ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group

Page created by Terrence Leonard
 
CONTINUE READING
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
ETHICAL
SOURCING AT
THE WAREHOUSE
         2018 REPORT
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
2
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
CONTENTS

                                                                    ETHICAL
                                                                    SOURCING AT
                                                                    THE WAREHOUSE
                                                                                        2018 REPORT

CONTENTS                                                            Ethical Sourcing
                                                                    at The Warehouse
                                                                    2018 Report
                                                                    The structure and content of
4 //   Introduction
                                                                    this report was informed by:
5 //   The Warehouse and its supply chains                          The Warehouse Group Ethical
                                                                    Sourcing Policy (2017)
7 //   Ethical sourcing programme structure
                                                                    The Modern Slavery Act
13// Policy Themes and 2017 commentary                              (UK) 2015 and its guidance
       5.1 Management Systems                                       on Transparency in Supply
       5.2 Child Labour                                             Chains.
       5.3 Voluntary Labour                                         Baptist World Aid Australia’s
       5.4 Health & Safety                                          ongoing series of “Behind
       5.5 Wages and Benefits                                       the Barcode“ reports on the
       5.6 Working Hours
                                                                    Fashion industry.

       5.7 Freedom of Association and Collective Bargaining         Data within this report
       5.8 Environment                                              is derived from labour
       5.9 Subcontracting                                           audits undertaken for
                                                                    The Warehouse in calendar
       5.10 Business Integrity
                                                                    year 2017 and from our
                                                                    internal purchase order
22// New Initiatives
                                                                    management systems.
       Apparel Supplier Survey & Tier 2 Discovery
       Customer Survey – New Zealanders views on Ethical Sourcing   Where data or commentary
       ELearning – online resources for factory managers            is derived from external
                                                                    sources these are
       Worker Voice - Integrated Audits
                                                                    referenced in the footnotes
30// Trending now                                                   on each page.
       Transparency                                                 The report was compiled
       Living wages                                                 and authored by our Ethical
       Bangladesh                                                   Sourcing Manager and
                                                                    reviewed and approved by
       Human Trafficking and Modern Slavery
                                                                    our Executive.
37// Appendices
       Factory Lists
       List of The Warehouse’s Private Label (“House”) Brands
       Country Working Hour and Wages table

                                                                                                      3
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
INTRODUCTION

INTRODUCTION
The Warehouse Ltd is the largest subsidiary of The
Warehouse Group1 – New Zealand’s largest publicly listed
non-food retailer. The genesis of our Ethical Sourcing
programme dates to the values and vision of our founder
and cornerstone shareholder Sir Stephen Tindall.
Sir Stephen’s and The Warehouse Group’s                      attention. We have provided disclosures                      organisation to tackle these challenges
vision is to help communities throughout                     and commentary in relation to these                          alone – even in tiers of the supply
New Zealand to flourish and to contribute                    NGOs’ expectations - even where they                         chain where there is direct contact and
to a more sustainable country and planet.                    currently exceed our capabilities. This                      influence. We need further collaboration
                                                             reflects our commitment to transparency                      between business, government, and
At The Warehouse, with our extensive
                                                             and continuous improvement.                                  civil society. Consumers also have an
direct sourced, private label merchandise
                                                                                                                          important role to play by informing
programme, we recognise that we have                         Our report also highlights several
                                                                                                                          themselves about the ethical attributes
a special duty to protect the welfare of                     new initiatives undertaken during
                                                                                                                          of the choices available to them and
workers in our supply chain. Since 2004                      the year and for the first time a list
                                                                                                                          continuing to support those businesses
we have been on a journey to continually                     of our apparel factories along with
improve and extend the scope and                                                                                          who are meeting their expectations.
                                                             a comparative real wage and
effectiveness of our programme.                                                                                           We aim to be one of those businesses,
                                                             working hour table across different
                                                                                                                          and look forward to informing you further
                                                             source countries.
This report is intended to inform the                                                                                     about our progress in the future.
reader openly and transparently about                        Despite significant progress on our
conditions “behind the barcode” in our                                                                                    Nick Grayston
                                                             journey to date there remain many
source factories. It describes how our                                                                                    Group Chief Executive Officer
                                                             issues to address. Each year we reset
Ethical Sourcing Programme functions,                                                                                     The Warehouse Group
                                                             our strategy according to our learnings
and how we work to ensure that the
                                                             and emerging external expectations.                          Your feedback or questions are welcome
profit in our enterprise and the value we
                                                             It’s impossible for any single sourcing                      at ethical.sourcing@thewarehouse.co.nz
deliver to customers is also functioning
to protect and improve working
conditions for those at the origin of
our supply chain.

The information in this report is presented
through the lens of our January 2017
Ethical Sourcing Policy2 – so readers can
see how we have implemented the policy
in practice over the past year. We have
also taken account of the “Transparency
in Supply Chains” guidance3 provided
by the UK Government to companies
preparing public statements under the
UK’s 2015 Modern Slavery Act. Although
no such legislation exists yet in New
Zealand it has attracted considerable
interest in Government, NGO, and
Academic circles. Closer to home, reports
published by Baptist World Aid Australia
and Oxfam addressing labour issues
and setting expectations for apparel
supply chains have also captured media

1. http://www.thewarehousegroup.co.nz/
2. http://docs.thewarehouse.co.nz/red/pdfs/suppliers/ethical-sourcing/the-warehouse-group-ethical-sourcing-policy-01.17.pdf                                           4
3. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/649906/Transparency_in_Supply_Chains_A_Practical_Guide_2017.pdf
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
THE WAREHOUSE
AND IT’S SUPPLY
CHAINS

The Warehouse QC Inspector Dhaka Bangladesh

                                              5
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
THE WAREHOUSE AND
     IT’S SUPPLY CHAINS

THE WAREHOUSE
AND IT’S SUPPLY CHAINS
The Warehouse is New Zealand’s largest general merchandise
retailer with 92 stores throughout New Zealand and a large
online presence at www.thewarehouse.co.nz
Our customers represent a completely                                 layers of margin capture, with the origins                            goods is China. Everyday consumables
diverse group of New Zealanders. Our                                 of manufacture usually invisible to the                               and grocery items tend to be sourced
marketing, and wide ranges of general                                retailer if not the local wholesaler as well.                         closer to home in New Zealand and
merchandise and apparel, are focused                                                                                                       Australia. Recently we have seen a
primarily on families, and shoppers                                  Commencing with opening of our                                        growth in home textiles and apparel being
looking for great everyday bargains.                                 own direct sourcing office in Shanghai                                sourced from India and Bangladesh. To
                                                                     in 2004 The Warehouse set about                                       support this, we opened another sourcing
At the time of The Warehouse’s listing                               revolutionising this model, flattening the                            office in New Delhi India in January 2017.
on the New Zealand Stock exchange                                    supply hierarchy, and securing direct
in 1995 through to the early 2000s’ the                              access to manufacturing sources with an                               The most recent trend transforming
dominant model for most large general                                attendant leap forward in traceability and                            retail everywhere is the advent of the
merchandiser retailers was to source both                            transparency. For our customers, this has                             online giants such as Amazon offering
branded and private label4 merchandise                               meant reduced prices for most product                                 consumers efficient direct access to vast
through a New Zealand network of local                               classes while maintaining our position in                             ranges of merchandise where ever they
agents, manufacturers, wholesalers                                   an increasingly competitive marketplace.                              might be.
and importers. These enterprises in turn                             This trend has continued to accelerate in
sourced merchandise through their own                                recent years to a point where at the end                              Fortunately, because of the work we have
supply chains – additional networks of                               of 2017 more than a quarter of our                                    already done flattening our supply chain,
“middlemen” (trading companies) and                                  merchandise is sourced direct through                                 developing our direct sourcing expertise,
factories predominantly in Asia5.                                    our own sourcing offices.                                             and investing in our online webstore The
                                                                                                                                           Warehouse is very well placed to meet
This old model was characterised by                                  By far our biggest source of general                                  the challenges of an international and
highly dispersed supply chains, multiple                             merchandise, apparel, and electrical                                  digitised market place.

