UpWest sources our products and raw materials from all over the globe. Our approved suppliers must verify in writing that they follow the UpWest Supplier Code of Conduct, and we require our product suppliers in our supply chain comply with all applicable laws, rules, and regulations.
OUR SOURCING POLICIES
In our work to ensure that all of our manufacturing partners comply with our Code of Conduct, we employ independent, third-party auditors that audit our factory partners, unannounced or semi-announced, on our behalf annually. Our overall Social Responsibility and Factory Audit Programs are built around 4 foundational pillars:
- UpWest Supplier Code of Conduct
- Compliance with National & Local laws
- International Labor Organization (ILO) conventions for forced or trafficked labor and
- Ongoing benchmarking and analysis amongst peers and other retail industry organization participants.
In addition to our 4 foundational pillars, our factory audits have 15 different focus areas that are evaluated during each audit. These focus areas help us ensure that our factory partners continue to provide a healthy, safe working environment for all participants within the manufacturing process.
- Transparency & Business Integrity
- Management Systems
- Hiring, Discipline & Termination
- Young Worker and Child Labor
- Forced Labor
- Harassment or Abuse
- Freedom of Association & Grievance Mechanisms
- Foreign Migrant Labor
- Wages and Benefits
- Hours of Work
- Health & Safety
SUPPLIER CODE OF CONDUCT
UpWest requires all suppliers and subcontractors to fully comply with the following Code of Conduct:
- Compliance with Laws
Suppliers are obligated to identify and comply with all international, national, regional and local laws and regulations applicable to their operations. This obligation also includes ensuring that any required certificates, licenses, permits and/or registrations are and remain current, and all activity undertaken by suppliers does not extend beyond the scope of those authorizations.
- Minimum Wages and Benefits
Suppliers shall ensure that workers are paid wages equal to the minimum wage prescribed by local law or the prevailing local industry wage, whichever is higher. Suppliers shall also ensure that workers are compensated for overtime and are provided benefits that conform to the better of applicable local law or prevailing local industry standards. All such payments must be made in legal tender, on a regular basis and in a timely manner.
- Maximum Working Hours
Overtime shall be limited to a level consistent with humane and productive working conditions. Workers shall not be required, on a regularly scheduled basis, to work in excess of sixty hours per week, or a lesser amount if prescribed by local laws or local industry standards. Workers shall also be provided with at least one day off in seven, along with adequate rest breaks during the workday consistent with applicable local legal requirements.
- No Forced Labor
UpWest will not accept any form of forced labor in its supply chain, whether that be in the form of prison, indentured, bonded, involuntary, coerced or slave labor, or as labor obtained through human trafficking or other forms of exploitation. All labor must be voluntary and provide workers with full freedom of movement. Suppliers are not permitted to retain any personal identification, travel documents or wages as a condition of employment, with workers provided complete details about their employment in their native language including all rights, responsibilities and information pertinent to their wages, hours and established time off. UpWest utilizes all indicators of forced labor identified by the International Labor Organization ("ILO") for purposes of identifying whether forced labor may be found in its supply chain with any confirmed violation establishing the basis for an immediate termination of any existing contractual relationship.
- No Child Labor
The use of child labor by any supplier, whether in the form of employee or contracted labor, will not be tolerated. No individuals may be hired who are under 15 years of age, under the age consistent with local law and applicable ILO Conventions, or under the otherwise legal minimum age for employment in the country, whichever of those ages is greatest.
- Health and Safety
Suppliers shall ensure that the work environment remains safe and healthy, including ensuring that workers are protected against any physical or operational hazard. Workers should be properly trained on all equipment, provided with any required safety or operational gear and apprised of applicable occupational health and safety policies and procedures including those pertaining to emergency evacuation. All workers must also retain the right without retribution to refuse to work under conditions that would compromise their health and safety. A safe and healthy working environment also includes ready access to potable drinking water, adequate lighting, ventilation and sanitation as well as, where applicable, safe and healthy company living quarters.
Hiring and employment decisions, including those relating to compensation, benefits, promotion, training and development, discipline and termination must be based solely on the worker’s skill, ability, experience and performance and not on the basis of discriminatory intent including on the basis of characteristics such as race, national origin, gender, age, physical characteristics, social origin, disability, union membership, religion, family status, pregnancy, sexual orientation, gender identity, gender expression or any unlawful factor under applicable law.
- No Corporal Punishment
Neither corporal punishment nor any other form of physical or psychological coercion, threatened or otherwise, shall be used against workers.
- Freedom of Association
The lawful exercise of workers' rights of free association and collective bargaining shall be respected and not restricted or interfered with. Workers' ability to voluntarily form, join or not join trade unions or other organizations shall be unconstrained without fear of reprisal in the form of discrimination, retaliation, harassment or intimidation.
Suppliers must have controls in place that ensure compliance with all applicable anti-corruption and anti-bribery laws, rules and regulations and anti-bribery policies and requirements established by UpWest.
