Risks of Modern Slavery In Your Sector: Apparel

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Apparel

Risks of Modern Slavery in Your Sector

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[email protected] / www.assentcompliance.com / 1 866 964 6931 / © Assent Compliance 2016Confidential and Proprietary to Assent Compliance. © 2015 Assent Compliance Inc.

Today’s Moderator

Madison AdamsAssent ComplianceCompliance Services

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INTRODUCTION







Assent Product SuitesOur Market Leading Platform

Ethical Sourcing

Materials Management

Supplier Information Management

InspectionsConfigurable Surveys & Declarable Substance

Lists

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Today’s Presenter

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Sarah CarpenterAssent ComplianceBusiness & Human Rights Analyst







Webinar Series Details

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November 3rd10 AM EDT

Apparel with Fair Wear Foundation

November 8th1 PM EST

Food & Beverage with Oxfam America

December 2016

Electronics

December 2016

Jewelry







Agenda

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[email protected] / www.assentcompliance.com / 1 866 964 6931 / © Assent Compliance 2016 7

Introduction to Modern Slavery

Snapshot of Modern Slavery in Apparel Sector

Challenges Faced by Apparel Companies

Preventing & Mitigating Risk

Case Study












Organization Overviews

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Assent Compliance provides best-in-class compliance solutions that help organizations with their global, environmental and human

rights compliance strategies.

The Fair Wear Foundation is active in 11 production countries in Asia, Europe and

Africa. It works with more than 80 member companies representing over 120 brands to improve labor conditions

for garment workers worldwide.







IntroductionModern Slavery







Modern Slavery: Definition

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MODERN SLAVERY

Slavery ServitudeForced

& Compulsory Labor

Human Trafficking







45.8 million people

Modern Slavery: In Numbers

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Supply chains provide fertile ground for modern slavery conditions to arise

International Labour Organization:Global Slavery Index:

living in modern slavery (2016)

21 million victimsof forced labor (2012)







Modern Slavery: By Country

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Source: The Global Slavery Index (2016)

58 percent of those living in slavery are located in five countries

Top Five Countries (Proportion of Population):

North Korea: 4.37% - Uzbekistan: 3.97% - Cambodia: 1.65% - India: 1.4% - Qatar: 1.36%







Anti-Human Trafficking Laws: New & Stronger

◆ Amended FAR Rule on Combating Trafficking in Persons (52-555-50) - 2015

◆ UK Modern Slavery Act - 2015

◆ California Transparency in Supply Chains Act - 2012 (compliance sweep in 2015)

◆ U.S. Trade Facilitation and Trade Enforcement Act - 2016

◆ More to come: EU Directive on Non-Financial Reporting and others

Why Now?

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NGO Scrutiny, Investigative Journalism, Strategic Litigation

Why Now?

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Today’s Partners

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Suhasini SinghFair Wear Foundation Country Representative - India

Lisa SüssFair Wear Foundation Country Coordinator - India







Feature PresentationModern Slavery in the Apparel Sector







Forced Labor

Forced labor refers to situations in which persons are coerced to work through the use of violence or intimidation, or by more subtle means such as accumulated debt, retention of identity papers or threats of denunciation to immigration authorities.

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Nomenclatures

Forced labor, contemporary forms of slavery, debt bondage and human trafficking are closely related terms though not identical in a legal sense.

Most situations of slavery or human trafficking are, however, covered by ILO's definition of forced labor.

