Supplier Code of Conduct
This Code of Conduct applies to all suppliers and factory partners that produce goods for Cole Haan or any of its subsidiaries, divisions, affiliates or agents. This Code sets forward the basic requirements that all factories must meet in order to do business with Cole Haan. The Code is based on internationally accepted labor standards, including International Labor Organization (ILO)’s core conventions, the Universal Declaration of Human Rights, SA8000 and the Footwear Distributors and Retailers of America Code of Conduct. The Code provides the foundation for Cole Haan’s ongoing evaluation of a factory’s labor practices and compliance.
A. BUSINESS INTEGRITY + TRANSPARENCY
Cole Haan is committed to working with suppliers and factory partners who are open and honest with us, and believes that transparency is the foundation for true collaboration and partnership. Business must be carried out with a high degree of ethics, honesty and fair dealings; ensuring staff is familiar with the Cole Haan Code of Conduct, Anti-Corruption Policy, and Code of Ethics, and does not engage in threats, bribery or corruption practices. Suppliers and factory partners shall maintain complete, as well as accurate records and information so that compliance can be effectively assessed. Suppliers and factory partners must not falsify or understate any aspects of their operations to Cole Haan or their appointed representatives. Suppliers must not coach employees on how to answer questions or respond to inquiries by Cole Haan or their appointed representatives.
B. COMPLIANCE WITH THE LAW
Cole Haan requires all suppliers and factory partners to comply fully with national and local legal requirements and regulations, at a minimum. Suppliers shall also comply with industry standards and the requirements of this Code. In cases where these requirements are inconsistent, suppliers shall comply with the provisions that are most protective of workers.
C. MANAGEMENT SYSTEMS
Suppliers and factory partners shall have effective management systems in place to proactively identify and sustainably address compliance issues in their facilities. This includes management commitment and support, policies and procedures, communications and training, grievance systems, regular internal assessments, management review and continual improvement.
Suppliers and factory partners must commit to upholding the human rights of workers, to treat them with dignity and respect, and to improve working conditions within their supply chain. Special consideration should be given to the rights of those most vulnerable to abusive labor practices, such as young workers, women, homeworkers, agency workers, temporary workers, migrant workers and smallholders.
D.1. Forced and Compulsory Labor
Suppliers and factory partners shall not engage in or support the use of forced or compulsory labor, including prison labor and human trafficking.
D.2. Freedom of Association and Collective Bargaining
Suppliers and factory partners are expected to respect the rights of workers to freely and peacefully associate and collectively bargain. Suppliers and factory partners shall not harass or intimidate workers who wish to join unions and participate in legitimate union activities. Workers should be free not to join in unions as well.
D.3. Child labor
There must be no recruitment of “child labor.” Child Labor is defined as any work by a child under the age of 15, or the minimum working age set by local law, whichever is greater. There must be no recruitment of “young persons” who meet the standards of the minimum working age but are between the ages of 15 and 18 for work duties which do not comply with the provisions of the relevant International Labor Organization (ILO) standards. Production facilities must comply with all local laws and ILO standards regarding the working conditions and restrictions for “young persons,” also known as “juvenile workers.”
D.4. No discrimination
Suppliers and factory partners shall not engage in, support or tolerate discrimination in employment including recruitment, hiring, training, working conditions, job assignments, pay,
benefits, promotions, discipline, termination or retirement on the basis of gender, age, religion, marital status, race, caste, social background, diseases, disability, pregnancy, ethnic and national origin, nationality, membership in worker organizations including unions, political affiliation, sexual orientation, or any other personal characteristics.
D.5. Wages and benefits
Suppliers and factory partners are expected to ensure that wages for a normal work week, not including overtime, shall always meet at least legal or industry minimum standards, or collective bargaining agreements (where applicable).
D.6. Working hours
Suppliers and factory partners are expected to adhere to all local and national laws governing working hours. Suppliers and factory partners are expected to not exceed 60 working hours in a given week and provide one day off for every seven-day period. Overtime must be on a voluntary basis and shall not be demanded on a regular basis and shall be compensated at a premium rate as stipulated by local laws.
D.7. Regular employment
Work performed must be on the basis of a recognized employment relationship established in compliance with national legislation and practice and international labor standards, whichever affords the greater protection.
D.8. No harsh or inhumane treatment
Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.
E. WORKING CONDITIONS
E.1. General Health and Safety
A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards.
E.2. Building + Machine Safety
The structure of the supplier or factory partner, including residential facilities provided by the supplier or factory partner, is stable and safe and does not put people in jeopardy.
E.3. Emergency/Fire Preparedness
Supplier or factory partner communicates fire and emergency evacuation plans and posts the diagrams in the local language in various locations around the production unit. Designated supplier or factory partner personnel (workers and supervisors) are trained at regular intervals in fire safety, the use of fire extinguishers, and how to administer the fire prevention procedures and emergency evacuation plan.
In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public. At a minimum, this includes meeting all relevant local and national environmental protection laws.
Suppliers and factory partners may not subcontract any operation in the manufacturing process without prior written consent from the factory’s customer, and only after the subcontractor has agreed to comply with the Cole Haan Code of Conduct. Suppliers and factory partners are responsible for ensuring compliance with the Cole Haan Code of Conduct by all approved subcontractors including but not limited to: tannage stabilization, converting to crust, embossing, weaving, finishing, lasting, bottoming, cutting, sewing, embroidery, printing, laundry/washing, dry processing, garment dyeing, panel knitting, final assembly/packing.
H. COMPLIANCE WITH THE COLE HAAN CODE OF CONDUCT
Cole Haan reserves the right to conduct announced and unannounced inspections of all suppliers and factory partners. Any violations will be reported to the supplier or factory partner for follow up and corrective action. Suppliers and factory partners are required to cooperate with the entire process. Where there are repeated, systematic, and/or egregious violations, such as child labor, blatant forced or prison labor, bribery and physical abuse; systematic or repeated violations that demonstrate the production unit’s inability or unwillingness to comply, Cole Haan member companies reserve the right to discontinue business with the supplier or factory partner.