at 3) Arrange health examination for them ensuring they are in safe keeping until the factory.“ as soon as possible. The health the school term recommences or the Notwithstanding the factory’s positive child reaches the legal working age. examination fees should be paid by response to these findings there were the factory and examination results We cannot categorically exclude the other significant non-conformances should be kept on files. possibility of more systemic and uncovered during the audit it’s overall 4) Compensation should be given to audit score was 62% and failed 6 of abusive child labour practices existing these workers until they turn to 16 10 core standards including the zero within the subsidiary levels (Tier 2 & years old, a minimum legal working tolerance underage labour finding 3) of our supply chain but can say we age. The compensation amount above. We ceased trading with have never encountered it within our should no less than local legal this factory. due diligence work to date at the minimum wage per month. final manufacture level (Tier 1) of our supply chain. Child labour on the streets 13
Policy POLICY themes THEMES and AND2017 2017commentary COMMENTARY 5.3 VOLUNTARY LABOUR This policy provision addresses some of the most potentially Employment is freely chosen egregious labour abuses. In addition to checking for a “Prison labour is prohibited. Bonded factory’s policies on these topics our auditors also closely labour is prohibited - suppliers shall examine payroll practices for evidence of delayed or withheld not bind workers to their workplace payments, or deductions associated with disciplinary fines. through debt associated with recruitment fees, fines, loans, deferred payment or other means. Where evidence of these practices is suppliers because we were unable to Workers shall not be recruited or found, an immediate corrective action satisfy ourselves that our preferred employed through human trafficking. to the offending practice is raised. course of continuing to work with Suppliers shall not retain identity the supplier was going to affect Bonded labour is a concern in documents (such as passports or positive change for workers. Despite countries where there are high rates identity cards,) unless at the request repeated attempts we had been of migrant workers coming from of workers and with written unable to secure management permission. Workers must be able to undeveloped countries to take low support for changes to their migrant take leave form the factory for reasons skilled jobs in developing countries. recruitment and labour management of bereavement, illness, or significant In these cases, our auditors look practices. We moved this business family events and at any time when closely at the recruitment pathways to another Malaysian supplier with they are not working. leave, including deployed by the factory, their better audit outcomes where we felt maternity leave, entitlements shall be practices around the safekeeping that our commercial leverage was upheld. Workers can terminate their of identity documents, and worker more likely to secure improvements employment with reasonable notice disclosures about the fees paid to for workers. Our interventions in and without penalty.” secure their placements or access to Malaysia have included escalating working visas. The legality of Visas is - Policy extract our concerns to the board of closely examined as undocumented directors of a public company, workers or those with expired Visas ensuring freedom of access to are vulnerable to exploitation. identity documents, improving This year we terminated our dormitory conditions, and reducing relationship with two Malaysian working hours for migrants. Dhaka Garment Factory 14
POLICY THEMES AND 2017 COMMENTARY 5.4 HEALTH AND SAFETY Our average health and safety audit score in 2017 was 91% Working conditions are safe and hygienic “Workplace hazards are clearly identified A safe workplace is the most basic of deficiencies in the quality of their and controlled through a working health worker entitlement. Our due diligence construction and infrastructure - as and safety plan. Responsibility for assessment contains over 57 Health evidenced in the tragic collapse of the health and safety is assigned to a senior & Safety investigation points Rana Plaza building in 2013 - Health management representative. Health and and Safety, especially building and Fortunately, in most cases, because safety training is provided for all workers. fire safety, demand special attention. of the long held focus of brands on Appropriate Personal Protective Equipment Consequently, we decided to further is deployed and its use enforced. Access to this area, and the interest of local strengthen our health and safety adequate medical assistance and facilities governments, Health & Safety is assessment capability by joining and drinking water and, if applicable, consistently one of the highest scoring the Alliance for Worker Safety in sanitary facilities for food preparation sectors within our audit reports. Bangladesh.15 Our membership of and storage. However as with the above concerns the Alliance has delivered major