The California Transparency in Supply Chains Act
Disclosure
In September 2010, the government of California approved a new law, which
requires retailers and manufacturers operating in the state to make public the steps they
have undertaken to eradicate slavery and human trafficking from their supply and
distribution chain. Volcom considers the practice of slave labor and human trafficking to
involve “the recruitment, harboring, transportation, provision, or obtaining of a person for
labor or services, through the use of force, fraud, or coercion for the purpose of subjection
to involuntary servitude, peonage, debt bondage, or slavery” (TVPA of 2000). As a company,
we strongly condemn these practices and do not allow them to have a place in our supply
chains. The following describes how we oversee our supply chains for continued compliance:
Verification
We assess the risks of slavery and human trafficking by understanding that such
practices can happen anywhere. With that in mind, we regularly review our supply chain and
audit all non-WRAP-certified factories that we do substantial business with to ensure that
they show continued compliance with the Volcom Code of Conduct and all applicable laws,
rules, and regulations. Our Code of Conduct covers issues such as maximum working hours,
basic wages, respect, equality, and restriction of forced labor (amongst others).
Auditing
Our verification practices include third-party audits of the entire factory, including
its dormitories. We work with both Intertek and SGS for all of our audits. The auditing teams
interview groups of workers, as well as individuals, without the presence of their
management, to allow them to comment on their working conditions and any suspected
abuse. We require every new factory in our supply chain to present a recent, passing report
from a third party auditing firm or other approved auditing body to comply with the
requirements for our new vendor/factory set-up.
Our audits are scheduled in advance in order to give the factory time to prepare
for the visit and compile all of the necessary documentation. If an audit report ever brings up
evidence regarding any violations of the Code above, we work with the factory to create a
Corrective Action Plan clearly listing solutions with estimated completion dates for each non-
compliant point. If a re-audit is necessary, it is un-announced, and the factory is given a
two-week window. If we ever discover suspected child labor, slave labor, or forced labor, we
take immediate action to correct the issue and send auditors in seven (7) days later to
confirm that the factory is in compliance.
Volcom schedules audits depending on a factory’s past audit history. If a factory
has had passing results two years in a row, they do not have to audit the third year. For
WRAP- and SA8000-certified factories, we are willing to accept their certificates in lieu of a
Volcom audit as long as we are able to review the full report and track the completion of
their Corrective Action Plan. All of these actions help to verify that there is no human
trafficking or slave labor in our supply chain.
Certification and Code of Conduct
Every year Volcom updates its vendor manual with the current requirements, and
we require our entire supplier base to sign agreements noting that they have read,
understood, and implemented the requirements set forth. One of these agreements is our
Work Place Code of Conduct.
The Volcom Work Place Code of Conduct covers the following aspects (a copy of
the Code can be found here):
- Compliance with the Law
- Employment Standards:
- Child Labor/Young Labor/Forced Labor
- Health and Safety
- Freedom of Association, Discrimination, and Disciplinary Practices
- Working Hours and Compensation
- Environment
- C-TPAT (Customs Trade Pact Against Terrorism)
Additionally, our Vendor/Manufacturing Agreement specifically requires the
vendor/manufacturer to warrant and represent that “it is not engaged in, and will not engage
in any activities which are in violation of any applicable domestic, foreign or international
laws, rules, or regulations, including without limitation, laws, rules or regulations governing
labor.”
Vendors agree to comply with the Code and to disclose the names and addresses
of every factory, contractor, and sub-contractor that they use to produce raw materials
and/or garments for Volcom. All of these factories, contractors, and sub-contractors must
also comply with the Code, otherwise our vendors are not allowed to do business with them.
Lastly, the vendors agree to allow Volcom staff and representatives to inspect the
facilities to ensure compliance by visiting or conducting audits. Volcom reserves the right to
discontinue business with vendors who do not comply with the Code or who work with
factories, contractors, and sub-contractors that do not comply.
Internal Accountability
Volcom requires all new hires to sign and agree to comply
with our Code of Business Conduct & Ethics and Reporting Fraud. This Code
specifically states that “Volcom employees must comply with all applicable labor and
employment laws, including anti-discrimination laws and laws related to freedom of
association, privacy and collective bargaining.” If there is ever a violation of the Code,
employees have a duty to report the violation to their supervisor or department head, or a
member of the senior management. All reports are handled anonymously.
The Code further explains how violations are handled:
It is Volcom’s policy that any employee who violates this Code will be subject to
appropriate discipline, including possible termination of employment. This determination will
be based upon the facts and circumstances of each particular situation. An employee who is
thought to have possibly violated this Code will be given an opportunity to present his or her
version of the events at issue prior to any determination of appropriate discipline.
Volcom is in the process of educating our contractors and
business partners on the hazards of human trafficking and slavery, and encouraging them to
investigate their supply chains to eradicate this problem within their own organizations.
Training
Our Compliance Department continuously engages in online tutorials and
webinars to continue their training and deepen their knowledge regarding slavery and human
trafficking laws.
In addition to this online training, members of the design, merchandising,
production, compliance, and legal teams came together December 2, 2011 for a Corporate
Social Responsibility seminar hosted by Intertek, which focused on indentifying and
mitigating risks in the supply chain, particularly regarding factories’ employment practices.
Volcom plans to continue this training by conducting one-on-one meetings for new hires or
for employees with new responsibilities in the relevant area, as well as major group trainings
whenever there are new developments within slavery and human trafficking enforcement.
Our auditing partners provide compliance seminars in China that our vendors can
attend. Vendors are always welcome to contact Volcom’s Compliance Department at any time
with regards to any compliance questions or concerns, and the Department will work with
them to resolve any issues they may have.
Consumer Education
Volcom has always been supportive of its most avid fans. We hope that our
customers are as dedicated to eradicating slavery and human trafficking as we are. We would
appreciate the opportunity to answer any questions regarding our supply chain transparency
and compliance procedures.
Volcom is pleased to present this information for compliance with The California
Transparency in Supply Chains Act, which we feel is a good tool to enable companies to
explain their personal efforts to eradicate the practice of slave labor and human trafficking.
Hopefully, with our fellow brands’ help, our combined statements will make a large impact
on these dark areas of the industry and help move us towards a fairer manufacturing future.