          THE WAREHOUSE PRODUCT SUPPLY CHAIN
                                              The
                                           Warehouse                                                Diminishing levels of
                                                                                                   influence and control

                                                                                                           In recent years The Warehouse            Top 20 Source Countries Share of Business
             External                                                          Tier 1                      has been moving to much more          CHINA                           61.14%
                                    Agent               Vendor
              Brand                                                           factory                      direct and concentrated sourcing
                                                                                                           relationships with attendant          NEW ZEALAND MADE                11.17%
                                                                                                           improvements in traceability and      AUSTRALIA                       7.41%
                                                                                                           all forms of assurance. In 2017
                                                                                                                                                 UNITED STATES OF AMERICA        3.68%
                                                                                                           about 43% of our sales were
            No further                                    Tier 1              Tier 2                       derived from own branded              BANGLADESH                      1.67%
                                   Vendor                                                                  merchandise. We can trace 99%         UNITED KINGDOM                  1.64%
             visibility                                  factory             supplier
                                                                                                           of our branded merchandise to its
                                                                                                           Tier 1 (final manufacture) source.
                                                                                                                                                 DENMARK                         1.48%
                                                                                                           In 2017 we had 1240 vendors           INDIA                           1.42%
                                                                                                           overall of whom 525 were              THAILAND                        1.37%
                                    Tier 1               Tier 2               Tier 3                       supplying our own brands.
                                                                                                           Associated with these were 985        MALAYSIA                        1.32%
                                   factory              Supplier             Supplier                      Tier 1 factories including 190        KOREA (SOUTH) REPUBLIC          0.94%
                                                                                                           apparel factories. All these are      GERMANY                         0.90%
                                                                                                           required to undergo and pass our
                                                                                                           quality, labour and environment       VIETNAM                         0.80%
                                   Tier 2                Tier 3                                            assessment before joining our         ITALY                           0.65%
                                                                                                           supply chain.
                                  supplier              Supplier                                           At present our traceability and
                                                                                                                                                 FRANCE                          0.48%
                                                                                                           assurance does not extend             PAKISTAN                        0.48%
                                                                                                           beyond the first Tier (final          POLAND                          0.32%
                                                                           Preferred more                  manufacture) factories but we
        Historical                                                          direct model                   have now begun mapping and            INDONESIA                       0.31%
         Model
                                   Tier 3                                                                  identifying the 2nd Tier of our       CANADA                          0.29%
                                  Supplier                                                                 apparel supply chain.                 SWITZERLAND                     0.28%

      Tier 1 = Final manufacture sites Tier 2 = Components and subsidiary processes Tier 3 = Raw materials

4. A retailer’s own brand versus a national or international brand owned by a supplier external to the retail enterprise. You can see List of The Warehouse private labels on page 41
5. During this and previous eras in NZ there remained a base of light manufacturing supplying retailers however this has declined significantly with the liberalisation of trade in the        6
    1980s culminating in free trade agreements of the early 2000s.
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
ETHICAL
SOURCING
PROGRAMME
STRUCTURE

Shanghai office footwear team   7
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
ETHICAL SOURCING
    PROGRAMME STRUCTURE

ETHICAL SOURCING
PROGRAMME STRUCTURE
The Warehouse’s Ethical Sourcing programme
contains the three elements of policy, due
diligence, and remediation or corrective action
described in the United Nations Guiding Principles
on Business and human rights.6
Our policies, and a description of our due                   Once a factory is qualified and              development workshops and training
diligence and remediation processes are                      manufacturing for one of our private         for factories who need help to improve
published on The Warehouse Supplier                          labels we maintain visibility of standards   their labour management practices. In
website.7 In practice our due diligence                      through an ongoing monitoring and            addition, from December 2017, we have
is implemented through supplier                              continuous improvement (remediation)         made an online library of eLearning
pre-qualification processes (for new                         cycle. Monitoring is achieved either via     courses, focused on common corrective
factories), ongoing factory monitoring                       our own commissioned follow up audits        action themes, available to factories
(for active factories), and continuous                       or via a desktop review of improvement       in their local language to support their
improvement initiatives and training.                        actions evidence submitted by the            remediation and improvement initiatives.
Through these activities we strive to
                                                             factory. Face to face support from our       Our prequalification processes are
ensure that only factories which meet
                                                             internal Ethical Sourcing specialists is     intended to screen out poor performing
or exceed our standards can supply
                                                             available to assist factories with their     factories before they enter our supply
goods bearing one of The Warehouse’s
                                                             remediation path. We hold regular            chain, however should a zero-tolerance
private labels.
To qualify new candidate factories
(from an Ethical or Labour Standards
perspective) we first invite the factory
to submit any existing labour standard
credentials they may have in the form
of a recent audit report undertaken
for another customer. This is to avoid
unnecessary duplication and to minimise
audit fatigue for factories. However, we
are very conservative in our approach to
such mutual recognition and reject about
half of such desktop submissions. In
these cases, the factory must undergo
our own audit8 if they wish to qualify.
These audit findings are then assessed
against our policy, especially for zero
tolerance standards like child labour,
voluntary labour, or non-transparent audit
practices. The overall pass rate for new
factory submissions in 2017 was 60%.

6. Page 16 http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf
7. https://www.thewarehouse.co.nz/c/suppliers/ethical-sourcing                                                                                       8
8. Executed by 3rd parties according to our policy and audit protocol
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
ETHICAL SOURCING
     PROGRAMME STRUCTURE

 The Warehouse Group Chief
 Executive Nick Grayston with
 our New Delhi sourcing team

issue be encountered within an active                           array of Tier 2 suppliers - manufacturing          Ethical Sourcing team for further review,
factory we suspend business and call for                        components, and undertaking subsidiary             analysis, and eventual response to the
an immediate rectification of the issue.                        manufacturing processes. Below this level          supplier. Our three main service providers
If this is not achieved, we permanently                         still lie the (Tier 3) raw material suppliers      at present are Elevate12, Taos Network13,
discontinue trading.15 active factories                         – natural and synthetic fibers in the              and Asia Inspection Services14. Our own
were discontinued for standards failure                         case of apparel; plastic resins, minerals,         internal Ethical Sourcing staff travel
in 2017. For less critical issues, training                     timber, leather and so on in the case of           regularly with these auditors in the field,
and support is provided for the factory                         general merchandise products classes.              exchange reciprocal training, and draw
to demonstrate improvement within an                            At present, we can’t make any assurance            on their expertise to inform our policies
agreed time frame.                                              statements about these levels of our               and gain deeper insight into actual
                                                                supply chain (Tier 2 & 3) except for FSC           practices in factories. We prioritise the
Programme Scope and Scale                                                                                          deployment of these resources based
                                                                certified timber products10 and products
Although our Ethical Sourcing policy is                                                                            on a historical risk profile for the factory,
                                                                containing certified sustainable palm oil.11
directed to all suppliers, our monitoring                                                                          region or industry. In 2017 22% of audits
and enforcement work is focused on                              However, in 2017 we began to map the               were undertaken on an unannounced
factories manufacturing our private                             characteristics of the second tier of our          basis. Each audit includes an
label merchandise.9 As we are primarily                         Apparel supplier base and to capture the           anonymously captured record of worker
an “own brand” retailer this is a very                          identity and location of the various fabric        interviews and a wage and working
significant share of our product range                          mills, dye and wash houses, print shops            hour table which clearly illustrates any
– about 43% of purchases in 2017 –                              and accessory suppliers associated with            variances in a sample of workers’ pay
equivalent to NZD $500 million. This was                        our garment factories. You can read                from legal entitlements. In a small
sourced from 985 factories represented                          more about the outcome of this work in             number of cases we supplement the
by 525 vendors. We can trace 99% of this                        the feature on our Apparel supply chain            audit findings with offsite observations
business back to its (Tier 1) factory of                        on page 23.                                        and worker interviews. We don’t publicly
origin. The largest 300 of these account                                                                           share our audit reports but this report
                                                                Audits
for about 80% of private label purchases.                                                                          discloses our audit findings and activity
                                                                All our labour audits are undertaken by
At present our programme is focused                             third party audit firms that specialise            at an aggregated level.
the first Tier of the supply chain – i.e. the                   in labour standards and worker rights              Our audit traverses five sectors of a
final manufacture sites. This is where                          auditing. They have many years’                    factories Labour and Environmental
we have the most control and influence,                         experience working in this way on behalf           management performance: Employment
and our progressive improvements                                of international brands. Each audit report         Policies, Compensation & Hours, Health
in transparency and traceability over                           is subject to an internal quality assurance        & Safety, Dormitory, and Environment.
time have been significant. However,                            review by the service provider before              Each audit report generates an overall
beyond Tier 1 there exists a complex                            being submitted to The Warehouse                   score, highlights any core standards or

