The California Transparency in Supply Chains Act of 2010 (the “Act”) requires certain manufacturers and retailers doing business in California to make available information regarding their efforts to address the issue of slavery and human trafficking in their direct supply chains. We fully support the goals of the Act and are proud of our commitment to the protection of human rights and to conducting business in an ethical manner. This commitment is reflected in the Delta Apparel, Inc. Ethics Policy Statement (the “Ethics Policy”), to which all of our employees are required to adhere.
Our Ethics Policy requires all business activities, including our sourcing and procurement activities, to be conducted in full compliance with all applicable laws and regulations, including the laws of the United States as well as those of other countries within which we operate. This obligation specifically includes compliance with laws prohibiting the use of involuntary or forced labor. In addition, our supplier conduct standards require our suppliers to, among other things, operate their businesses in full compliance with all applicable laws, regulations and ethical standards, and not utilize forced labor. Further, our customers and business partners, who include some of the largest and most respected brands in the world, maintain robust social responsibility standards prohibiting the use of forced labor and human trafficking that we must meet as a condition of doing business.
Verification and Audit
We invest significant time and resources in ensuring that the working conditions in our facilities meet or exceed the standards imposed by applicable laws. We have obtained Worldwide Responsible Accredited Production (WRAP) certification for all of our manufacturing facilities in the United States, Honduras, El Salvador and Mexico. WRAP certification requires a rigorous self-monitoring and accredited third party auditing process designed to ensure compliance with a variety of principles based on applicable laws and international labor conventions, including a prohibition on the use of involuntary or forced labor. We also adhere to the Fair Labor Association (FLA) Workplace Code of Conduct, which prohibits the use of forced labor.
With respect to our suppliers, we may utilize internal or external resources to evaluate and conduct due diligence on potential suppliers with respect to social responsibility and legal compliance. We would not engage or continue to work with a supplier if we become aware of slavery or human trafficking concerns. We endeavor to verify that our suppliers comply with our Ethics Policy, our supplier conduct standards and applicable legal and regulatory requirements, including those related to slavery and human trafficking. Our supplier terms allow us to conduct unannounced audits and inspections with either our own employees or independent third parties to verify compliance with our standards and requirements, including those pertaining to the use of forced labor. In addition, our customers and business partners conduct periodic audits and on-site inspections for compliance with their conduct standards and legal requirements. Moreover, some of our suppliers have their own codes of conduct and auditing programs and share their audit results with us. All of these mechanisms facilitate verification that our suppliers comply with applicable laws, regulations and standards, including those relating to the use of forced labor.
Certification
As a part of our supplier application process, potential suppliers are required to agree in writing to refrain from utilizing forced labor. In addition, our supplier terms require our suppliers to warrant that all products and services are provided in strict accordance with all applicable laws and regulations, including those relating to slavery and human trafficking, and to provide certifications and supporting data regarding such compliance upon request. Our supplier terms also require our suppliers to warrant that they will comply with our Ethics Policy and FLA Workplace Code of Conduct in the performance of their obligations.
Internal Accountability
If any employee fails to comply with our Ethics Policy or applicable laws or regulations, we will take the appropriate remedial action and reserve the right to terminate our relationship with the employee depending upon the nature of the circumstances. Should a supplier fail to meet our standards or otherwise comply with applicable laws and regulations, we reserve the right to terminate our relationship with that supplier. In addition, employees who interact with suppliers are expected to report any potentially unlawful or unethical conduct within our supply chain of which they become aware, including the presence of slavery or human trafficking, and any such report will be promptly and appropriately investigated. Moreover, our Ethics Policy contains clear reporting mechanisms that allow for the anonymous reporting of issues regarding the use of forced labor and prohibits retaliation against those reporting or providing information.
Training
We currently do not provide training that is specific to slavery and human trafficking. However, each of our employees is required to review and acknowledge compliance with our Ethics Policy, which identifies the principles under which we conduct business and deal with employees and suppliers. Moreover, our sourcing and procurement teams are well aware of our social responsibility requirements and the need to be cognizant of these issues in connection with our supplier and facility selection and certification efforts.