Policies and standards

We ground ourselves in the Universal Declaration of Human Rights and the International Labour Organization Declaration on Fundamental Principles & Rights of Work. We also align our policies and standards with international best practices, including the Ethical Trade Initiative base code, the Fair Labor Association, the American Apparel & Footwear Association (AAFA), and the Business Social Compliance Initiative (BSCI).

The Brooks Supplier Code of Conduct (Code) is the foundation of our responsible sourcing program. Together with local law and international labour standards, the Code sets the standards for all factories in our manufacturing supply chain.

Key topics addressed by the Code include:

• Health and safety
• Child labour
• Forced labour
• Working hours
• Wages and benefits
• Harassment, abuse, and discipline
• Freedom of association and collective bargaining
• Environmental responsibility
• Chemical management

The Code is part of the purchase agreement and must be signed by all suppliers who manufacture Brooks product and materials, to ensure a common vision, accountability, and transparency.

Supplier traceability

Visibility into the factories that manufacture Brooks products and materials, none of which we own or operate, is critical to ensuring that our responsible sourcing standards are upheld. We track 100% of Tier 1 (final product assembly) and Tier 2 (material manufacturing) factories, and we publicly disclose our global factory list, which can be found here.

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:

• They meet or exceed the requirements in the Code.
• They will maintain current and detailed records to substantiate compliance with the Code.
• They will be transparent with Brooks in all respects, including all documents such as accurate working hours and payroll records.
• Any Brooks merchandise will be produced in compliance with the wage and working hours laws of the country of manufacture and without the use of child, prison, or forced labour.
• They understand that failure to comply with the Code may result in termination of business with Brooks.

Additionally, Brooks requires all prospective factories to complete the Higg Facility Social Labour Module (Higg FSLM) self-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 Social Labour Convergence Program (SLCP), we aligned with the apparel and footwear industry by fully adopting the Higg FSLM and replacing our traditional third-party audit approach. This industry-standardized tool measures social labour practices in factories across nine key areas:

• Recruitment and hiring
• Working hours
• Wages and benefits
• Worker treatment
• Health and safety
• Termination
• Management systems
• Empowering people and communities

The Higg FSLM evaluation begins with a self-assessment completed by the factory, which is subsequently verified by an SAC-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, worker 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 factories’ continued compliance to our Code and local law through the use of the Higg FSLM. 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 dollars spent.

We also use the Higg FSLM to gain visibility into other Tier 2 factories located in countries that are identified as high-risk for foreign migrant workers. 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 retain control of their travel documents and have full freedom of movement, and all workers are informed of the basic terms of their employment before leaving home.

Following completion of a Higg FSLM assessment, we work closely with factories to remediate any identified issues that do not meet our standards. Factories are expected to remediate critical issues immediately and less severe issues within six months. In the spirit of continuous improvement and our commitment to establish long-term factory partnerships, when Brooks finds non-compliances, we work with the factory to understand the root cause and find a sustainable solution that will both correct the problem and prevent similar issues in the future.

Beyond compliance

As we closely collaborate with our factories, we commit to going beyond compliance: we’re using the Higg FSLM scoring and benchmarking tools to help our factories implement leading social and labour practices. A factory can receive a score of up to 100% on its verified Higg FSLM assessment, based on performance across the nine sections. The Higg FSLM is divided into three steps, and a factory can only score the maximum score if it answers questions in all three steps of the assessment. Step 1 questions assess a factory’s awareness and understanding of responsible social and labour practices and systems to ensure legal compliance and carry a maximum Higg FSLM score of 45%. Step 2 questions require factories to set baselines, targets, and track improvements and carry a maximum Higg FSLM score of 80%. Step 3 addresses beyond compliance questions and enables factories to achieve the maximum 100% Higg FSLM score. These practices include commitments to worker empowerment programs such as programs focused on gender equity in the workplace and programs focused on community engagement to drive factories to give back to their local communities.

