Taking an ethical approach to sourcing
In the Fall of 2004 our Chairman and Board of Directors gave the directive to create a comprehensive Social Compliance and Human Rights Program for Coldwater Creek. The goal of the Program is to assure that our products are manufactured in facilities that are operating in compliance with our Code of Conduct which outlines our position on child labor, forced labor, slavery, human trafficking, working hours and compensation, and disciplinary practices and/or coercion. Our Program requires our apparel suppliers to abide by global standards and local laws and regulations regarding human rights.
Today the Program encompasses all apparel suppliers. Each factory is required to undergo an annual audit by an independent firm, and may be subject to additional review by our compliance team. The result of each annual audit is a detailed corrective action plan highlighting all areas identified as needing improvement. The implementation of the corrective action plan is then monitored by our internal compliance team.
Our production is primarily centered in Asia, Southeast Asia and the Asia Sub-continent along with some production in Central America.
Specifically, our Program includes the following elements relative to the guidelines set forth in the California Transparency in Supply Chain Act of 2010 –
- Has implemented procedures for the review of all apparel production facilities from both an operational and human rights perspective prior to beginning a business relationship, to evaluate and address issues of human trafficking and slavery. These review procedures are conducted internally and not by a third party.
- Routinely audits all active apparel production facilities. Audits are completed by an independent third party and our internal compliance team. These audits are both announced and unannounced. The focus of these audits is to assure compliance with our Code of Conduct, and with applicable local laws and regulations.
- Does not require direct suppliers to certify that materials incorporated into our products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
- Maintains accountability standards for direct suppliers, employees and/or contractors who fail to meet our standards regarding slavery, human trafficking or any aspect of our Code of Conduct.
- Is reviewing best practices of established programs with the intention to be prepared to establish a training program as standards are established.