California Transparency in Supply Chains Act Disclosure
Fear of God supports ethical and responsible sourcing practices. In compliance with the California Transparency in Supply Chains Act of 2010 (SB 657), we are disclosing our efforts to eradicate slavery and human trafficking from our direct supply chain.
1. Verification
Fear of God works closely with our suppliers to identify and eliminate slavery and ensure fair working conditions in our supply chain. To that end, we engage in risk-based verification, tailoring the anti-slavery requirements we place on our direct suppliers to the unique risks they face. Every production site in our direct supply chain receives a unique risk rating that utilizes industry standard third party audit reporting, audit data, and supplier history, including prior non-compliance. This process includes close consideration of country and regional risks and, as appropriate, those risks are incorporated into the supplier risk rating. Fear of God also employs protocols to conduct additional internal verification on certain product lines on a risk-based basis.
Fear of God’s verification steps include a contractual commitment from our direct suppliers to take steps to combat slavery. For instance, our direct suppliers are required to affirm their commitment to taking proactive steps to combat slavery and ensure fair working conditions within their respective supply chains as part of their compliance with Fear of God’s vendor policies.
As a company, we are committed to continual review and improvement as we seek to identify ways to be more effective in our efforts to combat unethical work practices. Accordingly, we are continually reviewing these policies and procedures to monitor their effectiveness and identify areas of improvement.
2. Audits
Fear of God audits suppliers for compliance with human trafficking laws, ethical sourcing, and our supplier requirements. These audits are conducted on a risk-based basis and are “semi-announced,” meaning that the audits are either fully unannounced or suppliers are only provided a brief notice before the audit team visit. Audits may consist of site visits, interviews, and/or a review of the supplier’s records.
In addition, all of Fear of God’s primary production sites have a monitoring program utilizing quality control inspectors or an alternative approved by Fear of God. Relatedly, suppliers are encouraged to designate at least one staff member responsible for centrally managing ethical employment requirements.
3. Certification
Fear of God requires direct suppliers to annually certify compliance with trafficking and slavery laws in the country or countries in which they are doing business. In addition, direct suppliers must affirm their commitment to compliance with Fear of God’s policies and expectations as outlined in its vendor manual, which explains our expectations regarding eliminating slavery and ensuring fair working conditions.
Fear of God endorses the transparency in supply chains provision of the Modern Slavery Act, focusing on the eradication of modern slavery and human trafficking.
4.
Internal Accountability
Fear of God has strict policies and enforcement processes for suppliers who fail to meet standards or comply with our requirements regarding ethical work environments. Should an existing supplier fail to meet our requirements, the supplier must formulate an actionable plan with specific, articulable timelines to remediate the supplier’s failures and implement any necessary improvements.
Fear of God reserves the right to terminate the supplier relationship for non-compliance. That said, while suppliers are held responsible for reaching set standards, Fear of God collaborates with all related parties to ensure factory management teams make improvements to meet our standards.
5. Training
Fear of God employees who are directly involved in purchasing from suppliers and engaging with supplier relationships receive annual in-depth training that directly addresses identifying and combating modern slavery, unethical behavior, and fair working conditions.