9. See current list of our private labels on page 41
10. http://docs.thewarehouse.co.nz/red/pdfs/suppliers/product-quality/wood-product-sourcing-policy-mar15.pdf
11. http://docs.thewarehouse.co.nz/red/pdfs/suppliers/product-quality/palm-oil-product-sourcing-policy-may16.pdf
12..http://www.elevatelimited.com/
13. http://taosnetwork.org/                                                                                                                                        9
14. https://www.asiainspection.com/
ETHICAL SOURCING AT THE WAREHOUSE - 2018 REPORT - The Warehouse Group
ETHICAL SOURCING
   PROGRAMME STRUCTURE

transparency issues and contains extensive
contextual commentary from the auditors
along with a record of any corrective actions
agreed with factory management at the time
of the audit.
The average overall audit score in
2017 was 84.25%

Programme Management
and Accountability
Within our management structure
accountability for the strategy and operational
outcomes of The Warehouse ethical sourcing
programme lies with the Executive General
Manager of Sourcing and the CEO of Sourcing
Support for The Warehouse Group.
The execution of our strategy is monitored
through a typical plan-act-review cycle and
our quarterly reporting meetings are also
attended by the Head of Risk and Audit for
The Warehouse group. Operations are                               Average overall score
overseen by our Ethical Sourcing manager                                 84.25
and team based in Auckland and Shanghai.
All sourcing and merchandise personnel
based in Asia or New Zealand receive an
orientation and ongoing updates to our policies                                            Employment
                                                      Dormitory                              Policies
and programme. One of the strengths of our              92.66
                                                                                              94.58
programme is its close engagement with
our senior sourcing personnel who have full
visibility of the programme’s progress and the
status of all supplier factories. They regularly
lend their commercial support to the Ethical
team’s efforts to motivate and engage factories
in improvement initiatives.
An internal protocol dictates that all zero
tolerance issues such as underage labour,          Environment
bribery attempts, or involuntary labour are           85.64
                                                                                          Compensation
immediately escalated to the CEO of Sourcing                                                & Hours
                                                                                             66.18
Support for review to secure an Executive
mandate for any consequential actions.

                                                                    Health & Safety
                                                                        90.98

                                                                                                         10
POLICY THEMES
AND 2017
COMMENTARY

                                  11
Fabric processing Fuijian China
Policy
   POLICY themes
            THEMES
   and
   AND2017
        2017commentary
              COMMENTARY

5.1 MANAGEMENT
SYSTEMS
                                                                                        Adequate Management
   The average audit score for policies in 2017 was 94.5%                               Systems are deployed.
                                                                                        “Suppliers should maintain
                                                                                        all necessary policies,
Within the first section of every audit    bonded labour, and non-discrimination
                                                                                        management and information
we undertake, there is a comprehensive     on grounds of pregnancy or other
                                                                                        systems, facilities and human
series of twenty seven checkpoints         reasons.
                                                                                        resources needed to ensure
which examine the factories policies
                                           The policies section typically scores        they comply with all applicable
and management systems.
                                           highly within audits – its relatively easy   local laws and regulations
These address wages, benefits and          for a factory to assemble the requisite      and the requirements of
hours, overtime rates, discipline and      policy documents required by various         this policy.”
termination, grievance procedures,         customer codes. A common failure in                           - Policy extract
harassment and abuse and written           factories however is in deploying the
contracts. Also included are age           requisite management and information
identification, freedom of association     systems needed to give effect to policies
and collective bargaining rights,          – for example when it comes to tracking
prohibitions on: child labour, forced or   and controlling working hours.

   Fabric Sizing, Dhaka, Bangladesh

                                                                                                                            12
Policy
   POLICY themes
            THEMES
   and
   AND2017
        2017commentary
              COMMENTARY

5.2 CHILD LABOUR
   This is a core or zero tolerance issue within our due diligence                              Child labour shall not be used.
   approach. Our auditors carefully review identity records for any                             “Suppliers shall not employ
   evidence of underage workers or falsified identity records along with                        workers younger than the national
                                                                                                minimum working age. Juvenile
   careful observation of workers during interviews and the factory tour.
                                                                                                or young workers are employed
                                                                                                in accordance with local law and
In 2017 we had just one incident of confirmed underage labour.                                  shall not be required to participate
                                                                                                in night work or hazardous work.
                                                                                                Children are not permitted in
   Footwear factory Zheijiang China July 2017
                                                                                                the workshop areas of the factory.
  This factory was undergoing a follow        5) Contact the parents and legal                 Where underage workers are
  up audit. Two underage workers were             guardians and provide transportation          detected during a compliance
  found onsite. They were proximate to            and meals package to assist them to           audit, the factory shall take
  working age -16 and working during the          return home safely. All the cost should       responsibility for repatriating the
  school holidays. The factory followed           be paid by the factory; bus/train             child and enduring the continuity
  all the auditors recommendations and            tickets should be kept on files.              of their education and welfare
  provided documented evidence that                                                             until they attain legal working age.”
                                              6) Review all personnel files and take
  these actions had been taken :                  all possible measures to identify the                              - Policy extract
                                                  real ages of the current employees,
  1) “These underage labourers should
                                                  especially those workers who are          Whatever the cultural tolerance or
      stop their work immediately.
                                                  young-looking.                            rationale present in these instances,
  2) Terminate the employment                                                              they are violations of local laws and
                                              7) Establish age-verification process
      relationship with these two workers                                                   in every case, we issue the factory a
                                                  for all new workers and conduct
      immediately and pay their wages                                                       warning along with a requirement that
                                                  personnel file screening regularly
      according to the hours they had                                                       they take steps to help the underage
                                                  through self-monitoring to prevent
      already worked.                                                                       worker leave the workplace while
                                                  the employment of child labour at
  3) Arrange health examination for them                                                   ensuring they are in safe keeping until
                                                  the factory.“
      as soon as possible. The health                                                       the school term recommences or the
                                              Notwithstanding the factory’s positive        child reaches the legal working age.
      examination fees should be paid by
                                              response to these findings there were
      the factory and examination results                                                   We cannot categorically exclude the
                                              other significant non-conformances
      should be kept on files.                                                              possibility of more systemic and
                                              uncovered during the audit it’s overall
  4) Compensation should be given to         audit score was 62% and failed 6 of           abusive child labour practices existing
      these workers until they turn to 16     10 core standards including the zero          within the subsidiary levels (Tier 2 &
      years old, a minimum legal working      tolerance underage labour finding             3) of our supply chain but can say we
      age. The compensation amount            above. We ceased trading with                 have never encountered it within our
      should no less than local legal         this factory.                                 due diligence work to date at the
      minimum wage per month.                                                               final manufacture level (Tier 1) of
                                                                                            our supply chain.

