Russell行为守则合规性评估

CODE OF CONDUCT COMPLIANCE EVALUATION

The following is a simple outline of the Assessment procedures. The evaluations do not necessarily follow this

order, however all steps are completed during the Assessment. In addition, if further steps or documents are needed in order to have a complete understanding of the facility situation, they may be requested and should be provided.

Management such as factory owner, general manager or human resource personnel should be present during the

Assessment. Otherwise, anyone who has delegated authority to provide the documents needed and answer the

questions from the Third Party Monitor could assist in the process.

•  The Third Party Monitor(s) arrives at the facility and present business cards and their company badge.

•  An Opening Meeting is held with the facility’s contact person, preferably management. During this

meeting, the format of the Assessment is described. If the facility has a legally constituted union a member

of the union board must be present during the opening and closing meetings.

•  The production manager and the human resource personnel are needed in order to answer a series of

questions regarding production capacity, machines, lead times, hiring practices and security procedures.

•  Company policies, handbooks, and management systems are reviewed.

•  Private employee interviews are conducted. The Third Party Monitor selects the employees to be

interviewed in private, without management present. Employees are asked questions regarding hours of

work, length of employment, their understanding of disciplinary policies of the factory, hiring policy, and

working conditions.

FRUIT OF THE LOOM, INC. WILL NOT TOLERATE RETALIATION AGAINST FACILITIES

EMPLOYEES WHO PARTICIPATE IN INTERVIEWS OR ANY OTHER PARTS OF OUR CODE OF

CONDUCT COMPLIANCE ASSESSMENTS. IF FRUIT OF THE LOOM, INC RECEIVES

COMPLAINS OF EMPLOYEE RETALIATION FROM ANY RELIABLE SOURCE PRODUCTION

AT THE FACILITY WILL BE TERMINATED.

•  Payroll documentation is reviewed. Payroll journals, timecards, production records, attendance books,

proof of insurance payment or tax payment (if applicable) must be provided to the Third Party Monitor for

a complete Assessment to take place. The Third Party Monitor evaluates that the regional minimum wage

is provided to all employees for all hours worked, including overtime compensation. Also it is evaluated

whether maximum hours authorized to work, including weekend and evening hours, are in compliance

with regional labor laws.

•  Employee records are reviewed. Proof of age documentation must be available.

•  A walkthrough of the facility is conducted. Here the health and safety conditions of the facility are

evaluated, as is the production capacity. Dormitory, housing and childcare units, if provided, also need to

be inspected by the Third Party Monitor. The eating area or cafeteria used by the workers is also checked,

as is the kitchen if cooking takes place onsite.

•  Photographs of the facility are also taken with permission from management.

•  Copies of operating licenses and other government issued permits are also reviewed.

•  Security of the facility will be evaluated, with attention to physical security features as well as factory

policies concerning security.

•  A Closing Meeting is held at the conclusion of the Assessment. A Corrective Action Plan (CAP) report is

completed listing all identified violations (if any). All violations are discussed with the facility

management and union representatives (if applicable).