Suppliers shall ensure that residential for migrants in Malaysia each country improvements in building safety for facilities for workers, where provided, are has unique labour management all our participating factories. (see clean and safe. An accident and injury challenges. In Bangladesh, because our Bangladesh feature on page 34) register is maintained. All legal building, electrical, and fire safety, requirements are met. The operating safety of machinery and equipment is assured through a documented maintenance schedule. hazardous Chemicals are clearly identified, and stored and handled in accordance with local regulations and or international best practice. A natural disaster or emergency preparedness plan and training is in place. The workplace and its recruitment practices are free from harassment, or abuse. There is no discrimination in hiring, compensation, access to training, promotion, termination ore retirement based on age and race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation. A written grievance procedure and training should be established for workers that ensures confidentiality, freedom from reprisal and a pathway to resolution. Establishment for workers that ensures confidentiality, freedom from reprisal and a pathway to resolution.” - Policy extract Alliance Safety Signage in The Warehouse Garment Factory Dhaka Bangladesh 15 15. http://www.bangladeshworkersafety.org/
POLICY THEMES AND 2017 COMMENTARY 5.5 WAGES AND BENEFITS In 2017 the average audit score for wages and Workers monetary entitlements are working hours was 66.2% met or exceeded “Wages for regular working hours shall meet or exceed local minimum rates, enable workers to meet their basic Determining workers’ actual and averaged over several months, needs, and provide some discretionary income. pay and its relationship to legal cross checked with payslips and entitlements and working hours dialogues with the workers. These Where labour is employed indirectly through a licensed is one of the most important and calculations are then summarised agency or broker wages for regular working hours shall challenging tasks for our auditors. in a wage table (sample below meet or exceed local minimum rates, enable workers to for a Chinese factory) which meet their basic needs and provide some discretionary The baseline indicator an auditor illustrates the local monthly income. Where workers are paid by piece, the factory’s must be aware of is the legal piece rate schedule should enable workers to achieve at minimum wage, the number of minimum wage for that region least the minimum legal payment applicable to all regular days worked in the month, the and any benefit entitlements such and overtime hours worked. total number of overtime hours as workplace insurance. In many worked in the month, a projected When commencing work, all workers must have signed developing country workplaces, entitlement at a benchmark contracts in accordance with local law which include especially in China, workers are overtime premium of 1.5 times relevant information about their employment conditions, paid by pieces produced rather the legal minimum hourly rate, wages, working hours and benefits. than an hourly rate. Auditors must the actual pay received, and a convert a worker’s total pay into an Suppliers shall provide each worker pay slips in their local percentage variation against the equivalent hourly rate for regular language detailing regular hours and wages, overtime entitlement. This calculation is hours worked and an overtime hours and wages, any bonus paid, and any legally then used to score the factory rate for overtime hours worked. permitted deductions. Suppliers shall not make any wage against its minimum and overtime To make this calculation true deductions unauthorised by law. Wages shall not be wage obligations. auditors must have both accurate withheld beyond due dates. Suppliers shall not terminate payroll data and accurate working While factories typically pay and re-hire workers in a manner that avoids paying hour data and then validate that in excess of minimum wage applicable legal benefits. this amount was paid to the entitlements, and weekday overtime Where stipulated by law, the supplier shall provide work- worker either in cash or via bank rates, they often do not achieve related injury insurance for all workers.” account deposits. A random weekend overtime premiums. sample of payroll records for - Policy extract individual workers are analysed Examples of wage calculation table: Total Pay Normal Total Monthly Total Pay @ 1.5 Employee No Name Department According Variation % Working Day OT hours OT Std. Records N/A Liu Chenghui Tie dye 22 142 3577.01 3272.44 -8.5% N/A Yu Xiaoqing Tie dye 22 132 3439.08 3412.35 -0.8% N/A Xu Lanfang Dyeing 22 135 3480.46 4052.14 16.4% N/A Xu Fang Dyeing 22 117 3232.18 4157.07 28.6% N/A Xu Youlan Washing 19 132.5 3225.29 3904.63 21.1% N/A Liu Guoshun Washing 22 141 3563.22 4063.85 14.0% N/A Yu Youqin Pressing 22 127 3370.11 3425.12 1.6% N/A Yang Le Printing 21 105 2993.10 3032.04 1.3% N/A Zhou Shuwang Cutting 22 117.5 3239.08 4757.52 46.9% N/A Lan Dong Sewing 22 106 3080.46 4765.79 54.7% Month, Year: Jun-17 Local Min Wage: 1600 Total Local Regular Working Days for Calculation 21.75 16
