Over the past decade, governments have enacted legislation requiring companies to disclose their efforts to eradicate human trafficking and slavery from their supply chains. We see this as a positive trend: propelling companies towards transparency, something we at EILEEN FISHER continue to work on within our supply chain. We are committed to building more transparency into our broader human rights approach and recognize that this is a long-term effort requiring continuous attention. This statement is issued in response to the reporting requirements of the California Transparency in Supply Chains Act of 2010 (SB 657) and the United Kingdom Modern Slavery Act of 2015. We agree with the intent behind these acts, and believe wider government action is needed for meaningful change to take place.
Human trafficking is a form of slavery that can include forced labor, debt bondage and sex trafficking. An egregious violation of human rights, human trafficking and slavery exist in every country, with nearly 25 million victims worldwide. EILEEN FISHER has long believed that our company’s continued success and growth should be based on doing the best for our employees and, by extension, the people who manufacture our products. At the heart of this belief is the commitment that every person in our company and supply chain is employed at her or his own free will and that she or he has a voice.
How is EILEEN FISHER taking action?
Founded in 1984, EILEEN FISHER INC. is a privately owned women’s apparel company headquartered in Irvington, New York, with nearly 1,000 employees working in the United States, Canada, and the United Kingdom. Our products are sold through company-owned retail stores and our e-commerce website, as well as through global wholesale department stores, boutiques and licensees. In 2019, our supply chain partners included 42 finished garment suppliers—15 of which account for 80% of our products.
As a certified B Corp and a Benefit Corporation, we have a strong commitment to both women and human rights. Over the years, we have communicated this commitment to our manufacturing partners globally. However, we know that conditions that can lead to human rights abuses can exist in very subtle forms, such as the withholding of identity or travel documents and excessive recruitment fees. Therefore, we have made a company commitment to try to eliminate the root causes that could lead to human trafficking and slavery in our supply chain. We accomplish this through: policies and governance; risk assessment, audits and verification; and awareness raising.
Policies & Governance
We have been building our human rights program since 1997, and are committed to the SA8000 standard. Forced labor is a major element of SA8000. We believe that employment should be freely chosen and that none of our suppliers should engage in or support the trafficking of human beings. We are committed to doing everything possible to prevent any conditions in our supply chain that could contribute to human trafficking or forced labor, and we expect our suppliers to take serious action to ensure that these violations do not occur in their supply chains. We have communicated this commitment to suppliers through our Social and Environmental Implementation Guide (SEIG), and require our suppliers to sign a Statement of Commitment to confirm their receipt of and their agreement to comply with the SEIG. Should we discover that our suppliers are in violation of this commitment, we will engage them in a remediation process as outlined in our Forced Labor & Human Trafficking Remediation Policy in the SEIG. We always prefer to work with our suppliers on remediation, but reserve the right to end our relationship if satisfactory remediation is not possible within a reasonable timeframe. The SEIG was originally developed in 2016 in consultation with Verité and Social Accountability International, and we are in the process of updating its content.
Risk Assessment, Audits & Verification
We have been utilizing independent, third-party reviewers to conduct social audits in our supply chains. Audits are conducted on an announced or semi-announced basis; unannounced audits will be used when necessary. We have also utilized worker mobile phone surveys to collect worker sentiment data as a way of detecting forced labor. If any areas of concern are identified during an audit or survey, we expect suppliers to develop an improvement plan to address such issues within 30 days of receiving an audit report, unless more immediate action is required. Improvement plans must list the actions the supplier will take to remedy the issue, along with target completion dates. The supplier is responsible for providing EILEEN FISHER with a status update at each target completion date identified in the improvement plan. If the supplier needs guidance in developing an improvement plan, EILEEN FISHER will act as a resource.
