Kellwood Company LLC d/b/a Democracy Clothing (“Democracy Clothing”) and its subsidiaries expect all of its business suppliers to comply with the applicable laws and regulations of the United States and those of the respective country of manufacture or exportation. Democracy Clothing will not conduct business with any factory that uses involuntary labor of any kind; including prison labor, indentured labor, bonded labor or labor obtained through human trafficking or slavery. Pursuant to the California Transparency in Supply Chains Act (2012), below you will find disclosure of the efforts Democracy Clothing is taking to eradicate slavery and human trafficking from our direct supply chain.
Engagement in verification of product supply chains to evaluate and address risks of human trafficking and slavery.
Democracy Clothing utilizes an independent third party to conduct Workplace Conditions Assessments (“WCA”) to determine every prospective supplier’s risk level. The risk assessment includes additional focus on monitoring for human trafficking and slavery risks within the supply chain. Democracy Clothing will only accept suppliers that meet a high-performance threshold following their WCA. When potential risks are identified, a course of action is determined to best address them. Democracy Clothing may require prospective suppliers to complete a corrective action plan (“CAP”) to remediate risks identified in the WCA. All business partners are reviewed annually by an independent third party for social compliance, which includes evaluating risks related to human trafficking and slavery. Partners with identified risks will be required to complete a CAP or other remediation to alleviate such risks. Partners who fail to complete the CAP or fail to demonstrate remediation cannot be approved as Democracy Clothing business partners.
Auditing of suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains.
New suppliers that produce Democracy Clothing goods agree to adhere to Kellwood’s Supplier Manual for Social Responsibility through confirmation and acknowledgement exercises. Also, Democracy Clothing audits and monitors existing suppliers that produce Democracy Clothing goods against the Kellwood Supplier Manual for Social Responsibility, Kellwood’s Code of Conduct and the suppliers' country labor laws through independent third party monitoring companies that conduct both unannounced and announced audits. In addition, for all suppliers, Purchase Order Terms and Conditions include statements regarding compliance standards against trafficking and slavery practices. By acceptance of each and every Purchase Order, our suppliers are confirming their understanding and agreement to the compliance standards.
Compliance with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
All Democracy Clothing suppliers agree to adhere to the Kellwood Supplier Manual for Social Responsibility and Code of Conduct, which include language regarding human trafficking and slavery. The Kellwood Supplier Manual for Social Responsibility requires that all suppliers abide by applicable local laws, including laws related to labor practices, health and safety, environmental sustainability, anti corruption and anti-bribery, and brand protection. In addition, the Kellwood Supplier Manual for Social Responsibility and Code of Conduct specifically state that all suppliers must adhere to both the guidelines therein and country labor laws, whichever are stricter. Democracy Clothing specifically monitors for forced labor in our pre-production assessment of all vendor partner factories. If there are any findings, we end any relationship or potential relationship with the supplier. Democracy Clothing also includes similar requirements in its Purchase Order Terms and Conditions and other service agreements. Democracy Clothing sends periodic communications to suppliers making them aware of new laws or revisions to existing laws as appropriate.
Maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Democracy Clothing expects all employees and contractors to adhere to Kellwood’s Code of Conduct, which includes information related to our hiring practices. Human Resources is responsible for ensuring that all employees are aware of and adhere to the Kellwood Code of Conduct, and addresses any incidences where an employee or contractor does not do so.
Training on human trafficking and slavery for company employees and management who have direct responsibility for supply chain management.
All Democracy Clothing employees responsible for supply-chain-related decisions are required to complete a training and assessment that ensures their knowledge of identifying and addressing human trafficking and slavery in Democracy Clothing direct supply chains. Further, Democracy Clothing conducts focused employee education in order to mitigate labor and compliance risks within our direct supply chain and will continue to raise their awareness of this issue through regular trainings, information posted on the company's internal websites and communications sent to employees.