  Child labour on the streets

                                                                                                                                        13
Policy
   POLICY themes
            THEMES
   and
   AND2017
        2017commentary
              COMMENTARY

5.3 VOLUNTARY
LABOUR
   This policy provision addresses some of the most potentially
                                                                                 Employment is freely chosen
   egregious labour abuses. In addition to checking for a
                                                                                 “Prison labour is prohibited. Bonded
   factory’s policies on these topics our auditors also closely
                                                                                 labour is prohibited - suppliers shall
   examine payroll practices for evidence of delayed or withheld                 not bind workers to their workplace
   payments, or deductions associated with disciplinary fines.                   through debt associated with
                                                                                 recruitment fees, fines, loans,
                                                                                 deferred payment or other means.
Where evidence of these practices is      suppliers because we were unable to    Workers shall not be recruited or
found, an immediate corrective action     satisfy ourselves that our preferred   employed through human trafficking.
to the offending practice is raised.      course of continuing to work with
                                                                                 Suppliers shall not retain identity
                                          the supplier was going to affect
Bonded labour is a concern in                                                    documents (such as passports or
                                          positive change for workers. Despite
countries where there are high rates                                             identity cards,) unless at the request
                                          repeated attempts we had been
of migrant workers coming from                                                   of workers and with written
                                          unable to secure management            permission. Workers must be able to
undeveloped countries to take low
                                          support for changes to their migrant   take leave form the factory for reasons
skilled jobs in developing countries.
                                          recruitment and labour management      of bereavement, illness, or significant
In these cases, our auditors look
                                          practices. We moved this business      family events and at any time when
closely at the recruitment pathways
                                          to another Malaysian supplier with     they are not working. leave, including
deployed by the factory, their
                                          better audit outcomes where we felt    maternity leave, entitlements shall be
practices around the safekeeping
                                          that our commercial leverage was       upheld. Workers can terminate their
of identity documents, and worker
                                          more likely to secure improvements     employment with reasonable notice
disclosures about the fees paid to
                                          for workers. Our interventions in      and without penalty.”
secure their placements or access to
                                          Malaysia have included escalating
working visas. The legality of Visas is                                                                    - Policy extract
                                          our concerns to the board of
closely examined as undocumented
                                          directors of a public company,
workers or those with expired Visas
                                          ensuring freedom of access to
are vulnerable to exploitation.
                                          identity documents, improving
This year we terminated our               dormitory conditions, and reducing
relationship with two Malaysian           working hours for migrants.

     Dhaka Garment Factory

                                                                                                                              14
POLICY THEMES
     AND 2017 COMMENTARY

5.4 HEALTH AND SAFETY
     Our average health and safety audit score in 2017 was 91%                                     Working conditions are safe and
                                                                                                   hygienic
                                                                                                   “Workplace hazards are clearly identified
A safe workplace is the most basic                       of deficiencies in the quality of their
                                                                                                   and controlled through a working health
worker entitlement. Our due diligence                    construction and infrastructure - as
                                                                                                   and safety plan. Responsibility for
assessment contains over 57 Health                       evidenced in the tragic collapse of the
                                                                                                   health and safety is assigned to a senior
& Safety investigation points                            Rana Plaza building in 2013 - Health
                                                                                                   management representative. Health and
                                                         and Safety, especially building and
Fortunately, in most cases, because                                                                safety training is provided for all workers.
                                                         fire safety, demand special attention.
of the long held focus of brands on                                                                Appropriate Personal Protective Equipment
                                                         Consequently, we decided to further       is deployed and its use enforced. Access to
this area, and the interest of local
                                                         strengthen our health and safety          adequate medical assistance and facilities
governments, Health & Safety is
                                                         assessment capability by joining          and drinking water and, if applicable,
consistently one of the highest scoring
                                                         the Alliance for Worker Safety in         sanitary facilities for food preparation
sectors within our audit reports.
                                                         Bangladesh.15 Our membership of           and storage.
However as with the above concerns                       the Alliance has delivered major
                                                                                                   Suppliers shall ensure that residential
for migrants in Malaysia each country                    improvements in building safety for
                                                                                                   facilities for workers, where provided, are
has unique labour management                             all our participating factories. (see
                                                                                                   clean and safe. An accident and injury
challenges. In Bangladesh, because                       our Bangladesh feature on page 34)
                                                                                                   register is maintained. All legal building,
                                                                                                   electrical, and fire safety, requirements are
                                                                                                   met. The operating safety of machinery
                                                                                                   and equipment is assured through a
                                                                                                   documented maintenance schedule.
                                                                                                   hazardous Chemicals are clearly identified,
                                                                                                   and stored and handled in accordance with
                                                                                                   local regulations and or international best
                                                                                                   practice. A natural disaster or emergency
                                                                                                   preparedness plan and training is in place.

                                                                                                   The workplace and its recruitment
                                                                                                   practices are free from harassment,
                                                                                                   or abuse. There is no discrimination in
                                                                                                   hiring, compensation, access to training,
                                                                                                   promotion, termination ore retirement
                                                                                                   based on age and race, caste, national
                                                                                                   origin, religion, age, disability, gender,
                                                                                                   marital status, sexual orientation, union
                                                                                                   membership or political affiliation. A written
                                                                                                   grievance procedure and training should
                                                                                                   be established for workers that ensures
                                                                                                   confidentiality, freedom from reprisal and
                                                                                                   a pathway to resolution. Establishment
                                                                                                   for workers that ensures confidentiality,
                                                                                                   freedom from reprisal and a pathway
                                                                                                   to resolution.”

                                                                                                                                  - Policy extract

      Alliance Safety Signage in The Warehouse Garment Factory Dhaka Bangladesh

                                                                                                                                                     15
15. http://www.bangladeshworkersafety.org/
POLICY THEMES
   AND 2017 COMMENTARY

5.5 WAGES AND BENEFITS
   In 2017 the average audit score for wages and                                               Workers monetary entitlements are
   working hours was 66.2%                                                                     met or exceeded
                                                                                               “Wages for regular working hours shall meet or exceed
                                                                                               local minimum rates, enable workers to meet their basic
Determining workers’ actual               and averaged over several months,
                                                                                               needs, and provide some discretionary income.
pay and its relationship to legal         cross checked with payslips and
entitlements and working hours            dialogues with the workers. These                    Where labour is employed indirectly through a licensed
is one of the most important and          calculations are then summarised                     agency or broker wages for regular working hours shall
challenging tasks for our auditors.       in a wage table (sample below                        meet or exceed local minimum rates, enable workers to
                                          for a Chinese factory) which                         meet their basic needs and provide some discretionary
The baseline indicator an auditor         illustrates the local monthly                        income. Where workers are paid by piece, the factory’s
must be aware of is the legal                                                                  piece rate schedule should enable workers to achieve at
                                          minimum wage, the number of
minimum wage for that region                                                                   least the minimum legal payment applicable to all regular
                                          days worked in the month, the
and any benefit entitlements such                                                              and overtime hours worked.
                                          total number of overtime hours
as workplace insurance. In many
                                          worked in the month, a projected                     When commencing work, all workers must have signed
developing country workplaces,
                                          entitlement at a benchmark                           contracts in accordance with local law which include
especially in China, workers are
                                          overtime premium of 1.5 times                        relevant information about their employment conditions,
paid by pieces produced rather
                                          the legal minimum hourly rate,                       wages, working hours and benefits.
than an hourly rate. Auditors must
                                          the actual pay received, and a
convert a worker’s total pay into an                                                           Suppliers shall provide each worker pay slips in their local
                                          percentage variation against the
equivalent hourly rate for regular                                                             language detailing regular hours and wages, overtime
                                          entitlement. This calculation is
hours worked and an overtime                                                                   hours and wages, any bonus paid, and any legally
                                          then used to score the factory
rate for overtime hours worked.                                                                permitted deductions. Suppliers shall not make any wage
                                          against its minimum and overtime
To make this calculation true                                                                  deductions unauthorised by law. Wages shall not be
                                          wage obligations.
auditors must have both accurate                                                               withheld beyond due dates. Suppliers shall not terminate
payroll data and accurate working         While factories typically pay                        and re-hire workers in a manner that avoids paying
hour data and then validate that          in excess of minimum wage                            applicable legal benefits.
this amount was paid to the               entitlements, and weekday overtime                   Where stipulated by law, the supplier shall provide work-
worker either in cash or via bank         rates, they often do not achieve                     related injury insurance for all workers.”
account deposits. A random                weekend overtime premiums.
sample of payroll records for                                                                                                              - Policy extract
individual workers are analysed           Examples of wage calculation table:

