Last updated: Dec 30, 2011
In 2010, the state of California passed the Transparency in Supply Chains Act (the “Statute”). The Statute requires companies doing business in California to disclose their efforts to ensure slavery and human trafficking are not part of their supply chains. More specifically, the Statute requires companies disclose to what extent, if any, they address each of the five points below.
Carter’s strictly prohibits the use of slavery and human trafficking in our product supply chain. Our Supplier Code of Conduct (the “Code”) specifically prohibits the use of “forced or involuntary labor of any kind in the supply chain, including any labor obtained though slavery or human trafficking.” Prior to engagement, a Carter’s employee or third-party agent evaluates each potential supplier on such supplier’s ability to meet Carter’s requirements, including compliance with the Code.
To ensure compliance with our Code, each audit of a Carter’s supplier is conducted by an independent third-party firm. The third-party auditor employs experts in local laws who speak the local languages. The frequency of audit for each facility varies based on various factors, including prior audit results and a risk assessment profile. Our goal, however, is to have each facility audited at least once per year. In 2011, our third-party auditor conducted more than 450 audits on Carter’s behalf.
The third-party auditor conducts both announced and unannounced audits. We have found that providing a short notice period helps ensure that all required personnel and documentation can be made available. Unannounced audits, however, are conducted when previous audit results include serious or multiple violations of our Code.
Carter’s requires each of its suppliers to annually certify that it complies with Carter’s Code. In addition, each time a vendor enters into a purchase order with Carter’s, the vendor certifies compliance not only with our Code but also with all applicable laws regarding slavery and human trafficking.
Carter’s considers forced labor, slavery and human trafficking to be zero-tolerance violations to our Code. If any supplier is found to be non-compliant in these areas, immediate corrective action must be taken by the supplier. Regardless of corrective action taken, Carter’s reserves the right to terminate our business relationship with any supplier that does not comply with our Code.
Carter’s, our agents and our independent, third-party auditors work directly with suppliers to train them on compliance with our Code. Internally, we are in the process of implementing a formal training process for our employees who have direct responsibility for the management of our supply chain. This training will educate them on the risks of human trafficking and slavery in the supply chain and what actions can be taken to mitigate these risks
Carter’s | OshKosh B’gosh is a baby and children’s clothing retailer offering value pricing throughout Canada.
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