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Indicators of Forced Labor

◆ Abuse of vulnerability

◆ Deceptive recruitment practices

◆ Restriction on movement, isolation

◆ Physical and sexual violence

◆ Intimidation and threats

◆ Retention of identity documents

◆ Withholding of wages

◆ Debt bondage

◆ Abusive working and living conditions

◆ Excessive overtime







FWF Code of Labor Practices







FWF Code of Labor Practices Continued







Forced Labor In the (Indian) Garment Industry

◆ Forced overtime (average 2 hours/day)

◆ Paid at single rate or not paid if production target not reached

◆ Restriction of freedom of movement in hostels in the south

◆ Limited choice of where to work as inter-state migrants contractor or the intermediary assign them to garment factory or textile mill

◆ Sumangali (like) schemes







Sumangali (like) Scheme - Key Features

◆ Young women between the age of 15 and 18

◆ Mostly in spinning mills in Tamil Nadu

◆ Fixed term labor arrangements, usually 3-5 years

◆ Lump sum payment only after the completion of tenure

◆ Workers live in hostels controlled by factory management







Situation Of Workers Hired Under Sumangali (like) Schemes

◆ Denial of minimum wage and withholding wage◆ Poor working conditions (noise, pollution, no safety equipment,

excessive overtime)◆ Unhygienic and unsafe living conditions ◆ Deceptive recruitment◆ Sexual harassment







Key Challenges On the Ground

◆ Poverty, inequality and discrimination◆ Illiterate or semi-literate workers, language barrier◆ No unionization, powerful employers’ association◆ Poor implementation of international/national laws◆ Perpetrators are rarely prosecuted







Key Challenges In the Supply Chain

◆ Diverse and complex supply chain◆ Sourcing from unlicensed factories◆ Confinement of workers in hostels,

hence invisible◆ Forced labor in second or third-tier

factories







What Brands Can Do

◆ Get to know your supply chain◆ Create awareness◆ Set up functioning grievance mechanisms◆ Participate in multi-stakeholder action







Case Study: Tirupur

Situation in 2013◆ Young female migrant workers living in hostels, many below 18◆ Had been unable to leave the hostel for three months◆ No mobile phones, permission of warden needed for payphone calls◆ Home visits only allowed every six months◆ Limited access for relatives◆ Excessive overtime, paid at single rate◆ Some workers showed self-harming behavior◆ Factory management: Parents of the migrant

women requested the factory to keep them safe







Get To Know Your Supply Chain◆ Visit suppliers including spinning mills and subcontractors at least annually◆ Include hostels and subcontracting sites in monitoring◆ Work with audit partners that conduct off-site worker interviews by local

auditors that have been trained on gender and forced labor







Create Awareness & Collaboration

◆ Inform your supplier about your understanding of forced labor and that such practices violate your Code of Conduct

◆ Provide information and trainings to workers and management on labor rights and grievance mechanisms

◆ Bridge possible language barriers◆ Ensure suppliers that you will not withdraw orders in case of

complaints or non-compliances







Set Up Functioning Grievance Mechanisms

◆ Cooperate with local NGOs or unions◆ Ensure that (internal) grievance mechanisms

like unions, democratically-elected anti-harassment committees or worker committees are available

◆ Set up an external complaint hotline as a safety net and ensure access to phones







Participate In Multi-Stakeholder Action

◆ Collaborate with other customers ◆ Join or co-found regional partnerships◆ Engage with stakeholders including government◆ Inform the government that you expect national/regional legislation to reflect

international standards and that existing legislation is enforced







Case Study: TirupurSituation in 2016◆ Anti-harassment committee has been established◆ Complaints are reported and resolved◆ Nine payphones installed, committee members have mobile phones◆ Workers can take their leave any time◆ Relatives can visit any time◆ Overtime has been reduced and is paid at double rate◆ Workers receive their payments monthly

in a bank account◆ Workers are taken out once a week and

on regular excursions◆ Other outings have to be registered with

a female warden







[Webinar] Risks of Modern Slavery In Your Sector: Food & Beverage with Oxfam AmericaTuesday, November 8th | 10AM EDT

Upcoming Educational SummitsNovember 17, 2016 | BostonFebruary 8, 2017 | San Jose

Restricted Substance & Product Compliance ForumDecember 1, 2016 | Chicago

Upcoming Events: Webinars & Conferences

Learn more about Assent events:www.assentcompliance.com/events

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http://www.assentcompliance.com/events




Q&A Discussion

Questions?

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