POLICY THEMES AND 2017 COMMENTARY 5.6 WORKING HOURS Of all the prescriptions within the ILO Labour Conventions and other codes such as the Ethical Trading Initiative16 actual developing country working hours show the greatest deviation from local law and international codes and conventions. Working hours are not excessive. We have been tracking developing in a constructive debate about the country working hours data for more importance of transparency and integrity Regular working hours, excluding than ten years. Unlike progressive overtime, should not exceed 40 or within the overall business relationship 48 hours per week (whichever is increases in wages, and significant while at the same time demonstrating defined by local law). All overtime improvement in health, safety, and an understanding of local norms and hours should be voluntary and environmental measures, working hours practices. compensated. have remained persistently high – especially when viewed from a western According to data from our active Workers shall be provided with at perspective. Long hours remain despite factory audits in 2017 average weekly least one day off in every seven- the intensive monitoring efforts of working hours were 69 hours. In a much day period or two days off in every numerous brands and multi-stakeholder wider sample of audits undertaken for fourteen-day period. initiatives. Unless local governments multiple international brands working The supplier must record workers’ decide to strictly enforce this element hour averages for China and Bangladesh regular and overtime hours accurately of their labour law, change is unlikely, respectively were 65 and 70 hours as the basis for controlling excessive as production worker earning aspirations, per week.17 working hours and providing correct and competitive labour markets continue compensation. We believe by pursuing transparency and to dictate working hour norms - even accepting local working norms we are Seasonal peak or deadline based where wages have grown significantly. much better able to identify excessive demand for overtime must be offset by Our approach is to place transparency hours and reduce these via the corrective rest days and reduced working hours. at the forefront and seek a reliable actions plan agreed with the factory. - Policy extract account of working hours in every audit A typical corrective action request where we undertake. This often entails rejecting excessive hours are identified is to first documentary evidence which is too reduce weekly hours to 72 or less with good to be true and engaging factories one rest day per week. The Warehouse Consumer electronics factory Shenzhen China 16. https://www.ethicaltrade.org/eti-base-code 17 17. You can view a comparative table of various countries’ working hour data on pages 42-43.
POLICY THEMES AND 2017 COMMENTARY 5.7 FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING Each audit we undertake includes an evaluation as to whether these worker rights are being restricted. However, the legal sanction for such rights varies by country. China for example has not ratified restrict these rights and intermittent Freedom of Association or Collective the ILO conventions related to protest is feature of the Chinese bargaining are not restricted. the rights to organise, associate, labour landscape. These protests Where the right to freedom of association and collectively bargain.18 Nor are typically organised outside the and collective bargaining is restricted by has it ratified the convention auspices of the All-China Federation law, the employer does not hinder, the obliging ILO members to maintain of Trade Unions (ACFTU) the only development of parallel means for a system of labour inspection. trade union that is legally allowed independent and free association and Bangladesh by contrast has ratified to exist in the country. The relative bargaining. both these conventions and their absence (in a western sense) of Workers representatives are not discriminated garment sector alone has more workplace unions in China and against and have access to carry out their than 500 registered trade unions. the lack of enforcement of many representative functions in the workplace. Notwithstanding China’s position labour law elements are important our audits have never revealed any elements of the moral case made - Policy extract attempts by factory management to for programmes like ours. Seamstresses The Warehouse Garment factory Dhaka Bangladesh 18 18. http://www.ilo.org/dyn/normlex/en/f?p=1000:11210:0::NO:11210:P11210_COUNTRY_ID:103404