As part of our objective to respect human rights and advance worker well-being, we have an ambitious target: 100% of Brooks Tier 1 factories must achieve and maintain a verified Higg FSLM score greater than 80 by 2025. To achieve this score, factories are required to complete all three steps of the Higg FSLM and go beyond compliance of our Code and legal regulations to implement leading practices focused on worker empowerment.

We also have a target goal that 80% (by dollars spent) of Brooks Tier 2 factories must achieve and maintain a verified Higg FSLM score greater than 70 by 2025. We prioritize Tier 2 factories that make up 80% of our total dollars spent on materials, which includes midsole and outsole factories and high-volume textile factories. Achieving a score of 70 requires factories to complete Step 1 and Step 2 of the Higg FSLM self-assessment, comply to our Code and legal requirements, and actively work on targets to continuously improve their social responsibility. While we encourage all factories in the Brooks manufacturing supply chain to implement worker empowerment programs and other leading practices, we acknowledge that our Tier 2 factories are newer to social responsibility assessments. We will set our factory partners up for success by holding them to realistic expectations.

To further enhance our understanding of worker well-being, we have implemented ELEVATE’s worker sentiment survey with all our footwear Tier 1 factories. This survey directly engages with the workers and provides them with a platform to share their perspectives. This survey is 100% anonymous and allows us to hear from significantly more workers than a traditional audit or Higg FSLM verification. The survey scores factories on five topics based on direct worker responses: grievance mechanisms, wages and working hours, workplace well-being, environment, health, and safety, and productivity and stability. Through analyzing the section scores, we gain insight into how workers feel about their compensation, management, and overall working environment. The worker sentiment survey builds on the insights gained from the Higg FSLM and helps us develop a deeper understanding of worker satisfaction. Once we receive the survey results, we directly engage with our factory partners to develop solutions that specifically address concerns raised by the workers.

Environmental responsibility assessment

To achieve our sustainable manufacturing objective, we assess the environmental performance of facilities that manufacture our product and materials through the industry-standardized tool, the Higg Facility Environmental Module (Higg FEM). We have used this tool with our Tier 1 final assembly factories since 2014 and 80% (by dollars spent) of our Tier 2 material suppliers since 2019. Following the completion of this self-assessment, all factories are required to verify the accuracy of their assessment via an SAC-approved verifier.

Our expectation is that all factories achieve Higg FEM level 1. This level of performance indicates that the factory has a good understanding of its environmental impact and is tracking its sustainability performance. To improve performance, we review each verified assessment and identify specific actions the factory will need to take to achieve the level 1 performance requirement. For those factories that already achieve level 1, we work with them to develop an action plan toward achieving the longer-term goal of level 3 performance, which indicates that the factory has implemented leading practices to reduce environmental impact.

Learn more about additional strategies we’re implementing with our Tier 1 and Tier 2 factories related to reducing carbon emissions.

Responsible chemicals program

An important focus of our sustainable manufacturing program is chemicals management. The objective of our responsible chemicals program is to ensure factories that manufacture Brooks product and materials use only chemicals that are safe for people and the planet.

The Brooks Restricted Substances List (RSL) underpins the responsible chemicals program and defines those substances that we restrict or eliminate from our products. All materials in Brooks’ products must comply with our RSL. We communicate our restricted substances requirements to all our suppliers through our RSL and maintain this understanding through the Brooks Supplier Code of Conduct and RSL Compliance Agreement, which is signed by all suppliers with each updated version of our RSL.

Our responsible chemicals program goes beyond RSL compliance to take a holistic view of chemicals management. We implemented requirements to manage chemicals entering the factory (input management), exiting the factory (output management), and the use of chemicals in the factory (e.g., storage, handling, and inventory management). We’ve aligned with the wider apparel and footwear industry by adopting the Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substance List (MRSL) — a list of chemical substances banned from intentional use — and the ZDHC Wastewater Guidelines, which define standards and ensure the safety of wastewater discharge. We’re committed to 100% compliance with the ZDHC MRSL and zero discharge of hazardous chemicals by 2025. Our responsible chemicals program evaluates factory progress against this commitment, and we proactively work with factory partners to identify areas where we can improve practices and ensure ZDHC standards are met.

Read more about our responsible chemicals program and RSL here.