Over the last three years, we have verified the social and labor practices of nearly all of our finished garment suppliers through third-party audits. Through audits and worker surveys, we monitored 17 finished garment facilities in 2019. Combined with the facilities that were audited in 2018, a total of 39 suppliers have been evaluated, representing 94.75% of our total units produced for 2019. To date, we have not found evidence of human trafficking or slavery in our supply chain. In 2020, we started to ask our suppliers to complete the Higg Facility Social & Labor Module and will use this as a tool for collecting social data going forward.
EILEEN FISHER is a Buyer Partner of Better Work, a partnership between the International Labour Organization (ILO) and the International Finance Corporation (IFC) that brings together governments, employers, workers and international buyers to improve compliance with labor standards and promote competitiveness in global supply chains. Better Work and Buyer Partners engage strategically with both the Better Work Programme and with related stakeholders to drive change within the industry. Buyer Partners commit to the principles of Better Work, including promoting the implementation of Decent Work, transparency, collaboration and accountability. Buyer Partners also actively work to engage their supply chains in participating countries, where Better Work provides assessment, advisory and training services to registered suppliers to improve workplace conditions. Better Work offers suppliers a transparent and credible way to provide buyers with information about compliance and improvements. Through the Better Work Buyers' Forums, at the national and international levels, Buyer Partners can come together to discuss challenges to compliance with labor standards and help identify innovative solutions.
We believe that it is our responsibility, not just our suppliers’, to certify that raw materials incorporated into our products are not tainted by human trafficking and slavery. Information is collected each season from our suppliers to further understand our supply chains and to help identify potential human rights issues prior to production. Our Social Consciousness Team works closely with our Design Team and Supply Chain Management Team to incorporate ethical sourcing into our fabric and yarn approval process and engage our mills on social and ecological topics. In 2019, we conducted a Social Life Cycle Assessment on our finished garment and raw materials supply chains to identify social hot spots in order to further inform our future raw materials strategy.
Cotton is an important fiber to us, but one that is fraught with human rights abuses around the globe. As a company, we are a signatory to the Responsible Sourcing Network’s Cotton Pledge to not knowingly source cotton from Uzbekistan and Turkmenistan. We are also a signatory of The Coalition to End Forced Labor in the Uyghur Region, and have committed to exit the Xinjiang region at every level of our supply chain, from cotton to finished products within a year. Until there is clear evidence of change in these regions, our ban on cotton from these regions will continue to be a core policy. If cotton from one of these regions is found, our suppliers must work with us to identify an alternative from ethical sources, or they will risk losing our business. We do not source finished garments or fabrics from suppliers located in the Xinjiang region. Recently, we conducted further due diligence to understand our indirect risks in Xinjiang based on the guidance in the Center for Strategic and International Studies report. We are working diligently on addressing these indirect risks.
Our company leadership, employees and supply chain partners were trained on the subject of human trafficking and slavery when the California Transparency in Supply Chains Act (SB 657) went into effect in 2012. Since then, our human trafficking and slavery efforts have been incorporated into our risk assessment, audits, verification processes and sourcing strategy. Our Social Consciousness Team continues to keep our company leadership and key internal partners updated as new information becomes available on the subject.
We have long been aware of human trafficking and how it adversely affects the lives of the victims and their families. As a small company, we realize that our impact is limited by our size. We understand the need to engage with civil society for meaningful change. Through our philanthropic activities, we have funded various nonprofit organizations working on this issue at the grassroots level. Since 2018, we have been partnering with the Uyghur Human Rights Project, supporting the organization on documentation of abuse, advocacy, emergency rescue and humanitarian relief.
How can you take action?
As a consumer, you can help prevent human trafficking and slavery worldwide by supporting companies who responsibly manage their supply chains. Everyone has a role to play to end this egregious human rights violation—governments, businesses, international organizations and consumers.
Human trafficking and slavery are often invisible to people who do not look carefully. If you think you might have known or seen a victim of human trafficking, there are actions you could take to help him or her. Please click here (https://humantraffickinghotline.org/) to learn how you could help identify and assist victims of human trafficking.
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