Policy POLICY themes THEMES and AND2017 2017commentary COMMENTARY 5.8 ENVIRONMENT Factories’ environmental scores have been improving and Environment Protection measures averaged 86% in 2017. are sound. Suppliers must comply with all local The suite of environmental check The Chinese Government’s laws and regulations pertaining to points within our audit tool seeks determination to address its pollution environmental protection. Suppliers must to assess first whether the factory problems was very visible in 2017 maintain an environmental policy and has achieved any form of external with a series of crackdowns on management plan sufficient to control environmental accreditation such polluting factories rolling through the and minimize all Environmental Hazards, as ISO 1400119, or Oeko-Tex 20. industrial provinces.21 In our case, Wastes or Pollutants unique to the factory. several dye houses associated with Suppliers should be able to trace the We examine the factories our garment factories were shut origin of all their primary materials and environmental planning resources down without notice while they components and provide the disclosure to such as its policies, environmental underwent government inspections The Warehouse Group on request. hazard register, records associated before reopening. - Policy extract with energy and water conservation. In 2017 we began profiling this 2nd tier Finally, we track the practical and of our apparel supply chain in much legally required actions being taken to more detail requiring garment factories monitor wastewater discharge, control to identify such secondary sites and air pollutants, dispose of solid waste, describing what kind of environmental enable recycling, and deal with any oversight they deploy (see our apparel hazardous wastes. supply chain feature on pages 23-24) Fabirc Mill Waste Water treatment ShaoXing China 19. https://www.iso.org/iso-14001-environmental-management.html 20. https://www.oeko-tex.com/en/business/certifications_and_services/ots_100/ots_100_start.xhtml 21. https://www.ft.com/content/f48c9674-ae68-11e7-beba-5521c713abf4 ; https://www.npr.org/sections/parallels/2017/10/23/559009961/china-shuts-down-tens-of-thousands-of- 19 factories-in-unprecedented-pollution-crack
POLICY THEMES AND 2017 COMMENTARY 5.9 SUBCONTRACTING Although this requirement pertaining to subcontracting has always been implicit in our policy we decided to make these expectations very explicit when we released our updated policy in January of 2017. Subcontracted production or Ensuring that production is occurring in Shanghai and in our regular face to processing is disclosed and in qualified designated source factories face meeting with vendors in China, authorised. is a challenge in many supply chains Bangladesh and elsewhere. - especially in apparel and footwear. Facilities engaged by the suppler or In the past 18 months, we have taken We documented 12 instances of factory for subsidiary processing additional measures to strengthen unauthorised subcontracting in 2017. must be disclosed at the time of our assurance systems in this regard. factory registration. Subsidiary In the instances where we uncover processing facilities may be inspected In Bangladesh, we deploy our own quality control inspectors to factories instances of unauthorised at any time at the discretion of The daily rather than our former practice subcontracting at minimum we Warehouse Group. Purchase orders of releasing shipments based on final suspend trading with the responsible must be manufactured at the factory inspections by third parties. In Chinese vendor or factory until and if we can designated by the supplier on the garment factories if we don’t think we re-establish confidence that they purchase order. Order diversion or are maintaining sufficiently frequent understand and will adhere to our subcontracting to a factory other than contact with factories we have deployed policies. We also check to see if we designated on the purchase order 3rd party auditors to factories on an have contributed in any way through a shall only occur with the advance unannounced basis to analyse the lack of communication or overbooking knowledge and written authority of factories recent production schedule the factory in relation to its capacity and the The Warehouse Group. and look for evidence of subcontracting. ability to meet production deadlines. - Policy extract In November, we employed a full-time specialist within our Shanghai office However, unless a final manufacture to focus on production validation and site is very large and vertically corrective action plan support for integrated some processes and factories – primarily in the garment most procurement of materials and sector. We have been emphasising components must be sourced from this policy requirement in all our subsidiary suppliers or processors. recent supplier communications This is a necessary and entirely – at our September vendor conference legitimate form of subcontracting. Fabric Mill Waste Water treatment Fujian China 20