                                                                                                                              Total Pay
                                                                   Normal         Total Monthly       Total Pay @ 1.5
  Employee No             Name                 Department                                                                     According        Variation %
                                                                 Working Day        OT hours              OT Std.
                                                                                                                               Records
      N/A            Liu Chenghui                Tie dye              22                142               3577.01              3272.44            -8.5%

      N/A            Yu Xiaoqing                 Tie dye              22                132               3439.08              3412.35            -0.8%

      N/A             Xu Lanfang                 Dyeing               22                135               3480.46              4052.14            16.4%

      N/A                Xu Fang                 Dyeing               22                117               3232.18              4157.07            28.6%

      N/A                Xu Youlan              Washing               19               132.5              3225.29              3904.63            21.1%

      N/A            Liu Guoshun                Washing               22                141               3563.22              4063.85            14.0%

      N/A                Yu Youqin              Pressing              22                127               3370.11              3425.12             1.6%

      N/A                Yang Le                Printing              21                105               2993.10              3032.04             1.3%

      N/A           Zhou Shuwang                 Cutting              22               117.5              3239.08              4757.52            46.9%

      N/A                Lan Dong               Sewing                22                106               3080.46              4765.79            54.7%

 Month, Year:   Jun-17       Local Min Wage:      1600      Total Local Regular Working Days for Calculation      21.75

                                                                                                                                                              16
POLICY THEMES
     AND 2017 COMMENTARY

5.6 WORKING HOURS
     Of all the prescriptions within the ILO Labour Conventions and other codes such as the
     Ethical Trading Initiative16 actual developing country working hours show the greatest
     deviation from local law and international codes and conventions.

                                                                                                              Working hours are not excessive.
We have been tracking developing                                 in a constructive debate about the
country working hours data for more                              importance of transparency and integrity     Regular working hours, excluding
than ten years. Unlike progressive                                                                            overtime, should not exceed 40 or
                                                                 within the overall business relationship
                                                                                                              48 hours per week (whichever is
increases in wages, and significant                              while at the same time demonstrating
                                                                                                              defined by local law). All overtime
improvement in health, safety, and                               an understanding of local norms and
                                                                                                              hours should be voluntary and
environmental measures, working hours                            practices.
                                                                                                              compensated.
have remained persistently high –
especially when viewed from a western                            According to data from our active            Workers shall be provided with at
perspective. Long hours remain despite                           factory audits in 2017 average weekly        least one day off in every seven-
the intensive monitoring efforts of                              working hours were 69 hours. In a much       day period or two days off in every
numerous brands and multi-stakeholder                            wider sample of audits undertaken for        fourteen-day period.
initiatives. Unless local governments                            multiple international brands working
                                                                                                              The supplier must record workers’
decide to strictly enforce this element                          hour averages for China and Bangladesh
                                                                                                              regular and overtime hours accurately
of their labour law, change is unlikely,                         respectively were 65 and 70 hours
                                                                                                              as the basis for controlling excessive
as production worker earning aspirations,                        per week.17                                  working hours and providing correct
and competitive labour markets continue                                                                       compensation.
                                                                 We believe by pursuing transparency and
to dictate working hour norms - even
                                                                 accepting local working norms we are         Seasonal peak or deadline based
where wages have grown significantly.
                                                                 much better able to identify excessive       demand for overtime must be offset by
Our approach is to place transparency                            hours and reduce these via the corrective    rest days and reduced working hours.
at the forefront and seek a reliable                             actions plan agreed with the factory.
                                                                                                                                       - Policy extract
account of working hours in every audit                          A typical corrective action request where
we undertake. This often entails rejecting                       excessive hours are identified is to first
documentary evidence which is too                                reduce weekly hours to 72 or less with
good to be true and engaging factories                           one rest day per week.

      The Warehouse Consumer electronics factory Shenzhen China

16. https://www.ethicaltrade.org/eti-base-code                                                                                                            17
17. You can view a comparative table of various countries’ working hour data on pages 42-43.
POLICY THEMES
    AND 2017 COMMENTARY

5.7 FREEDOM OF
ASSOCIATION AND
COLLECTIVE BARGAINING
     Each audit we undertake includes an evaluation as to whether these worker rights are
     being restricted. However, the legal sanction for such rights varies by country.

China for example has not ratified                    restrict these rights and intermittent   Freedom of Association or Collective
the ILO conventions related to                        protest is feature of the Chinese        bargaining are not restricted.
the rights to organise, associate,                    labour landscape. These protests         Where the right to freedom of association
and collectively bargain.18 Nor                       are typically organised outside the      and collective bargaining is restricted by
has it ratified the convention                        auspices of the All-China Federation     law, the employer does not hinder, the
obliging ILO members to maintain                      of Trade Unions (ACFTU) the only         development of parallel means for
a system of labour inspection.                        trade union that is legally allowed      independent and free association and
Bangladesh by contrast has ratified                   to exist in the country. The relative    bargaining.
both these conventions and their                      absence (in a western sense) of
                                                                                               Workers representatives are not discriminated
garment sector alone has more                         workplace unions in China and
                                                                                               against and have access to carry out their
than 500 registered trade unions.                     the lack of enforcement of many
                                                                                               representative functions in the workplace.
Notwithstanding China’s position                      labour law elements are important
our audits have never revealed any                    elements of the moral case made                                         - Policy extract
attempts by factory management to                     for programmes like ours.

    Seamstresses The Warehouse Garment factory Dhaka Bangladesh

                                                                                                                                                 18
18. http://www.ilo.org/dyn/normlex/en/f?p=1000:11210:0::NO:11210:P11210_COUNTRY_ID:103404
Policy
    POLICY themes
             THEMES
    and
    AND2017
         2017commentary
               COMMENTARY

5.8 ENVIRONMENT
    Factories’ environmental scores have been improving and
                                                                                                                            Environment Protection measures
    averaged 86% in 2017.                                                                                                   are sound.
                                                                                                                            Suppliers must comply with all local
The suite of environmental check                           The Chinese Government’s                                         laws and regulations pertaining to
points within our audit tool seeks                         determination to address its pollution                           environmental protection. Suppliers must
to assess first whether the factory                        problems was very visible in 2017                                maintain an environmental policy and
has achieved any form of external                          with a series of crackdowns on                                   management plan sufficient to control
environmental accreditation such                           polluting factories rolling through the                          and minimize all Environmental Hazards,

as ISO 1400119, or Oeko-Tex 20.                            industrial provinces.21 In our case,                             Wastes or Pollutants unique to the factory.
                                                           several dye houses associated with
                                                                                                                            Suppliers should be able to trace the
We examine the factories                                   our garment factories were shut
                                                                                                                            origin of all their primary materials and
environmental planning resources                           down without notice while they                                   components and provide the disclosure to
such as its policies, environmental                        underwent government inspections                                 The Warehouse Group on request.
hazard register, records associated                        before reopening.
                                                                                                                                                                - Policy extract
with energy and water conservation.
                                                           In 2017 we began profiling this 2nd tier
Finally, we track the practical and                        of our apparel supply chain in much
legally required actions being taken to                    more detail requiring garment factories
monitor wastewater discharge, control                      to identify such secondary sites and
air pollutants, dispose of solid waste,                    describing what kind of environmental
enable recycling, and deal with any                        oversight they deploy (see our apparel
hazardous wastes.                                          supply chain feature on pages 23-24)

