Human Trafficking and Modern Slavery Disclosure Statement
In compliance with the regulations of the California Transparency in Supply Chains Act (SB 657) (“CTSCA”), the UK Modern Slavery Act of 2015 (“UKMSA”), and the Australian Modern Slavery Act of 2019 (“AMSA”), the following “Statement” discloses and updates the policies and actions of Fruit of the Loom and 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.; Vanity Fair Brands, LP; and Russell Brands, LLC (collectively, “Fruit of the Loom” or “Company”) relating to Modern Slavery in our global supply chain during 2022. In order to prepare this joint statement, we engaged with each of the foregoing entities covered by this Statement, and consulted the entities we own or control.
Fruit of the Loom defines “Modern Slavery” broadly to include any form of servitude, forced or compulsory labor, and human trafficking. Fruit of the Loom defines 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 are dedicated to continuously monitor and improve the effectiveness of our prevention efforts, and will incorporate key learnings into the enhancement of our policies and practices to eliminate any form of Modern Slavery in the factories producing our family of brands. We recognize that our review and assessment of our actions to identify and address our Modern Slavery 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.
Melissa Burgess Taylor
Chairman and Chief Executive Officer
Modern Slavery is a complex issue that requires diligence and collaboration at all levels of our supply chain. Our 2022 accomplishments included the following:
- We continue to advance the mapping of our supply chain.
- We mapped our Vietnam supply chain for our Fruit of the Loom® brand.
- We mapped seven (7) of our U.S. tier 1 sourcing supply chains (which, together with our internal supply chain, accounts for approximately 90% (by value) of our apparel imports into the U.S.).
- We mapped our international sourcing supply chain for our Fruit of the Loom® brand.
- As with efforts from prior years, we continued to review our cotton apparel supply chain to avoid the utilization of cotton, yarns, and fabrics from the Xinjiang Uighur Autonomous Region in China (“XUAR”). With the passage of the Uyghur Forced Labor Prevention Act, we implemented the following contractual requirement of our suppliers and our licensees:
- “Our suppliers and licensees may not produce, manufacture, or source goods or materials (including, without limitation, cotton and cotton inputs), in or from the XUAR, or from any entity suspected of using forced labor. Documentation of the foregoing, satisfactory to us in our sole discretion, shall be provided upon request. Our suppliers and licensees that do business with and in China or use inputs from China must review new developments on a regular basis and make sure that their policies and procedures align with current economic, sanction, export, and import requirements.”
Fruit of the Loom has a zero-tolerance policy for employees or suppliers who fail to meet Fruit of the Loom’s standards for the prevention of Modern Slavery in our supply chain. If evidence of Modern Slavery 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
Out of 250 factory assessments in 2022, there were no identified findings in the area of forced labor. Our forced labor criteria include the following:
- No prisoners, indentured, slave, or bonded labor are permitted.
- Workers must not be in debt to a third party or the employer due to recruitment or placement.
- Workers must not pay any fees, taxes, deposits, or bonds for employment-related costs during recruitment, placement, or for continued employment. The foregoing does not include income tax deductions, social insurance, or other similar withholdings legally required by government authorities.
- The actual terms and conditions of employment must be in compliance with the contracts signed at the time of recruitment.
- Workers’ personal identification documents and money must not be controlled or held by the facility or employment agency, even with written consent from workers.
- Workers must not be restricted from leaving the factory after work and/or during unpaid breaks.
Fruit of the Loom conducts training on our Code of Conduct to ensure the understanding of our commitments and requirements, including those related to Modern Slavery, with a particular focus on mitigating risks. All suppliers are provided with our Code of Conduct in all languages understood by the workforce (based on an annual profile), are required to post the Code(s) of Conduct in a conspicuous location and must train employees annually on the contents. In 2022, our Corporate Social Responsibility team engaged in webinar training and committee participation, and conducted multiple virtual workshops totaling 290 hours of training to employees and key partners covering our Modern Slavery policies.
Our Social Compliance Assessment Program is designed to evaluate factories’ compliance with our Code of Conduct. Factories that we own and operate, as well as finished goods contractors – including subcontractors directly sourced by our Company or a licensee – are generally assessed by an accredited third-party or Fruit of the Loom staff on an annual basis. Assessments are typically scheduled with factories, but we reserve the right to perform unannounced assessments at our discretion.
We incorporate efforts to detect Modern Slavery into our factory assessments. By acceptance of our Supplier or Manufacturing Agreement, including our Code of Conduct, our suppliers and licensees certify that the products supplied to us effectively comply with applicable laws regarding Modern Slavery in the country or countries in which they are doing business.
Our Supplier Guidelines (accessible here: https://www.fotlinc.com/sustainability/supply-chain/resources-for-suppliers/#.XPA4ZYhKjcs) include specific benchmarks to assist our suppliers and licensees in their efforts to prohibit forced labor in their, and our, supply chains. We also provide a means for workers to report suspected violations of the Code of Conduct by phone or by email, and we strictly prohibit any retaliation against persons who report violations.
Our Company’s Core Values, as well as our Code of Conduct, govern our approach to Modern Slavery. “Respect for People” is a critical element of these governing documents that define the culture of our employees and contractors in offices, distribution centers and factories alike. Our Code of Conduct includes the following provision regarding Modern Slavery:
“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.””
Additional examples of our efforts against forced labor include our longstanding prohibition of the use of cotton from Uzbekistan and Turkmenistan, and our more recent position statements and monitoring involving allegations of forced labor of North Koreans in China’s Shandong Province and of Muslim Uighurs in the XUAR.
Fruit of the Loom is a private corporation doing business around the world, and, in particular, in California, the United Kingdom, and Australia. Fruit of the Loom manufactures goods in the apparel and sporting goods industries, and our applicable businesses exceed the financial thresholds which require compliance with the CTSCA, the UKMSA, and the AMSA.
Our supply chain is composed of factories that we own and operate, in addition to factories directly sourced by our Company or licensees that produce our family of brands. Approximately 70% of our total imports (by value) are from our Central America supply chain where we own the manufacturing facilities, and directly purchase all of the materials, yarns, fabrics, and trim items.