POLICY THEMES AND 2017 COMMENTARY 5.10 BUSINESS INTEGRITY Our overall transparency score in 2017 was 76% - an improvement from 66% in 2016. No unethical or illegal conduct. This policy element goes to the heart of integrity commitment which is Suppliers shall not offer gifts or money to why our programme exists. a feature of every audit opening an employee or service provider engaged We know our customers22 and team meeting). This was the first social by The Warehouse. members expect our supply chain compliance audit undertaken by Assistance with transportation shall behaviours and standards to be this factory. The audit score was be limited to local hub connections. consistent with The Warehouse 62%, with four core standards failures Hospitality shall be limited to working Group’s vision to help communities and non-transparent practices. lunches or dinners. throughout New Zealand to flourish We ceased trading with this factory. and to contribute to a more sustainable Where an employee or service provider country and planet. Every audit we of the The Warehouse Group solicit By far the most common breach of undertake contains the auditor’s gifts, money or any other benefit this integrity we encounter is an attempt assessment of the transparency must be declined and reported to during an audit to misrepresent payroll and reliability of the audit findings. The Warehouse Group at and working hour data. This is a zero- ethical.sourcing@thewarehouse.co.nz. Our auditors function within a tolerance issue for us and unless this is resolved promptly we terminate the Suppliers and their employees shall protocol that demands an immediate trading relationship. Another important not attempt to fraudulently meet the notification of any integrity breaches integrity risk highlighted in our policy, requirements of this policy, quality such as bribery attempts. We received standard, or any other business 2 such notifications in 2017. is fraudulent or doctored product test requirement through any kind of intentional reports or certifications. For this reason, misrepresentation or deception whether Bribery Notifications our QA technicians always validate documentary or verbal in nature. - Home Decor Factory Shanghai China these documents with their associated December 2017 test lab prior to commencing their The provision of copies of audit reports as Attempted bribery during audit own review. evidence of the suppliers conformance with this policy shall be deemed as permission on challenge to non-transparent New Zealand is still fortunate enough to contact the auditing body for report records. After we received the to enjoy a number 123 ranking in verification purposes. Likewise, any copies immediate notification from our Transparency International’s World of test reports or certifications submitted in auditor the factory manager met Corruption Perceptions Index. In their support of any product’s conformance with with our China Sourcing Manager and open letter to the then Prime Minister, any regulation or standard shall be deemed provided a documented retraction Transparency International stated that as permission to contact the test laboratory and commitment to the provision “New Zealand is perceived as the least or certifying body for verification purposes. of transparent records. These were later validated by our internal Ethical corrupt nation in the world; integrity is Suppliers shall participate in any audits New Zealand’s most important asset.” or assessments undertaken with respect Sourcing specialist. Conditions in the We are lucky that “doing the right to their compliance with this policy in a factory are otherwise positive (audit thing“ is still a core Kiwi value. At the cooperative and transparent manner. score of 94%) and we continue to trade with this factory. Warehouse, we are determined to do - Policy extract our best to uphold this value wherever - Home Décor Factory Yiwu China we operate. We know we are not perfect August 2017 - we find challenges everyday – but we Attempted bribery during an initial are continuing to press forward with our audit (despite signing the audit continuous improvement initiatives. 22. See page 25 for our recent survey of customer’s ethical sourcing expectations. 21 23. https://www.transparency.org/country/NZL
NEW INITIATIVES Seamstress - China Garment factory 22
NEW INITIATIVES APPAREL SUPPLIER SURVEY & TIER 2 DISCOVERY In October 2017, we distributed an online survey to all our active Apparel vendors. The main purpose of the survey was to begin to map the characteristics of the second tier of our garment manufacturing base. These are the fabric mills, dye and wash with the Tier 2 assurance disclosures survey. Based on our survey responses plants, fabric printers, accessory and provided in the survey will inform we estimate that underlying this group packaging suppliers supplying the final our interest in extending our ethical of vendors and their Tier 1 factories garment manufacturing sites making our assurance programme into this level is a larger group around 1000 Tier 2 private label clothing ranges. A secondary of the apparel supply chain. suppliers. Survey data indicates that the objective was to understand what forms largest number of these are fabric mills of assurance apparel vendors deploy Quantifying (21%) followed by accessory suppliers over their own supply chains. In 2017 we sourced from 103 apparel (17%) and dye houses (16%). vendors associated with 190 (Tier 1) The remainder are distributed among Following on from the survey we have factories. At the time of the survey we various kinds of specialists such begun to capture the location and identity had consolidated this to a group of 66 embroidery shops, screen printers, of these diverse Tier 2 sites. This along vendors of whom 55 participated in the and packaging suppliers. APPAREL