    Fabirc Mill Waste Water treatment ShaoXing China

19. https://www.iso.org/iso-14001-environmental-management.html
20. https://www.oeko-tex.com/en/business/certifications_and_services/ots_100/ots_100_start.xhtml
21. https://www.ft.com/content/f48c9674-ae68-11e7-beba-5521c713abf4 ; https://www.npr.org/sections/parallels/2017/10/23/559009961/china-shuts-down-tens-of-thousands-of-          19
     factories-in-unprecedented-pollution-crack
POLICY THEMES
   AND 2017 COMMENTARY

5.9 SUBCONTRACTING
   Although this requirement pertaining to subcontracting has always been
   implicit in our policy we decided to make these expectations very explicit
   when we released our updated policy in January of 2017.

                                                                                                    Subcontracted production or
Ensuring that production is occurring                 in Shanghai and in our regular face to
                                                                                                    processing is disclosed and
in qualified designated source factories              face meeting with vendors in China,           authorised.
is a challenge in many supply chains                  Bangladesh and elsewhere.
- especially in apparel and footwear.                                                               Facilities engaged by the suppler or
In the past 18 months, we have taken                  We documented 12 instances of                 factory for subsidiary processing
additional measures to strengthen                     unauthorised subcontracting in 2017.          must be disclosed at the time of
our assurance systems in this regard.                                                               factory registration. Subsidiary
                                                      In the instances where we uncover             processing facilities may be inspected
In Bangladesh, we deploy our own
quality control inspectors to factories               instances of unauthorised                     at any time at the discretion of The
daily rather than our former practice                 subcontracting at minimum we                  Warehouse Group. Purchase orders
of releasing shipments based on final                 suspend trading with the responsible          must be manufactured at the factory
inspections by third parties. In Chinese              vendor or factory until and if we can         designated by the supplier on the
garment factories if we don’t think we                re-establish confidence that they             purchase order. Order diversion or
are maintaining sufficiently frequent                 understand and will adhere to our             subcontracting to a factory other than
contact with factories we have deployed               policies. We also check to see if we          designated on the purchase order
3rd party auditors to factories on an                 have contributed in any way through a         shall only occur with the advance
unannounced basis to analyse the                      lack of communication or overbooking          knowledge and written authority of
factories recent production schedule                  the factory in relation to its capacity and   the The Warehouse Group.
and look for evidence of subcontracting.              ability to meet production deadlines.                                - Policy extract
In November, we employed a full-time
specialist within our Shanghai office                 However, unless a final manufacture
to focus on production validation and                 site is very large and vertically
corrective action plan support for                    integrated some processes and
factories – primarily in the garment                  most procurement of materials and
sector. We have been emphasising                      components must be sourced from
this policy requirement in all our                    subsidiary suppliers or processors.
recent supplier communications                        This is a necessary and entirely
– at our September vendor conference                  legitimate form of subcontracting.

     Fabric Mill Waste Water treatment Fujian China

                                                                                                                                              20
POLICY THEMES
     AND 2017 COMMENTARY

5.10 BUSINESS INTEGRITY
    Our overall transparency score in 2017 was 76% - an improvement
    from 66% in 2016.

                                                                                                                No unethical or illegal conduct.
This policy element goes to the heart of
                                                                     integrity commitment which is              Suppliers shall not offer gifts or money to
why our programme exists.
                                                                     a feature of every audit opening           an employee or service provider engaged
We know our customers22 and team                                     meeting). This was the first social        by The Warehouse.
members expect our supply chain                                      compliance audit undertaken by             Assistance with transportation shall
behaviours and standards to be                                       this factory. The audit score was          be limited to local hub connections.
consistent with The Warehouse                                        62%, with four core standards failures     Hospitality shall be limited to working
Group’s vision to help communities                                   and non-transparent practices.             lunches or dinners.
throughout New Zealand to flourish                                   We ceased trading with this factory.
and to contribute to a more sustainable                                                                         Where an employee or service provider
country and planet. Every audit we                                                                              of the The Warehouse Group solicit
                                                                  By far the most common breach of
undertake contains the auditor’s                                                                                gifts, money or any other benefit this
                                                                  integrity we encounter is an attempt
assessment of the transparency                                                                                  must be declined and reported to
                                                                  during an audit to misrepresent payroll
and reliability of the audit findings.                                                                          The Warehouse Group at
                                                                  and working hour data. This is a zero-        ethical.sourcing@thewarehouse.co.nz.
Our auditors function within a                                    tolerance issue for us and unless this
                                                                  is resolved promptly we terminate the         Suppliers and their employees shall
protocol that demands an immediate
                                                                  trading relationship. Another important       not attempt to fraudulently meet the
notification of any integrity breaches
                                                                  integrity risk highlighted in our policy,     requirements of this policy, quality
such as bribery attempts. We received
                                                                                                                standard, or any other business
2 such notifications in 2017.                                     is fraudulent or doctored product test
                                                                                                                requirement through any kind of intentional
                                                                  reports or certifications. For this reason,
                                                                                                                misrepresentation or deception whether
  Bribery Notifications                                           our QA technicians always validate
                                                                                                                documentary or verbal in nature.
  - Home Decor Factory Shanghai China                             these documents with their associated
  December 2017                                                   test lab prior to commencing their            The provision of copies of audit reports as

  Attempted bribery during audit                                  own review.                                   evidence of the suppliers conformance with
                                                                                                                this policy shall be deemed as permission
  on challenge to non-transparent
                                                                  New Zealand is still fortunate enough         to contact the auditing body for report
  records. After we received the
                                                                  to enjoy a number 123 ranking in              verification purposes. Likewise, any copies
  immediate notification from our
                                                                  Transparency International’s World            of test reports or certifications submitted in
  auditor the factory manager met
                                                                  Corruption Perceptions Index. In their        support of any product’s conformance with
  with our China Sourcing Manager and
                                                                  open letter to the then Prime Minister,       any regulation or standard shall be deemed
  provided a documented retraction
                                                                  Transparency International stated that        as permission to contact the test laboratory
  and commitment to the provision
                                                                  “New Zealand is perceived as the least        or certifying body for verification purposes.
  of transparent records. These were
  later validated by our internal Ethical                         corrupt nation in the world; integrity is     Suppliers shall participate in any audits
                                                                  New Zealand’s most important asset.”          or assessments undertaken with respect
  Sourcing specialist. Conditions in the
                                                                  We are lucky that “doing the right            to their compliance with this policy in a
  factory are otherwise positive (audit
                                                                  thing“ is still a core Kiwi value. At the     cooperative and transparent manner.
  score of 94%) and we continue to
  trade with this factory.                                        Warehouse, we are determined to do                                           - Policy extract
                                                                  our best to uphold this value wherever
  - Home Décor Factory Yiwu China                                 we operate. We know we are not perfect
  August 2017                                                     - we find challenges everyday – but we
  Attempted bribery during an initial                             are continuing to press forward with our
  audit (despite signing the audit                                continuous improvement initiatives.

