CORPORATE SOCIAL RESPONSIBILITY PROGRAM

CORPORATE SOCIAL RESPONISIBILITY PROGRAM
CODE OF CONDUCT

2017


TABLE OF CONTENTS

Page 1 Mission Statement
Page 2 Code of Conduct
Page 3 Compliance Program
Page 4 Factory Information
Page 5 Sourcing
Page 6 Internal Monitoring
Page 7 Remediate Noncompliance


MISSION STATEMENT
Create great sportswear in a thriving, fun, profitable, win-win environment.

Produce high quality, affordable clothing for young sports-minded people. Provide an environment where employees can grow to their full potential. Ensure a good profit to all parties involved, and have fun doing it.
Garb is committed to overseeing all factories that produce and embellish collegiate-licensed goods in order to ensure factories are having a positive impact on the countries they are in. Garb’s Corporate Social Responsibility Program plays an integral part in the decision-making and product sourcing strategies of the company.

GARB CODE OF CONDUCT

Garb’s Code of Conduct is used throughout the process of selecting and retaining business partners who agree with, and share our same values and commitment to social responsibility.

Forced Labor: There shall not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor, etc.
Child Labor: No person shall be employed at an age younger than 15 or under the age for completion of compulsory education, whichever is higher.
Harassment or Abuse: Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological or verbal harassment or abuse.
Nondiscrimination: No person shall be subject to any discrimination in employment, including hiring, salary, benefits, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin.
Health and Safety: Employers shall provide a safe and healthy working environment to prevent accidents and injury to health arising out of, linked with or occurring in the course of work or as a result of the operation of employer facilities.
Freedom of Association and Collective Bargaining: Employers shall recognize and respect the right of employees to freedom of association and collective bargaining.
Wages and Benefits: Employers recognize that wages are essential to meeting employee’s basic needs. Employers shall pay employees at least the minimum wage required by local law or the prevailing industry wage – whichever is higher, and shall provide legally mandated benefits.
Hours of Work: Employers shall not require workers to work more than the regular or overtime hours allowed by the law of the country where the workers are employed. The regular work week shall not exceed 48 hours. Employers shall allow workers at least 24 consecutive hours of rest in every seven day period. All overtime work shall be consensual between employer and employee. A regular work week and overtime hours will be determined based on the law of the country where the workers are employed. All overtime work will be compensated at a premium rate, or as is legally required in the country of the manufacturer. In countries where such laws do not exist, a rate at least equal to their regular rate is required.

GARB CODE OF CONDUCT (CONT.)

Compensation: Every worker has a right to compensation for a regular work week that is sufficient to meet the workers’ basic needs and provide some discretionary income. Employers shall pay at least the minimum wage, comply with all legal requirements on wages, and provide any fringe benefit by law or contract.
Employment Relationship: Employers shall adopt and adhere to rules and conditions of employment that respect workers and safeguard their rights under national and international labor and social security laws.

Garb’s Code of Conduct will be communicated to all management, employees and participating factories through written and verbal communication.
A copy of Garb’s Code of Conduct will be translated to the main language of all factories located in non-English speaking countries. For illiterate workers, a factory representative will verbally discuss the code once a year. The factory representative must then sign and return a confirmation that the Garb Code of Conduct was explained prior to production.

COMPLIANCE PROGRAM
Garb has recently contracted with Sumerra as our factory and compliance solution. We will be following their lead to update our program and maintain a high standard with our vendors. Sumerra can be contacted at –
Sumeet Kumar
Compliance Program Coordinator
P: +91 80 6793 5725, + 91 80 23256539
S: sumeetk92 skumar@sumerra.com

Garb has a Compliance Committee that will meet once a month to discuss Garb’s code of conduct, compliance program and the training tools used to relay our standards to all internal and external employees associated with Garb Inc. This committee includes:
David Heimbach – Director of Operations
Dave is Garb’s main communication contact with our factory representative in India. At least once a year he is responsible for communicating the Code of Conduct with the factory representative. He is also responsible for completing FLA’s Auditing form for all contract facilities oversees.

Juli Messenger – Licensing Coordinator


FACTORY INFORMATION
The following is a list of factories in which blank goods are sourced/logo is applied:
• Royal India Clothing
• SAI Business Point, II Floor,
17 Mount Road, Saidapet,
Chennai 600 015, India
• jaheez@securaintl.com
• Phone: 33100863773
• Product Information: Infant, Toddler and Youth apparel
• Nature of Business Association: Vendor/Supplier – manufacturer and supplier of blank goods
• R.K. Knitwear
• Contact Person: Mr. R Thirquiam
• No. 9/3T 4&5 Karuppanayan Kovil St
Anpurpalayam Bst, India 641652
• Phone: 91-44-42100043
• Email: ravi@rkknitwear.in or jaheez@securaintl.com
• Product Information: Infant, Toddler and Youth apparel
• Nature of Business Association: Vendor/Supplier – manufacturer and supplier of blank goods.
• N.R.K Impex
• Contact Person: Mr. Kannen
• No 30 Rajulu Illu Sri Bannari Amman Nagar
Chandrapuram East Sevanthampalaym Road, K.N.P Colony Post
Tirupur – 641 608. India
• Product Information: Infant, Toddler and Youth apparel
• Nature of Business Association: Vendor/Supplier – manufacturer and supplier of blank goods.
• MIDWAY
• Contact Person: T.T.P. JAHEEZ UDDIN
• MIDWAY APPARELS INDIA PRIVATE LIMITED
54/4, V.S.S.GARDEN,
SIDCO EAST CROSS, KANGAYAM MAIN ROAD,
TIRUPUR – 641 606,
INDIA
• jaheez@securaintl.com
• Phone: 33100863773
• Nature of Business Association: Vendor/Supplier – manufacturer and supplier of blank goods.
SOURCING
David Heimbach, Director of Operations at Garb Inc. did live in Tirupur from March 1, 2016 – June 1, 2016 to oversee all production of team apparel. David did conduct extensive auditing with each factory with the forms and resources that were provided by the Fair Labor Association. He will be returning this year in Early April for our 2017 visit will conduct another extensive round of auditing to update our records.

Sourcing decisions will be based on:
Quality Samples
Pricing
Acceptable lead-times
Factory Survey – A survey will be given to all potential clients. The survey must be filled out, signed and returned within 2 weeks of distribution. If the factory does not cooperate or does not meet our company standards it will be considered a non-compliant factory, and will therefore not be used.


CONDUCTING INTERNAL MONITORING
Garb is committed to doing business with socially responsible and ethical companies, employees and factories. A number of pre-sourcing / pre-production social compliance evaluations are required before using a new applicable facility. Evaluations are conducted through annual company staff visits.
In the past year a Garb representative, David Heimbach, has traveled to India to conduct a full audit and review factory programs and company standards. All facilities are required to conduct internal monitoring.
Garb works with Secura Intl to ensure that our Compliance strategies and Code of Conduct are being translated to all factories.


REMEDIATE NONCOMPLIANCE
David Heimbach will be in charge of tracking remediation. Upon receiving the internal audit, the supplier will be contacted within 14 days to agree to a remediation plan that addresses any compliance issues found by the monitor. The remediation plan will include steps that will prevent the recurrence of noncompliance issues. Monthly updates from the supplier and written confirmation and proof of progress will be required from the Factory Representative.
Compliance issues will be taken into consideration when making future decisions on whether or not to use a specific factory.