At Brooks, we know that a responsible global supply chain starts with the decisions we make. That is why we establish long-term partnerships with factories that share our objectives to trace our supply chain, respect human rights, promote factory employee voice and reduce environmental impact.
Key topics addressed by the Code include:
- Health & safety
- Child labor
- Forced labor
- Working hours
- Wages & 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.
Partner with factories to continuously trace our suppliers from Tier 1 through Tier 4
Visibility into the factories that manufacture Brooks products, materials and raw materials, none of which we own or operate, is critical to ensure the responsible sourcing standards outlined in our Code are upheld. The expansive and complex nature of footwear and apparel supply chains makes this visibility difficult. Therefore, we invested in a software solution called TrusTrace to help us continuously discover and trace factories throughout the Brooks manufacturing supply chain.
This deeper visibility into our supply chain will be used to identify and mitigate responsible sourcing risks, increase due diligence for customs compliance and identify business continuity risks.
In an effort to be more transparent about where our products and materials are made, we have aligned with the Transparency Pledge, a pledge for apparel and footwear companies to publicly showcase their commitment towards greater transparency in the manufacturing supply chain. We publicly disclose our Tier 1 and 80% (by $ spend) of Tier 2 factories, which can be found here.
These factories are key partners who we engage with on both social and environmental assessments to drive performance improvements and progress towards our goals every year. We also contribute to the Open Supply Hub (OSH), a collaborative supply chain mapping platform. With this contribution we support data sharing and collaboration to expand transparency efforts in the footwear and apparel industry.
Work with factories that share our values in respecting human rights, promoting fair and safe working conditions and advancing employee well-being.
1 100% of footwear Tier 1 factories, footwear Tier 1 subcontractors and 80% (by $ spend) of Tier 2 factories. We also require the assessment for Tier 2 factories located in countries identified as high-risk for foreign migrant labor.
- 100% of in-scope factories1 complete and verify an annual SLCP CAF assessment
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 labor
- 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 a Social Labor Convergence Program (SLCP) Converged Assessment Framework (CAF) assessment and verification to evaluate social and labor 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 labor practices in factories across nine key areas:
- Recruitment and hiring
- Working hours
- Wages and benefits
- Worker treatment
- Worker involvement
- Health and safety
- Management systems
- Empowering people and communities
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 Labor Organization program that assesses compliance to international labor 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 labor 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 labor. We recognize that forced labor 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.
1 80% (by $ spend) of Tier 2 factories
Ensure fair and safe working conditions from the perspective of the employees in factories in our supply chain
To further enhance our understanding of employee well-being, we annually implement ELEVATE’s Worker Sentiment Survey with all our footwear Tier 1 factories. This survey directly engages with the factory employees and provides them with a platform to share their perspectives. This survey is 100% anonymous and allows us to hear from significantly more employees than a traditional audit or SLCP CAF assessment. The survey scores factories on five topics based on direct employee responses: grievance mechanism, 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 employees feel about their compensation, management and overall working environment. The Worker Sentiment Survey builds on the insights gained from a SLCP CAF assessment and helps us develop a deeper understanding of employee satisfaction. Once we receive the survey results, we meet with each factory to discuss concerns raised by employees. Following the meeting, factory managers are required to develop an Improvement Plan in collaboration with their HR teams, trade unions and employees to address the lowest scoring sections and ensure solutions are identified to create a better working environment from the perspective of their employees. Brooks reviews the Improvement Plan and remains engaged with the factory to ensure the plan is implemented and progress is made.
1 100% of footwear Tier 1 and 80% (by $ spend) of Tier 2 factories2 100% of Tier 2 midsole/outsole factories and high-volume Tier 2 textile factories3 100% of footwear Tier 1, Tier 2 midsole/outsole factories, and high-volume Tier 2 textile factories
Environmental responsibility assessment
To achieve our objective to reduce environmental impact at the factories manufacturing Brooks product and materials, we assess their environmental performance 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 dollar spend) 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 achieve level 1, we work with them to develop an action plan toward our long-term expectation to progressively improve their Higg FEM performance level, indicating the factory is implementing 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
Chemicals management is an important focus of our objective to reduce environmental impact. 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. The Brooks RSL is updated on an ongoing basis to ensure it meets or exceeds global regulatory requirements including California Proposition 65 and EU REACH. 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 working towards 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.