22. See page 25 for our recent survey of customer’s ethical sourcing expectations.                                                                                21
23. https://www.transparency.org/country/NZL
NEW
INITIATIVES

Seamstress - China Garment factory
                                     22
NEW INITIATIVES

APPAREL SUPPLIER
SURVEY & TIER 2
DISCOVERY
In October 2017, we distributed an online survey to all
our active Apparel vendors. The main purpose of the
survey was to begin to map the characteristics of the
second tier of our garment manufacturing base.
These are the fabric mills, dye and wash                                   with the Tier 2 assurance disclosures                                  survey. Based on our survey responses
plants, fabric printers, accessory and                                     provided in the survey will inform                                     we estimate that underlying this group
packaging suppliers supplying the final                                    our interest in extending our ethical                                  of vendors and their Tier 1 factories
garment manufacturing sites making our                                     assurance programme into this level                                    is a larger group around 1000 Tier 2
private label clothing ranges. A secondary                                 of the apparel supply chain.                                           suppliers. Survey data indicates that the
objective was to understand what forms                                                                                                            largest number of these are fabric mills
of assurance apparel vendors deploy                                        Quantifying                                                            (21%) followed by accessory suppliers
over their own supply chains.                                              In 2017 we sourced from 103 apparel                                    (17%) and dye houses (16%).
                                                                           vendors associated with 190 (Tier 1)                                   The remainder are distributed among
Following on from the survey we have                                       factories. At the time of the survey we                                various kinds of specialists such
begun to capture the location and identity                                 had consolidated this to a group of 66                                 embroidery shops, screen printers,
of these diverse Tier 2 sites. This along                                  vendors of whom 55 participated in the                                 and packaging suppliers.

       APPAREL SUPPLY CHAIN MAP : VENDOR/TIER1/TIER 2

                                                                                                                                        The
                                                                                                                                     Warehouse

                                                                                    Shanghai                                         New Delhi                                          Auckland
                                                                                    Sourcing                                         Sourcing                                           Sourcing
                                                                                     Office                                           Office                                             Office

  # Apparel Vendors that participated in the supplier survey
  •Total 55 responses collected (versus 66 targeted)                                  43                                                 8                                                 4
  •83% response rate                                                                Vendors                                           Vendors                                            Vendors

  Tier 1 (Final Manufacture Sites): Total 178
  •Avg. 3/ Vendor                                                                    132                                                33                                                13
  •Max. 11/ Vendor                                                                   Tier 1                                             Tier 1                                            Tier 1

  Tier 2 (Processing and Component Suppliers): Total 831
  •Avg. 15/ Vendor                                                                  617                                               118                                                 96
  •Max. 87/ Vendor                                                                   Tier 2                                             Tier 2                                            Tier 2

  Tier 2 Suppliers Distribution (Top 3 Tier 2 Supplier Categories)
                                                                      21%            17%             15%              18%             16%              15%              23%              23%             22%
  •Fabric Mills (21%) make up the largest percentage, followed by                   Accessory                                           Fabric        Packaging                         Accessory
   Accessory Suppliers (17%) & Dye House (16%)                       Fabric Mills   Suppliers       Dye House       Fabric Mills       Printing       Suppliers        Dye House        Suppliers       Fabric Mills

  Chart illustrates the network of apparel vendors, their Tier 1 final manufacture sites, and Tier 2 subsidiary suppliers associated with our three sourcing offices in Shanghai – China vendors and factories,
  New Delhi – Bangladesh vendors and factories, and Auckland – New Zealand vendors also sourcing from Asia.

       Slide 1

                                                                                                                                                                                                                       23
NEW INITIATIVES

Assurance                                    tier of the supply chain. Nevertheless,              The results for the 55 survey respondents
Securing any labour, environmental, or       as a first step within the survey we asked           are illustrated in the accompanying
quality assurance over this part of our      vendors several questions about the kinds            infographics.
supply chain is complex especially as our    of Environmental & Labour assurance
transactional significance and influence     they maintain over their Tier 1 and 2
is increasingly diluted at each descending   supply chains.

        TIER 1 ENVIRONMENT AND LABOUR ASSURANCE                                                          Tier 1= Final manufacture sites

                             {
                                              62% Conduct own
                                              environmental                    69% Communicate

             98%
  Apparel Vendors say they
        have a formal
                                              management
                                              system inspection

                                                65% Review
                                                Government
                                                permits
                                                                               the customers
                                                                               Labour Policy to the
                                                                               factory

                                                                                53% Assist the
                                                                                factory prepare for
                                                                                customer audit
                                                                                                       {                      100%
                                                                                                                       Apparel Vendors say
                                                                                                                        they have a formal
                                                                                                                         labour assurance
   environment assurance                                                                                               program in place for
    program in place for                                                                                                  Tier 1 suppliers
       Tier 1 suppliers

                                             38% Require factory                76% Require the
                                             to hold Environmental              factory to hold
                                             certification e.g. ISO             some labour
                                             14000 or FSC                       standards
                                                                                certification

       Slide 2

       TIER 2 ENVIRONMENT AND LABOUR ASSURANCE                                                           Tier 2 = Subsidiary suppliers – Fabric Mills,
                                                                                                         Accessory Supplier, Dye Houses

                             {
                                              52% Conduct own                  65% Communicate
                                              environmental

             96%
  Apparel Vendors say they
        have a formal
                                              management
                                              system inspection

                                                65% Review
                                                Government
                                                permits
                                                                               the customers
                                                                               Labour Policy to the
                                                                               factory

                                                                                48% Assist the
                                                                                factory prepare for
                                                                                customer audit
                                                                                                       {                        96%
                                                                                                                       Apparel Vendors say
                                                                                                                        they have a formal
                                                                                                                         labour assurance
   environment assurance                                                                                               program in place for
    program in place for                                                                                                  Tier 2 suppliers
                                                                                                                          Tier 1
      Tier
       Tier 2
            1 suppliers

                                             34% Require factory                31% Require the
                                             to hold Environmental              factory to hold
                                             certification e.g. ISO             some labour
                                             14000 or FSC                       standards
                                                                                certification

       Slide 3

                                                                                                                                                         24
NEW INITIATIVES

CUSTOMER SURVEY –
NEW ZEALANDERS’ VIEWS
ON ETHICAL SOURCING
In August 2017, we undertook 2 focus groups
to better understand customers’ views and
expectations concerning Ethical Sourcing.
The themes explored included:                    communications about Ethical Sourcing         • Develop own standard of conduct
• T
   he level of importance to customers          rather than passive or reactive to media         to apply
  when choosing a retailer?                      stories. They identified reputation
                                                                                               • Incorporate ethical clauses in contracts
                                                 and trust, as important factors when
• What does responsible sourcing mean?                                                        • Communicate sourcing with customers
                                                 choosing a retailer. They felt that hearing
• Who does it well/not so well?                 it from The Warehouse up front (before          – they would rather hear it from the
                                                 any negative media exposure) gives              horse’s mouth
• What are the issues?
                                                 reassurance.                                  • T
                                                                                                  raining modules for staff to complete
• What is the best way to communicate                                                           so they can share this information with
   about responsible sourcing?                   The focus group members had plenty of
                                                                                                 customers if they ask (should be based
                                                 suggested actions retailers could take to
• T
   he Warehouse and responsible                                                                 on NZ national standards that are used
                                                 exercise responsible sourcing:
  sourcing?                                                                                      by all/many retailers)
                                                 • Assist factories to achieve better
Customers told us that they don’t have                                                         • Advertise this information on social
                                                    standards, not to cut off sourcing
ethical sourcing top of mind and they                                                             media, in-store e.g. posters, and on
                                                    from them
                                                                                                  retailer’s website (must not be in your
don’t generally think about the supply
                                                 • Get actively involved and give them           face, yet easy to find)
chain of the retailers they shop at and
                                                    time to improve
products they purchase, but said it could                                                      • Stickers on products to show it’s ethically
be easily brought to mind by the media.          • Provide charitable support to                 sourced e.g. like star rating /Health tick
They recommended we be proactive with               communities factories are in                  on food or SPCA tick on eggs

Responsible sourcing was seen by focus group members
as just one element of overall responsible retailing.