SUPPLY CHAIN MAP : VENDOR/TIER1/TIER 2 The Warehouse Shanghai New Delhi Auckland Sourcing Sourcing Sourcing Office Office Office # Apparel Vendors that participated in the supplier survey •Total 55 responses collected (versus 66 targeted) 43 8 4 •83% response rate Vendors Vendors Vendors Tier 1 (Final Manufacture Sites): Total 178 •Avg. 3/ Vendor 132 33 13 •Max. 11/ Vendor Tier 1 Tier 1 Tier 1 Tier 2 (Processing and Component Suppliers): Total 831 •Avg. 15/ Vendor 617 118 96 •Max. 87/ Vendor Tier 2 Tier 2 Tier 2 Tier 2 Suppliers Distribution (Top 3 Tier 2 Supplier Categories) 21% 17% 15% 18% 16% 15% 23% 23% 22% •Fabric Mills (21%) make up the largest percentage, followed by Accessory Fabric Packaging Accessory Accessory Suppliers (17%) & Dye House (16%) Fabric Mills Suppliers Dye House Fabric Mills Printing Suppliers Dye House Suppliers Fabric Mills Chart illustrates the network of apparel vendors, their Tier 1 final manufacture sites, and Tier 2 subsidiary suppliers associated with our three sourcing offices in Shanghai – China vendors and factories, New Delhi – Bangladesh vendors and factories, and Auckland – New Zealand vendors also sourcing from Asia. Slide 1 23
NEW INITIATIVES Assurance tier of the supply chain. Nevertheless, The results for the 55 survey respondents Securing any labour, environmental, or as a first step within the survey we asked are illustrated in the accompanying quality assurance over this part of our vendors several questions about the kinds infographics. supply chain is complex especially as our of Environmental & Labour assurance transactional significance and influence they maintain over their Tier 1 and 2 is increasingly diluted at each descending supply chains. TIER 1 ENVIRONMENT AND LABOUR ASSURANCE Tier 1= Final manufacture sites { 62% Conduct own environmental 69% Communicate 98% Apparel Vendors say they have a formal management system inspection 65% Review Government permits the customers Labour Policy to the factory 53% Assist the factory prepare for customer audit { 100% Apparel Vendors say they have a formal labour assurance environment assurance program in place for program in place for Tier 1 suppliers Tier 1 suppliers 38% Require factory 76% Require the to hold Environmental factory to hold certification e.g. ISO some labour 14000 or FSC standards certification Slide 2 TIER 2 ENVIRONMENT AND LABOUR ASSURANCE Tier 2 = Subsidiary suppliers – Fabric Mills, Accessory Supplier, Dye Houses { 52% Conduct own 65% Communicate environmental 96% Apparel Vendors say they have a formal management system inspection 65% Review Government permits the customers Labour Policy to the factory 48% Assist the factory prepare for customer audit { 96% Apparel Vendors say they have a formal labour assurance environment assurance program in place for program in place for Tier 2 suppliers Tier 1 Tier Tier 2 1 suppliers 34% Require factory 31% Require the to hold Environmental factory to hold certification e.g. ISO some labour 14000 or FSC standards certification Slide 3 24
NEW INITIATIVES CUSTOMER SURVEY – NEW ZEALANDERS’ VIEWS ON ETHICAL SOURCING In August 2017, we undertook 2 focus groups to better understand customers’ views and expectations concerning Ethical Sourcing. The themes explored included: communications about Ethical Sourcing • Develop own standard of conduct • T he level of importance to customers rather than passive or reactive to media to apply when choosing a retailer? stories. They identified reputation • Incorporate ethical clauses in contracts and trust, as important factors when • What does responsible sourcing mean? • Communicate sourcing with customers choosing a retailer. They felt that hearing • Who does it well/not so well? it from The Warehouse up front (before – they would rather hear it from the any negative media exposure) gives horse’s mouth • What are the issues? reassurance. • T raining modules for staff to complete • What is the best way to communicate so they can share this information with about responsible sourcing? The focus group members had plenty of customers if they ask (should be based suggested actions retailers could take to • T he Warehouse and responsible on NZ national standards that are used exercise responsible sourcing: sourcing? by all/many retailers) • Assist factories to achieve better Customers told us that they don’t have • Advertise this information on social standards, not to cut off sourcing ethical sourcing top of mind and they media, in-store e.g. posters, and on from them retailer’s website (must not be in your don’t generally think about the supply • Get actively involved and give them face, yet easy to find) chain of the retailers they shop at and time to improve products they purchase, but said it could • Stickers on products to show it’s ethically be easily brought to mind by the media. • Provide charitable support to sourced e.g. like star rating /Health tick They recommended we be proactive with communities factories are in on food or SPCA tick on eggs Responsible sourcing was seen by focus group members as just one element of overall responsible retailing. Offers recycling Treats Cares Carbon staff well - about footprint promotion, customers training & pay “Responsible Retailer” Supplies lasting products Responsible sourcing Better use of Giving environmental back to the resources community A Warehouse Store 25