Suppliers must ensure that their operations are in compliance with all applicable environmental laws and regulations, including but not limited to those related to waste disposal, hazardous waste, emissions, wastewater and toxic substances. All required environmental permits and/or licenses must be secured and kept current and all operational, registration and reporting requirements followed.
- Community Involvement
Projects undertaken in partnership with community groups or local or international non-governmental organizations (NGOs), particularly those that address educational opportunities for younger people employed in production facilities, shall be encouraged and supported.
For the purpose of monitoring compliance with our policies, UpWest and its subcontractors and agents shall be given unrestricted access to all receiving, production and warehousing facilities and dormitories and to all relevant records, whether or not notice is provided in advance.
UpWest does not allow unauthorized subcontracting. A formal request must be submitted to UpWest for approval should a supplier require subcontracting.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
UpWest is dedicated to eliminating human trafficking and forced labor on all levels of our supply chain. Below are the steps UpWest is taking in furtherance of this goal.
- Supply Chain Verification. Our list of qualified suppliers and factories is established and maintained in reliance on specific qualification standards and protocols developed by us, in conjunction with our independent third party service provider, which specializes in supply chain compliance. First, our sourcing process includes a supplier verification procedure designed to ensure that we work only with suppliers who are committed to meeting our supply chain standards. Once a supplier is verified, the relationship begins with a written Master Sourcing Agreement (MSA) wherein the supplier agrees that it and the factories that it contracts with will adhere to our sourcing and labor standards, including those prohibiting slavery and human trafficking.
- Audit Procedures. Each supplier that we verify must agree to allow us, or an independent third party hired by us through our independent service provider, to conduct an audit of the supplier’s business unannounced, without prior notice, to ensure compliance with our human trafficking and forced labor standards. Generally, a third party conducts announced or unannounced audits of each of our approved factories at least annually to ensure compliance. We, through our third party service provider, may conduct more frequent reviews of suppliers located in countries designated as high risk by the U.S. State Department’s Trafficking In Persons Report. Exemptions from annual audits may be granted to highly compliant factories based on the previous year’s audit scores.
- Supplier Certification. Each supplier is required to sign an MSA in which they agree that they will comply with our Supplier Code of Conduct. The Supplier Code of Conduct requires our suppliers to comply with all applicable laws and policies, including prohibitions against child labor and forced labor.
- Internal Accountability. UpWest will not work with those who are unable or unwilling to meet our standards. We maintain policies and procedures which govern the consequences of non-compliance by associates or suppliers. Suppliers are informed of these policies and procedures and the consequences of non-compliance through receipt of a compliance guidebook. If any one of our suppliers falls below the standards listed in our Supplier Code of Conduct, we attempt to bring them into compliance by supporting them in making the necessary changes through corrective action plans.
- Training. We are committed to supplier and associate education. Our third party service provider conducts annual awareness and training sessions for our suppliers on our sourcing standards in multiple countries around the world. In addition, our third party service provider engages in one-on-one training in conjunction with routine audits and corrective action plans. Also, we assure that our associates fully understand and comply with our sourcing policies and procedures. Associates directly involved in supply chain management receive training on human trafficking that discusses the risks of human trafficking and actions that can be taken to mitigate the risk of human trafficking.
- Collaboration. We are committed to collaborating with others to eradicate human trafficking and support the work of international agencies and organizations dedicated to this cause.
RESPONSIBLE SOURCING PRACTICES
UpWest strives to maintain responsible and ethical sourcing practices and utilizes independent third-party auditors who consistently monitor our supply chain to ensure our standards are being met. Our independent third-party auditors also monitor our suppliers’ processes and procedures to ensure compliance with the requirements set forth in our code of conduct. Our commitment to responsible and ethical sourcing practices includes strict adherence to the following:
UpWest prohibits its suppliers from utilizing operations or materials in or from Xinjiang Uyghur Autonomous Region in the production of UpWest goods.
Uzbek and Turkmen cotton
UpWest prohibits the use of any cotton from Uzbekistan and Turkmenistan in the production of our product.
UpWest does not use any Alpaca in our products. While we do carry some products that contain wool or wool blends, our wool use is limited to non mulsed or recycled.
UpWest does not support the practice of sandblasting during the manufacturing of our goods. This is monitored through our rigorous product development process and monitored during factory visits and audits.
UpWest is committed to (1) compliance with the Conflict Minerals Rule that was adopted pursuant to Section 1502 of the Dodd-Frank Act, and (2) avoiding the use of Conflict Minerals which may directly or indirectly finance or benefit armed groups engaging in human rights abuses in the eastern Democratic Republic of the Congo. Conflict Minerals means columbite-tantalite (colton), cassiterite, gold, wolframite, and the derivatives tantalum, tin, and tungsten. We also expect our suppliers to communicate with us regarding their use of Conflict Minerals, including providing complete, accurate, and timely responses to surveys and other inquiries by UpWest.