Our target:

Compliance to our Code

As part of our new supplier onboarding process, Brooks requires all factories to sign the Brooks Supplier Code of Conduct, which certifies that:

Additionally, Brooks requires all prospective factories to complete a Social & Labor Convergence Program (SLCP) Converged Assessment Framework (CAF) assessment and verification to evaluate social and labour practices and verify compliance to our Code

In 2021, as a Sustainable Apparel Coalition (SAC) member and a signatory of the SLCP, we aligned with the apparel and footwear industry by fully adopting the SLCP CAF and replacing our traditional third-party audit approach. This industry-standardized tool measures social & labour practices in factories across nine key areas:

The SLCP CAF can be shared to brand partners via two accredited hosts: the Higg Index and Fair Factories Clearinghouse "(FFC)". The SLCP has also collaborated with Better Work, an International Labour Organization program that assesses compliance to international labour laws to improve working conditions. This collaboration means that Better Work will use the SLCP CAF assessment during their assessments to reduce audit fatigue and promote data sharing in the industry. As SAC members, we encourage our factories to use the Higg portal to complete the SLCP assessment through the Higg Facility Social & Labor Module (Higg FSLM); however, we also accept the SLCP report through FFC and Better Work. This ensures we are doing our part to help reduce duplicative auditing and costs for our suppliers.

The SLCP CAF evaluation begins with a self-assessment completed by the factory, which is subsequently verified by an SLCP-approved verifier to confirm the assessment questions were understood and answered correctly and the data is reliable. During verification, approved verifiers review the factory’s responses and conduct semi-announced onsite verification, which includes an opening and closing meeting, document review, factory employee interviews , and a facility walk-through. With industry adoption of this tool, duplicative auditing is eliminated, and brands can collaborate with their shared factories to use one data set to drive social and labour improvements in their supply chains.

Once factories are successfully onboarded, we evaluate 100% of our Tier 1 final assembly and footwear Tier 1 subcontractor factories’ continued compliance to our Code and local law through the use of a verified SLCP CAF assessment. We use a risk-based approach to determine our engagement level with Tier 2 material suppliers, prioritizing our engagement with factories that account for approximately 80% of our materials volume by dollar spend.

We also use a verified SLCP CAF assessment to gain visibility into other Tier 2 factories located in countries that are identified as high-risk for foreign migrant labour. We recognize that forced labour concerns of foreign migrant workers are among the most serious challenges facing the apparel and footwear industry. As a founding signatory of the Commitment to Responsible Recruitment, we commit to work with our global supply chain partners to create conditions so that no worker pays for their job, workers receive a timely refund of fees and costs paid to obtain or maintain their job, workers retain control of their travel documents and all workers are informed of the basic terms of their employment before leaving home.

Following completion of a SLCP CAF assessment and verification, we work closely with factories on a Corrective Action Plan (CAP) to remediate any identified issues that do not meet our standards.

In the spirit of continuous improvement, we rate factories twice throughout the CAP process. The assessment is initially rated following verification and then re-rated after the factory has been given two opportunities to show improvements. The final rating includes only those issues that have not been fully remediated. We believe it is critical to provide our factories with an opportunity to improve within the same year to foster a transparent relationship, motivate factories to remediate identified issues and give the factories an opportunity to explain any potential misunderstandings.

There are three kinds of ratings a factory can receive: Satisfactory, Needs Improvement and Demands Immediate Action. If a factory receives a Satisfactory rating, no issues were found in their latest verified SLCP CAF assessment. If a factory receives a Needs Improvement rating, one or more non-critical issues were found in their latest verified SLCP CAF. If a factory receives a Demands Immediate Action rating, at least one critical issue was found during their latest verified SLCP assessment. We identify a critical issue as a high-risk non-compliance to our Code and/or local and national laws and regulations that compromise the basic human rights of a factory employee.

If a critical issue is found and a factory receives a Demands Immediate Action rating, Brooks will immediately set up a meeting with the factory to discuss the issue, understand the root cause and work together to implement a solution to quickly remediate the issue and prevent it from occurring in the future. Factories who refuse or fail to remediate any critical issues found risk termination of business with Brooks.

Responsible purchasing practices

We recognize that our internal purchasing practices could affect our supplier’s ability to comply with social and environmental laws, regulations and our Code. To gain insight into how our suppliers view our internal practices, we partner with the Better Buying Institute (BBI), a non-profit organization which allows suppliers to anonymously rate the purchasing practices of their buyers. We deploy the Better Buying Partnership Index (BBPI) to 100% of Tier 1 and high-volume Tier 2 factories¹ who are anonymously surveyed about Brooks’ business purchasing practices such as accuracy of demand planning and forecasting. Upon completion of the survey, we review the results across various departments whose roles impact our purchasing practices such as costing, corporate responsibility, sourcing and supply planning. After reviewing the results, we determine steps to address low-scoring areas to drive improvements based on the feedback provided from our suppliers. Our partnership with BBI is our first step towards evaluating and improving our purchasing practices to ensure our business relationships with our suppliers are both responsible and mutually beneficial.