CA Supply Chain
Reformation’s Statement of Compliance with
California Transparency in Supply Chains Act (SB 567)
LYMI Inc. dba Reformation (“Reformation” or “we”) fully supports California’s efforts to protect human rights and enforce ethical labor practices under the California Transparency in Supply Chains Act of 2010 (SB 657).
Human trafficking, also known as modern-day slavery, is a form of slavery that can include forced labor, bonded labor, sex trafficking and domestic servitude. The International Labour Organization (ILO) estimates indicate that an estimated 24.9 million people are subject to forced labor globally. Modern slavery takes many different forms that can be hard to see. Even if an organization supports anti-slavery practices, the lack of a well-regulated supply chain can leave it open to the use of forced labor. This is why we see transparency, traceability of our supply chains and accountability as the only way of doing business. Reformation believes modern slavery and human trafficking are egregious violations of human rights and we are deeply committed to doing our due diligence to minimize, detect and remediate forced labor and human trafficking within our supply chain.
Reformation has adopted a Supplier Code of Conduct which requires that our direct suppliers do not engage in or support forced labor or unlawful child labor. We are committed to ensuring that working conditions in our supply chain are safe, that workers are treated with respect and dignity, and that manufacturing processes are environmentally and socially responsible. Additionally, we expect our suppliers to adopt and maintain terms of employment for their employees that comply with local law and the requirements of our Supplier Code of Conduct. The following are actions we take to prevent the use of modern-day slavery and forced labor in our supply chains:
Evaluation and Verification of Supply Chain
Our Sustainable Partners Guidebook outlines our standards and expectations for partners, provides resources, and outlines how we will support our suppliers in achieving our standards and moving beyond compliance. Reformation’s Supply Chain and Sustainability teams engage in Tier 1 Supplier (manufacturing units, vertically integrated factories, and any subcontractors) evaluations and verifications to address risks of human trafficking and slavery in the supplier’s operations, in addition to assessing the supplier’s quality, environmental, human resources and security standards. These evaluations and verifications are a standard part of pre-contract due diligence. Once approved, the supplier must contractually commit to meeting the standards set by Reformation or be subject to restrictions or termination of their contractual relationship with us.
Our Supplier Code of Conduct and benchmarks reference the FLA Workplace Code of Conduct and Compliance Benchmarks which are based on International Labor Organization (ILO) standards and internationally accepted good labor practices that we require all our direct cut, sew & finish manufacturing partners to adhere to. Reformation also includes provisions in its contractual agreements mandating that suppliers comply with the Supplier Code and disclose any non-compliance issues. These standards apply equally to permanent, temporary, and agency workers, as well as piece-rate, salaried, hourly, part-time, night workers, homeworkers, young workers and migrant workers. We require that as a condition of doing business with us, suppliers:
- Agree not to engage in any form of human trafficking or slavery. We describe examples of good management practices for evaluating and addressing risks of human trafficking in their own supply chain, including not using forced or involuntary labor of any type (e.g., forced, bonded, indentured, involuntary prison labor) or illegal child labor.
- At a minimum, comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime hours, piece rates and other elements of compensation, and provide legally mandated benefits.
- Treat all employees with respect and will not use corporal punishment, threats of violence or other forms of physical coercion or harassment. Supplier should have a policy that prohibits inappropriate conduct and a process for employees to report such conduct for supplier’s investigation and resolution.
Compliance assessments and audits
Reformation reserves the right to verify a supplier’s compliance with the Supplier Code through audits or on-site inspections, including interviews of the supplier’s employees in order to evaluate compliance with our standards for trafficking and slavery in supply chains and other Reformation standards. In order to ensure continued compliance with our Supplier Code of Conduct, all Tier 1 suppliers and their subcontractors must agree to semi-announced audits (14 day window of when the audit can occur) on an annual basis (at a minimum) by our independent and accredited third-party monitoring firms. Suppliers must grant full access (all facilities, employee records and employees for confidential interviews), maintain accurate documentation necessary for demonstrating compliance with our standards and be fully transparent when submitting to assessments.
Our independent third-party audits cover hours of work, wages and benefits, child labor, health and safety, non-discrimination, sub-contracting, homework, hiring, disciplinary & termination, forced labor, harassment and abuse, non-discrimination, foreign migrant labor, management systems, freedom of association and collective bargaining and transparency and include management and confidential worker interviews. Additionally, many of our audits include mobile phone surveys that provide deeper insight into worker satisfaction which help to identify and prioritize areas of improvement. The goal of our assessments is not only to help us evaluate our supplier’s overall compliance but to also identify progress and stimulate improvement.
Reformation requires our suppliers to strive to meet our requirements as well as demonstrating a commitment to our core values of transparency, open and ongoing communication, accountability and continuous improvement. Based on the findings during the audit, Reformation performs concentrated remediation efforts and a Corrective Action Plan (CAP) form is issued to the supplier detailing the areas which need improvement. Suppliers are expected to remediate any noncompliance issues in a timely manner which is reasonable and defined. Reformation works with suppliers to try and find the root cause of the issue and to develop necessary management, systems within the factory, to ensure ongoing compliance and continuous improvement.
Certification of Suppliers and Materials
We are committed to achieving transparency and traceability of our supply chain. We currently require any facility involved in the manufacturing of Reformation product to be disclosed regardless of the facility level and production process, this includes but is not limited to mills, dye houses and printers, yarn spinners and fiber producers. Currently, our direct suppliers are required to continuously monitor all approved subcontractors and sub-suppliers for compliance with our Code and our Additional Policies.
Reformation requires that our Suppliers agree to comply with our Supplier Code, and that each supplier apply the Code to all of its extended sources of supply that are engaged in the production of goods and services for Reformation. In addition, our purchase orders and purchasing agreements contain provisions requiring direct suppliers to comply with all applicable law, including those addressing forced labor and human trafficking. In this way, our suppliers certify that materials incorporated into Reformation products comply with all laws of the country or countries in which the supplier is doing business. If the Supplier continues to be non-compliant with our standards or corrective action plans, that Supplier may be removed from our supply chain.
We want to be able to answer “who made our clothes” at every level of the supply chain. We are currently introducing our Code of Conduct to our Tier 2 suppliers (all wet processing facilities, mills) and beyond as we are aware that we could be vulnerable to human trafficking and slavery right down to the lowest tiers of our supply chains.
Internal Accountability Standards
Reformation is committed to the highest standards of conduct throughout our supply chain. On a regular basis, we review and update our policies and procedures to ensure that our high standards are upheld and to guard against the mistreatment of anyone in our supply chain.
All Reformation employees receive training on our Business Practices Guidelines, which requires employee compliance with law and Company policy, on a periodic basis.
Employees in our Supply Chain, Sustainability and Procurement functions that interact with our supply chain receive training in recognizing and preventing and forced labor which includes but is not limited to understanding the red flags of forced labor, awareness of the risk factors related to forced labor and the steps to take to prevent forced labor and meet legal requirements.
The Reformation Sustainability team attends seminars and trainings to ensure internal awareness of various issues in the global supply chain like migrant worker issues and responsible recruitment practices. Additionally, we partner with monitoring firms and our suppliers, participate in a multi-stakeholder initiatives (MSI) with a focus on industry collaboration & shared learning to both provide and obtain information in our supply chain and make sure we are empowering those around us with the relevant knowledge and tools.
Everyone has the potential to discover a human trafficking situation. If you think that you might have known or identified a victim of forced labor or human trafficking, please visit https://www.state.gov/j/tip/id/index.htm or call 1-888-373-7888 for information on how to help and to report a tip.