TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010 AND THE UK MODERN SLAVERY ACT
Effective January 1, 2012; Revised February 1, 2019
Approved by TaylorMade’s Board of Directors
TaylorMade is committed to conducting business in a legal, ethical and responsible manner, and we expect the same commitment from our suppliers. This disclosure describes TaylorMade’s global efforts to ensure that the goods we make and sell are not produced by workers who are enslaved, coerced, or otherwise forced into servitude, or who have been victims of human trafficking. On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. The UK Modern Slavery Act came into force in October 2015. These laws describe the information to be made available by manufacturers and retailers regarding their efforts (if any) to address the issue of slavery and human trafficking.
TaylorMade makes significant efforts to verify the absence of forced labor and human trafficking in its supply chain, including the following:
Supply Chain Verification
TaylorMade assesses potential suppliers based on a variety of factors that include the risk of forced labor and human trafficking.
TaylorMade requires potential suppliers to sign and return TaylorMade’s Supplier Responsibility Standards (the “Supplier Standards”), which expressly prohibit the use of forced and child labor, and establish guiding principles and requirements specific to eradicating forced labor and human trafficking from TaylorMade’s supply chain. By signing the Supplier Standards, potential suppliers acknowledge their receipt of and obligation to adhere to them.
Potential suppliers must also complete a factory self-assessment, which requires disclosure of data such as the number, gender, age, nationality, and language of their workers, the proportion of their work force that is temporary, any collective bargaining or worker representation structure, the type of work conducted by the supplier, worker grievance procedures, satisfaction of permit requirements, and wage and hour data.
TaylorMade utilizes the Fair Factories Clearinghouse, which is a compliance database that allows its members to access and share historical audit and factory information that is never deleted, such as factory profile data, internal audit results, commissioned external monitoring reports, and remediation activities. TaylorMade requires potential suppliers to disclose information necessary to establish supplier accounts in the Fair Factories Clearinghouse for themselves and any subcontractors.
A potential supplier’s failure to return a signed acknowledgment of the Supplier Standards, provide a completed self-assessment, or disclose sufficient information to establish a supplier account in the Fair Factories Clearinghouse prevents a supplier from being authorized for production.
Additionally, based on information obtained from self-assessments and the Fair Factories Clearinghouse, TaylorMade identifies certain factories and subcontractor factories requiring additional assessment before being authorized for production. Such additional assessments may be conducted either by TaylorMade personnel or an authorized external monitor.
Supply Chain Audits
TaylorMade may audit any supplier’s factory location without prior notice. Typical audits, however, are announced and are conducted by an authorized external monitor.
The frequency of audits depends on TaylorMade’s assessment of a supplier’s likelihood of compliance with the Supplier Standards. This assessment takes into consideration various factors, including a supplier’s location and type of work performed, as well as information obtained through the self-assessment process, the Fair Factories Clearinghouse, and any formal and informal audits and onsite visits made by TaylorMade personnel. Higher risk suppliers are typically audited annually.
TaylorMade encourages suppliers to directly recruit and hire employees. Suppliers who opt to use a broker to hire workers are required to conduct annual audits of their brokers to confirm compliance with applicable local laws and with the Supplier Standards. The results of such broker audits are typically sought by TaylorMade’s external monitor during any subsequent audit of the supplier.
TaylorMade tracks audit results and factory remediation in the Fair Factories Clearinghouse. Some audit findings result in a supplier’s rejection or termination, while others require remediation, a corresponding Corrective Action Plan, and subsequent re-assessment.
Supply Chain Certifications
All suppliers are required to adhere to the Supplier Standards. They are distributed to suppliers at least annually via trainings and email and are available in six languages. Each year suppliers must sign and return them, acknowledging their continued acceptance of and adherence to them. The Supplier Standards must be posted at all factory locations.
TaylorMade also requires suppliers to retain employment-related records in accordance with applicable local law, but in any event for at least three months. Such records must include workers’ age verification documentation, payroll and timesheets, terms and conditions of employment, worker complaints, and supplier responses to complaints. TaylorMade reserves the right to request these records at any time, and such records are routinely reviewed during audits.
TaylorMade’s supplier agreements also obligate suppliers to comply with the Supplier Standards and all applicable laws and regulations, including local laws regarding forced and child labor. Where there is a conflict between applicable law and the Supplier Standards, TaylorMade requires compliance with the stricter standard.
Suppliers must establish whistleblower and non-retaliation policies. They also must publish in all factory locations contact information so that workers can raise concerns, including those related to forced labor and the Supplier Standards, directly to TaylorMade.
TaylorMade’s Internal Accountability Standards
TaylorMade has a Compliance Committee that consists of members of senior leadership whose purview includes compliance issues globally, including those related to human trafficking and child labor. The Compliance Committee participates in development of policies and procedures that relate to forced and child labor, such as the Supplier Standards and the employee Code of Conduct, and, when appropriate, is involved in addressing violations of or failure to comply with these policies. Corrective steps may include termination of an employee, contractor, or supplier.
TaylorMade also maintains an e-mail hotline that employees may use to report any compliance-related issues or concerns without fear of retaliation. Submissions to the hotline are reviewed and addressed by the Compliance Committee.
Employee and Management Training
TaylorMade has a team of employees knowledgeable about and dedicated to supplier responsibility as it relates to supply chain management and ensuring the absence of forced, coerced, or child labor in our supply chain. TaylorMade trains its suppliers each year on a wide range of compliance topics that include forced and child labor and human trafficking. Training is conducted in the supplier’s language, by TaylorMade or in conjunction with a certified third-party compliance partner. Typical attendees are suppliers, plant managers, and human resources and environmental, health, and safety representatives.
At TaylorMade, we believe in the integrity of our supply chain and are dedicated to maintaining it. Accordingly, we may update this disclosure from time to time to reflect our current practices.
If you have questions about TaylorMade’s efforts to eradicate forced labor from its supply chain, please e-mail us at: firstname.lastname@example.org.
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