PVH is committed to eliminating hazardous chemicals from our products and
manufacturing processes, a goal we first pledged in 2011, which is in line with our
historical commitment to corporate social responsibility (“CSR”). In order for this ambitious
phase-out of hazardous chemicals to be successful, we believe we must engage and
collaborate with other leading brands and stakeholders, including materials suppliers, the
chemical industry, NGOs, regulators and others.
To further our commitment, we have joined the Zero Discharge of Hazardous Chemicals
(“ZDHC”) Programme, a global coalition of leading international brands in the apparel
and footwear sector. ZDHC’s mission is to transform the global apparel and footwear
industry by improving environmental performance and chemical safety, thereby
delivering a safer and cleaner environment, with the ultimate goal of achieving zero
discharge of chemicals in our product life cycle by 2020. Several guiding principles
underlie this mission, including the Precautionary Principle1
, systemic change (e.g., broader societal and policy change) and the Right to Know Principle2.
Our membership in ZDHC is one step in our commitment to zero discharge. We are
implementing a chemical elimination strategy which, by 2018, we expect will lead to the
elimination of alkylphenol ethoxylates (“APEOs”) and perfluorocarbons (“PFCs”) from our
supply chain and accelerate the move to non-PFC technologies.
We also recognize the importance of disclosure and transparency in relation to
hazardous chemicals in the supply chain. Therefore, we will share information in line with
the Right to Know Principle, including public disclosure of our Restricted Substances List
(“RSL”), our audit processes and information about the hazardous chemicals in our supply
chain. We will be sharing our progress to achieve our goals on www.pvh.com and in our
annual CSR report (www.pvhcsr.com).
We acknowledge that our zero discharge commitment will require long-term dedication and allocation of resources. The action plan detailing our strategy is set forth below.
PVH Chemical Management Action Plan
Taking into account the commitment above, PVH has developed the following action plan, which outlines the steps we will take as we work toward achieving zero discharge of hazardous chemicals from our products and manufacturing processes by 2020.
Our action plan is inspired by ZDHC’s Joint Roadmap Version 2 (“the Roadmap”) (published June 2013)3. It is grounded in science and addresses the diverse and complex realities, inherent in global apparel industry supply chains. Our action plan is designed to comply with the requirements and timelines as outlined in the Roadmap.
PVH Achievements to Date:
- PVH’s long-standing code of conduct (“A Shared Responsibility”) requires our business partners to comply with all applicable social and environmental laws, rules and regulations at their facilities and in the communities in which they operate, particularly with respect to water, energy, hazardous chemicals, air quality and waste.
- We have a comprehensive compliance program, which requires suppliers to comply with all applicable environmental and regulatory laws. Key activities include:
- Regular and detailed communications to suppliers on RSLs, conflict minerals, European Community Regulation (“REACH”), the U.S. Consumer Product Safety Improvement Act, and other regulatory matters;
- Training programs;
- Attestations; and
- Detailed supplier agreements that include, among other things, requirements on environmental issues.
- We have developed a comprehensive Global Product Stewardship function that is responsible for chemical management across all business operations. We will continue to grow this effort in the near future through strategic hires.
- We created a unified RSL for the Company, which was made public on August 9, 2013, along with our PVH Chemical Management Commitment and Chemical Management Action Plan.
- We are a member of, and have taken an active leadership role in, the Global Social Compliance Programme (“GSCP”) since 2010, a business-driven program dedicated to improving the working and environmental conditions in global supply chains.
- We are a member of the Apparel and Footwear International RSL Management group (“AFIRM”) and have been collaborating with other industry brands to advance the global management of restricted substances within our supply chain.
- We conduct social audits of our suppliers. These audits include environmental parameters, as well as RSL-related questions to facilitate ownership of, and compliance with, RSL policies.
- We conduct screenings of Substances of Very High Concern in compliance with REACH legislation of 2009 (as updated in 2011).
- We have chemical testing programs in place today; however, these will be aligned and rolled-out consistently across all businesses and operations in 2014.
- The dress shirts we sell in North America are Oeko-Tex certified, indicating they are
free from harmful substances. The Oeko-Tex certification is a globally uniform
testing and certification system, which contains more than 100 testing parameters
for textile raw materials, intermediate and end use products at all stages of
Detailed Implementation Steps:
Restricted Substances List
We have been working to create one global RSL across all our businesses and operations,
which will be aligned with industry best practices and published along with our Chemical
Management Commitment and Chemical Management Action Plan. We are committed
to a process of continuous improvement and will expand and/or amend our global RSL
regularly as needed.
Priority Chemical Phase-Out
Based on ZDHC’s list of 11 prioritized chemical categories, we will conduct a pilot study in
2014 in China and Bangladesh to determine whether these chemical categories are
present in our supply chain through on-site visits, audits, inventories and other means. We
will develop an action plan to phase out any of the 11 chemical categories which might
be found during the pilot study. We will draw on research available through ZDHC and
industry peers to either eliminate or substitute these hazardous chemicals as available.
We will communicate to our suppliers our expectation to eliminate APEOs and PFCs. We
will also enhance both the training and auditing of our supply chain partners in
conjunction with other global brands, as well as ensure our suppliers have the latest
available information concerning APEOs and PFCs.
We are committed to the increased engagement of our suppliers, with regard to
chemical management, as true partners in the process. We will create and roll out a
global chemical management training and capacity-building program for our vendor
base, as well as our internal stakeholders (Design, Merchandising, Product Development,
and Supply Chain), drawing upon the common training program currently in
development through ZDHC. This chemical management training program will be rolled
out to at least 50 percent of our vendor base by 2015.
Assessment and Auditing
In conjunction with ZDHC, we will develop and roll out a Generic Environmental Audit
Protocol and Dyehouse Audit Protocol, which will include chemical management and
options to share supplier results. Furthermore, the Protocols will ensure the necessary
harmonization needed for success of our environmental efforts in the textile supply chain.
The roll out of the Protocols will take place by 2015.
We support the guiding principle of Right to Know, including practices that allow public
access to environmental information. We are committed over the long term to develop a
framework for data disclosure to monitor progress and agree on a performance rating
system to be applied to suppliers. We will deliver a report based on data collection from
a selected group of pilot facilities. Stakeholder dialogues with reference to disclosure are
already in progress, and further opportunities to develop a comprehensive disclosure
process will be identified in the near term.
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