Statement Under the California Transparency in Supply Chains Act of 2010 (SB 657)
PVH Corp., one of the world's largest apparel companies, owns and markets the iconic Calvin Klein and Tommy Hilfiger brands worldwide. We are the world's largest shirt and neckwear company and market a variety of goods under our own brands, Van Heusen, Calvin Klein, Tommy Hilfiger, IZOD, ARROW, Bass and G.H. Bass & Co., as well as numerous nationally and internationally known brands we license from third parties.
Central to our identity is a genuine commitment to corporate social responsibility - CSR. For over 100 years, our credo has been to conduct all business in keeping with the highest moral, ethical and legal standards. CSR is a fundamental component of how we run our business and is directly linked to our strategies and practices. We continually move toward increased transparency and accountability to the public and report on our CSR efforts, performance and vision for the future. We invite you to visit our online CSR report at pvhcsr.com to learn more.
We were one of the first companies to publish a code of conduct regarding workers rights and working conditions when our A Shared Commitment (PDF) was initially published in 1991. Our commitment to our workers and workers in our supply chain was further evidenced when we became a founding member of the Apparel Industry Partnership in 1996, which has been succeeded by the Fair Labor Association ("FLA"), of which we continue to be a member in good standing. In taking this leadership role and making this commitment to human rights and compliance with labor laws, we have aligned the requirements for doing business with us with the Universal Declaration of Human Rights, International Labor Organization's ("ILO") Core Conventions and the United Nations Framework on Business and Human Rights. More directly, the FLA has an accreditation program that is an independent external verification of each member's human rights program's compliance with the FLA's Workplace Code of Conduct. The FLA's Workplace Code of Conduct is a global set of principles based on the ILO's standards for working conditions in factories. Accreditation takes place every three years and we have been accredited by the FLA since 2005.
It is within this framework that we make this statement under the California Transparency in Supply Chains Act (SB 657), which requires us to disclose our efforts to eradicate slavery and human trafficking from our direct supply chain for the products we sell.
How we assess the risk of human trafficking and slavery in our product supply chain. We source and purchase substantially all of the products sold by our wholesale and retail businesses. Suppliers of these products must agree to our A Shared Commitment code of conduct requirements, disclose all factories intended for production of our goods, and submit to compliance audits. The audits, which are typically conducted by members of our Global Human Rights and Social Responsibility Department but may also be conducted by reputable third party auditors identified and managed by the Department, necessarily include investigation of terms and conditions of employment that are designed to verify the risks and uncover the existence of human trafficking, slavery or other forms of compelled employment and lack of freedom.
How we audit for compliance with our A Shared Commitment code of conduct. We require that all factories intended for production of our goods be audited for compliance with our A Shared Commitment code of conduct prior to the commencement of production. These audits are typically conducted by members of our Global Human Rights and Social Responsibility Department but may also be conducted by reputable third party auditors identified and managed by the Department. All factories are re-audited every 12 - 18 months. Initial audits are typically announced, while follow-up audits are typically unannounced.
We ensure that the vendors used by our suppliers in manufacturing our products comply with our A Shared Commitment code of conduct through auditing; we are implementing a program for our suppliers to certify that the materials used in the manufacturing of our products are produced in compliance with the code. Our A Shared Commitment code of conduct requires our suppliers to ensure that the vendors they use in manufacturing our products comply with the code, including in respect of human trafficking and slavery. Direct suppliers are evaluated for compliance with this aspect of the code though our audits of the suppliers, as well as our audits of their vendors and suppliers. With respect to the materials used in the manufacturing of our products, we are implementing a certification program for our suppliers. Under this program, our suppliers will be required to certify that the materials were produced in compliance with the requirements of the code.
We maintain and rigorously enforce internal accountability procedures for employees and contractors regarding our A Shared Commitment code of conduct, including standards with respect to slavery and human trafficking. Our Human Rights program includes a Sustainable Compliance Initiative for purposes of remediating violations of our Shared Commitment code of conduct that our audits uncover. This permits us to examine the specific situation and develop a best possible strategy for resolution. It also enables us to serve the interests of the workers best by aiding in the development of a safe, legal and respectful workplace. If cases of non-compliance are not resolved, or at least substantially addressed, within a specified time frame, we will terminate the business relationship. With respect to the most egregious cases of code violations, we will terminate the relationship immediately and report the situation to the appropriate authority. This would be the case if we were to uncover a situation involving slavery and human trafficking.
Internally, we have extensive policies, practices and procedures that encompass the requirements of our A Shared Commitment code of conduct and ensure compliance with the standards set forth therein. This includes a constant and vocal commitment of management (starting with our CEO) to the full array of workplace issues; in-house training programs for all associates, as well as additional training for our Human Resources and management teams; reporting hotlines; audits of facilities we acquire; and safeguards in the workplace and hiring process that also serve the purpose of enabling us to identify violations, including human trafficking and slavery, were they to occur. It is clear that our commitment to human rights standards would result in the severest discipline on any employee or contractor who engaged in, facilitated or allowed forced labor, human trafficking or slavery to exist in any of our own facilities.
We conduct training on our A Shared Commitment code of conduct, including with respect to human trafficking and slavery, with a particular focus on mitigating risks. The associates in our Global Human Rights and Social Responsibility Department and Global Sourcing division are trained on our A Shared Commitment code of conduct, as is management at our suppliers, in order to ensure the necessary participants in supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain. Our associates also participate (both as speakers and attendees) in external training programs and seminars on social compliance issues, including on the issues of human trafficking and slavery.
Corporate Social Responsibility
Central to our identity is a genuine commitment to corporate responsibility, a fundamental component of how we run our business that is directly linked to our strategies and practices.