NEW INITIATIVES ELEARNING – ONLINE RESOURCES FOR FACTORY MANAGERS Support for factories remediation or corrective action is the vital third element of the threefold prescription (of policy, due diligence, and remediation) described in the United Nations Guiding Principles on Business and human rights.24 A new initiative we have developed with us to deliver the resources and insights • Transparency & Ethics our service provider (Elevate) in 2017 and smaller factories often lack, more • Corrective Action Plans intend deploying in 2018 is the delivery effectively and uniformly than via our of ELearning courses addressing some typical training workshops. The courses • Working Hours of the most common improvement and are delivered in local languages. • Working Hours Management Systems remediation themes encountered during The initial library we intend distributing factory audits. The courses are intended • Working Hours Recording Systems in 2018 includes courses on: to supplement the direct contact and communication we have with factories, • Authentic preparation for workplace but the digital learning format enables assessments (audits). This is a sample of sequential slides from one of our ELearning courses on working hours. As course adminstrators our Ethical Sourcing team can monitor factories’ progress through their course library. 26 24. http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf
NEW INITIATIVES WORKER VOICE For most of the history of our programme our Substantive Caller Profile primary means of directly accessing workers’ Issues opinions and perceptions has been the worker Caller Profile Substantive Issues interview conducted within every factory audit. Brand: The Warehouse Total Substantive Issues (from Dec '14 onward): 156 A skilled auditor can putThe Warehouse Brand: Total Substantive Issues (from Dec '14 onward): Helpline Issues 156 workers at ease and Number of Substantive Issues Reported - Monthly Helpline Issues secure reliable anonymised Number of Substantive Issues Reported - Monthly information. We estimate 20 that we have been able # of Issues access over 5000 workers’ 20 views over the past 3 years # of Issues 10 in this fashion. However, we 10 have been trying to develop 0 a mechanism to enable Dec, 16 Jan, 17 Feb, 17 Mar, 17 Apr, 17 May, 17 Jun, 17 Jul, 17 Aug, 17 Sep, 17 Oct, 17 Nov, 17 Dec, 17 0 workers’ perceptions and Dec, 16 Jan, 17 Feb, 17 Mar, 17 Apr, 17 May, 17 Jun, 17 Jul, 17 Aug, 17 Sep, 17 Oct, 17 Nov, 17 Dec, 17 concerns to be captured Issues by Category independent of any audit – Aggregate* Monthly Issues by Category and potentially at any Aggregate* time. Monthly 100% 100% 0% Our first effort in this regard 23% 13% 80% was via the Worker Helpline 13% 0% 1% % of issues 80% 60% 23% operated by The Alliance for 1% % of issues 60% Worker Safety in Bangladesh. 40% All workers in our Bangladesh 40% 20% factories have access to 20% 0% the helpline. The Helpline— 0% 62% Dec, 16 Feb, 17 Apr, 17 Jun, 17 Aug, 17 Oct, 17 Dec, 17 Amader Kotha25 (“Our Voice”)62% Dec, 16 Feb, 17 Apr, 17 Urgent: Safety Aug, 17 Jun, 17 Urgent: Non-safety Oct, 17 Dec, 17 General Inquiries Non-urgent: Safety Non-urgent: Non-safety in Bangla—provides workers Urgent: Safety Urgent: Non-safety General Inquiries Non-urgent: Safety Non-urgent: Non-safety with a reliable 3rd-party Most Commonly Reported Substantive Issues* Most Commonly Reported Substantive Issues* reporting channel that allows Top Five Issues Reported by Category them to raise safety concerns Top Five Issues Reported by Category Non-urgent: Safety Health - Inadequate facilities 1 anonymously. Non-urgent: Safety Health - Inadequate facilities 1 Compensation - Benefits 2 The Helpline was first piloted Compensation - Benefits 2 and launched in July 2014, Verbal abuse 2 Verbal abuse Non-urgent: 2 and has receivedNon-urgent: thousands Non-safety Non-safety Compensation - Wages (including bonuses) 1 of calls from workers. Compensation - Wages (including bonuses) 1 Leave 1 Leave 1 0 1 2 3 0 1 2 3 Issue Resolution** The adjacent chart profiles Issue Resolution** helpline calls received from workers in Bangladesh factories Helpline Response to Info Request Helpline Response to Info Request 40% 40% supplying The Warehouse Resolved Resolved Per Factory 60% Per Factory 60% 0% 10% 20% 30% 40% 50% 60% 0% 70%10%80%20% 90% 30% 40% 50% 60% 70% 80% 90% % of Issues % of Issues Monthly views show last 13 months of data. Monthly views show last 13 months of data. Powered by: * Data collected * Data collected before December 1, 2014 is not included before in the analysis ofDecember issues. 1, 2014 is not included in the analysis of issues. Powered by: ** Issue resolution data collection) is reflectedonward. from June 15, 2015 (beginning of data collection) onward. ** Issue resolution data is reflected from June 15, 2015 (beginning of data 27 25. http://www.bangladeshworkersafety.org/en/what-we-do/worker-empowerment/worker-helpline
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