California Transparency in Supply Chains Act of 2010

In September of 2010, the state of California enacted legislation requiring all companies doing business in the state to disclose information on the actions being taken to address the risks of human trafficking and slavery in their global supply chains. Shown below are Carhartt WIP's responses to the five required disclosures outlined in the legislation:

VERIFICATION

All factories producing goods for Carhartt WIP are required to comply with the Company's Workplace Code of Conduct, which includes a specific prohibition of forced labor, which includes involuntary, prison or trafficked labor or labor otherwise obtained by force, fraud or coercion -- indentured, bonded or otherwise. These expectations extend to all Carhartt WIP suppliers. Suppliers to Carhartt WIP are expected to extend these standards to all of their suppliers and to initiate practices to assure that these standards are adopted throughout the global supply network supporting Carhartt WIP. Verification takes place through a two-pillar approach that involves a combination of 3rd party certification audits (e.g. WRAP, BSCI, Better Work, etc.) and Onsite Verification Assessments from Carhartt WIP’s Global Social Responsibility Team. More information on Carhartt WIP’s two-pillar approach can be found in Carhartt WIP’s Global Social Responsibility Supplier Manual: https://www.carhartt-wip.com/en/service/csr/where-its-made?tag=csr

AUDIT

Social audits are conducted by reputable third-party assessment firms and are typically unannounced within a 15 to 30-day window. These audits evaluate present factory conditions as well as the policies, procedures and management systems that are necessary for ongoing compliance. Carhartt WIP’s Onsite Verification Assessments are conducted by Carhartt WIP’s Global Social Responsibility team (or contractors hired to act as representatives for Carhartt WIP) and use a combination of announced and unannounced visits. These assessments are used to verify the information in the social audits, assess the factory’s overall compliance to Carhartt WIP’s requirements, and work directly with factories on any needed improvements.

CERTIFICATION

Carhartt WIP's Workplace Code of Conduct requires all suppliers to comply fully with all local laws, including those related to slavery and human trafficking. In the event local laws are not robust, Carhartt WIP's Workplace Code of Conduct further prohibits suppliers from using "involuntary, prison or trafficked labor or labor otherwise obtained by force, fraud or coercion -- indentured, bonded or otherwise." Suppliers certify that they understand and comply with these expectations before starting Carhartt WIP production and periodically thereafter.

INTERNAL ACCOUNTABILITY

Internal accountability resides with the leadership of the core business functions responsible for the relevant commercial relationships - e.g., the Sourcing function for all relationships with cut and sew suppliers, Product Development with raw material suppliers and Corporate Responsibility for defining, managing and coordinating the process.

If any supplier is found to be out of compliance with Carhartt WIP's Code of Conduct, appropriate remedial actions are taken. While we prefer to work with suppliers to achieve improved conditions, violations involving human trafficking or slavery are classified as "zero tolerance" issues that must be immediately corrected with long-term corrective actions implemented (approved and monitored by Carhartt WIP) or Carhartt WIP would terminate the contractual relationship.

TRAINING

Carhartt WIP has conducted several trainings on the company's Supplier Workplace Code of Conduct and complementing Supplier Social Responsibility Manual  - including provisions related to human trafficking and forced labor. Individuals completing this training include supply chain leadership through the manager level in Sourcing and Quality Assurance activities.