New Era Cap Co. Supply Chain Transparency Statement
New Era Cap Co.’ s statement on California Transparency in Supply Chains Act,UK Modern Slavery Act,and Australia Modern Slavery Act.
STRUCTURE,BUSINESS AND SUPPLY CHAIN
Since 1920,New Era has been hand-crafting the finest headwear in the world. Today,with apparel and accessories lines,the brand is a market leader rooted in sports and an influencer of street and lifestyle culture around the globe. With over 500 licenses in our portfolio,New Era is the brand of choice in the worlds of sport,fashion,music and entertainment. The company is headquartered in Buffalo,New York,USA,and its production are sold in more than 80 countries.
New Era has a long-standing commitment to social responsibility in the manufacturing of our products. We select third-party manufacturers who share our commitment to human rights and environmental sustainability. We use both owned and contract production facilities and manufacture products in 16 countries around the world.
POLICIES AND CERTIFICATION RELATING TO SLAVERY AND HUMAN TRAFFICKING
New Era’ s Workplace Code of Conduct is based on internationally recognized labor and human rights standards,and includes provisions prohibiting all forms of forced labor,such as prison labor,indentured labor,bonded labor and human trafficking. Our Code is supplemented by detailed benchmarks that further define requirements prohibiting forced labor such as:requiring that workers maintain possession or control over their personal identification documents; prohibiting the imposition of mandatory overtime or excessive recruitment fees; and requiring that workers’ freedom of movement is not unreasonably restricted.
Before we place orders with any new supplier,the supplier must agree to comply with all applicable laws of the country of manufacture as well as comply with our Code of Conduct (and apply the higher standards in cases of differences or conflicts). Our Manufacturing Agreement contractually binds our suppliers to comply with our Code of Conduct,and New Era reserves the right to terminate any supplier found to be in material non-compliance with our Code.
We conduct employee training as well as supplier training on our Code of Conduct standards,including education on forced labor indicators and risks,relevant regulations,how to identify potential risk or violations in the supply chain,and how to prevent forced labor for taking place. In addition,our Responsible Sourcing & Production team regularly participates in seminars and stakeholder forums on supply chain responsibility to ensure that we are learning about and adopting best practices to mitigate and eliminate forced labor risk in our supply chain.
RISK ASSESSMENT AND MANAGEMENT
Our supply chain risk assessment process evaluates risk factors related to human rights,labor rights and environmental impact. We have established policies prohibiting production from certain countries or regions in which there are documented reports of widespread government-sanctioned forced labor. In addition,we evaluate supplier risk factors such as whether the facility employs migrant workers,who may be more vulnerable to forced labor abuse,such as human trafficking. Where a supplier employs foreign migrant workers,we conduct targeted audits to investigate any risk of forced labor that may occur at different stages of the hiring process. We require that foreign migrant workers are provided information in their native language on their employment terms and conditions (such as in employment contracts) as well as education on how to terminate their contracts. In addition,we require that safety training and training on grievance mechanisms are provided in workers’ native language.
DUE DILIGENCE,AUDIT PROCESS AND VERIFICATION
New Era’ s Responsible Sourcing and Production program operationalizes the principles of our Workplace Code of Conduct in our supply chain through:
- Education and training for workers and suppliers; announced and unannounced audits of Code compliance
- Remediation of non-compliance
- Supplier sharing of best practices
- Stakeholder engagement
New Era’ s commitment to supply chain social responsibility and transparency is evidenced by our voluntary participation in the multi-stakeholder Fair labor Association (FLA),a non-profit organization that evaluates and publicly reports on company social compliance due diligence programs. Since we joined in 2003,the Fair Labor Association has made available on its website annual public reports containing information on our company’ s progress towards implementation of the FLA Code of Conduct.
To evaluate compliance with our Code of Conduct standards,including forced labor benchmarks,we conduct both announced and unannounced audits of supplier social responsibility performance against the standards. New Era uses both FLA accredited monitoring firms as well as qualified,in-house staff to perform all audits. The audit process includes an opening meeting with management,confidential interviews of workers,management interview,record review,a facility walkthrough and a closing meeting to discuss findings. In addition to assessing whether an incident or situation of non-compliance has occurred,the audit process also evaluates the supplier’ s management systems and controls in place to prevent non-compliance. For example,suppliers are measured against performance indicators under various employment functions such as hiring,compensation,health and safety,grievance and discipline,and working hours.
ACCOUNTABILITY AND ASSESSMENT OF EFFECTIVENESS
If any non-compliance findings are identified,we work with our suppliers to understand the root cause and develop a preventative and sustainable remediation plan to address the finding. Supplier performance on social and environmental compliance is incorporated into each supplier’ s scorecard alongside other metrics such as quality,on-time delivery,cost and service levels.
For any further questions about our Responsible Sourcing &
Production program please feel free to reach out:firstname.lastname@example.org.
This statement has been approved by the officers of the corporate entity of New Era Cap Co.,and Signed on behalf of New Era by Jim Patterson,COO. This confirms the officers of the corporate entity for New Era Cap Co. have considered and approved the statement for fiscal year 2021.
COO,New Era Cap Co.