                    Offers recycling

                                        Treats
          Cares         Carbon
                                      staff well -
          about        footprint
                                      promotion,
        customers                   training & pay

     “Responsible Retailer”
      Supplies lasting products         Responsible
                                         sourcing

             Better use of           Giving
            environmental          back to the
              resources            community

                                                                      A Warehouse Store

                                                                                                                                                25
NEW INITIATIVES

ELEARNING –
ONLINE RESOURCES FOR
FACTORY MANAGERS
Support for factories remediation or corrective action
is the vital third element of the threefold prescription
(of policy, due diligence, and remediation) described in
the United Nations Guiding Principles on Business and
human rights.24
A new initiative we have developed with                      us to deliver the resources and insights     • Transparency & Ethics
our service provider (Elevate) in 2017 and                   smaller factories often lack, more
                                                                                                          • Corrective Action Plans
intend deploying in 2018 is the delivery                     effectively and uniformly than via our
of ELearning courses addressing some                         typical training workshops. The courses      • Working Hours
of the most common improvement and                           are delivered in local languages.
                                                                                                          • Working Hours Management Systems
remediation themes encountered during
                                                             The initial library we intend distributing
factory audits. The courses are intended                                                                  • Working Hours Recording Systems
                                                             in 2018 includes courses on:
to supplement the direct contact and
communication we have with factories,                        • Authentic preparation for workplace
but the digital learning format enables                         assessments (audits).

                                                                                                                        This is a sample of
                                                                                                                        sequential slides from
                                                                                                                        one of our ELearning
                                                                                                                        courses on working hours.
                                                                                                                        As course adminstrators
                                                                                                                        our Ethical Sourcing team
                                                                                                                        can monitor factories’
                                                                                                                        progress through their
                                                                                                                        course library.

                                                                                                                                                    26
24. http://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf
NEW INITIATIVES

WORKER VOICE
For most of the history of our programme      our Substantive
                                      Caller Profile
primary means of directly accessing workers’ Issues
opinions and perceptions has been the worker                                                Caller Profile               Substantive
                                                                                                                         Issues

interview conducted within every factory audit.                               Brand: The Warehouse                                            Total Substantive Issues (from Dec '14 onward):                                    156

A skilled auditor can  putThe Warehouse
                  Brand:                                                Total Substantive Issues (from Dec '14 onward):                                           Helpline Issues
                                                                                                                                                                156

workers at ease and                                                                                                          Number of Substantive Issues Reported - Monthly
                                                                                                Helpline Issues
secure reliable anonymised
                                                        Number of Substantive Issues Reported - Monthly
information. We estimate
                                                                                           20
that we have been able
                                                                             # of Issues

access over 5000 workers’
                    20

views over the past 3 years
                        # of Issues

                                                                                           10

in this fashion. However, we
                    10
have been trying to develop                                                                0
a mechanism to enable                                                                            Dec, 16     Jan, 17     Feb, 17 Mar, 17                   Apr, 17     May, 17         Jun, 17       Jul, 17   Aug, 17        Sep, 17   Oct, 17        Nov, 17   Dec, 17
                     0
workers’ perceptions and  Dec, 16 Jan, 17          Feb, 17 Mar, 17                     Apr, 17     May, 17     Jun, 17      Jul, 17           Aug, 17        Sep, 17    Oct, 17            Nov, 17   Dec, 17
concerns to be captured                                                                                                                                         Issues by Category
independent of any audit –                                                                      Aggregate*                                                                                            Monthly
                                                                                                Issues by Category
and potentially at any Aggregate*
                         time.                                                                                               Monthly
                                                                                                                                            100%

                                                                      100%                             0%
Our first effort in this regard                              23%
                                                                               13%              80%

was via the Worker Helpline 13%
                              0%                                                    1%
                                                                                                                              % of issues

                                               80%
                                                                                                60%
                     23%
operated by The Alliance for       1%
                                                        % of issues

                                               60%
Worker Safety in Bangladesh.                                                                    40%

All workers in our Bangladesh                  40%
                                                                                                20%

factories have access to                       20%                                               0%
the helpline. The Helpline—                     0%
                                                                             62%                        Dec, 16      Feb, 17        Apr, 17        Jun, 17 Aug, 17       Oct, 17                                                                                  Dec, 17

Amader Kotha25 (“Our Voice”)62%                        Dec, 16        Feb, 17      Apr, 17      Urgent: Safety Aug, 17
                                                                                                  Jun, 17                          Urgent: Non-safety
                                                                                                                             Oct, 17        Dec, 17              General Inquiries
                                                                                                Non-urgent: Safety                 Non-urgent: Non-safety
in Bangla—provides workers                     Urgent: Safety                     Urgent: Non-safety                 General Inquiries
                                               Non-urgent: Safety                 Non-urgent: Non-safety
with a reliable 3rd-party                                                                  Most Commonly Reported Substantive Issues*
                                          Most Commonly Reported Substantive Issues*
reporting channel that allows                                                                         Top Five Issues Reported by Category
them to raise safety concerns                        Top Five Issues Reported by Category
                                                           Non-urgent: Safety    Health - Inadequate facilities                                         1

anonymously. Non-urgent: Safety Health - Inadequate facilities                                         1

                                                                                                                  Compensation - Benefits                                                                                                          2

The Helpline was first piloted               Compensation - Benefits                                                                                                               2

and launched in July 2014,                                                                                        Verbal abuse                                                                                                                     2

                                             Verbal abuse                        Non-urgent:                                                                                       2
and has receivedNon-urgent:
                  thousands                                                      Non-safety
                 Non-safety                                                                                       Compensation - Wages (including bonuses)                                                             1
of calls from workers.                       Compensation - Wages (including bonuses)                                                                  1

                                                                                                                  Leave                                                                                                1
                                             Leave                                                                                                     1

                                                                                                                                                                                       0                           1                           2                           3
                                                                                                              0                                    1                           2                               3

                                                                                                                                                                 Issue Resolution**
                     The adjacent chart profiles                        Issue Resolution**
                     helpline calls received from
                 workers in Bangladesh      factories
                                      Helpline Response to Info Request
                                                                                Helpline Response to Info Request
                                                                                                            40%
                                                                                                                                                                                                                           40%

                      supplying The Warehouse
                                                                                 Resolved
                            Resolved

                                                                                                              Per Factory                                                                                                                60%
                                          Per Factory                                                                                                                    60%

                                                                                                           0% 10%        20%                30%    40% 50% 60% 0% 70%10%80%20%
                                                                                                                                                                             90% 30%                               40% 50% 60%                 70%       80%     90%
                                                                                                                                                      % of Issues                                                     % of Issues
                                                                                                                                                           Monthly views show last 13 months of data.                       Monthly views show last 13 months of data.
                                                                              Powered by:                                                * Data collected
                                                                                       * Data collected before December 1, 2014 is not included           before
                                                                                                                                                in the analysis ofDecember
                                                                                                                                                                  issues.  1, 2014 is not included in the analysis of issues.
                         Powered by:                                                                                                      ** Issue resolution data collection)
                                                                                                                                                                   is reflectedonward.
                                                                                                                                                                                from June 15, 2015 (beginning of data collection) onward.
                                                                                      ** Issue resolution data is reflected from June 15, 2015  (beginning of data
                                                                                                                                                                                                                                                                               27
25. http://www.bangladeshworkersafety.org/en/what-we-do/worker-empowerment/worker-helpline
You can also read