As a company governed by the California Transparency in Supply Chains Act, we are pleased to provide information about our efforts to stand up against the risks of slavery. The California Transparency in Supply Chains Act requires large retailers and manufacturers that do business in California to publicly disclose their efforts to eliminate slavery and human trafficking. The Act gives consumers access to the critical information needed to help them make more informed purchasing decisions and to ensure that the goods they buy come from product supply chains that are free from slavery, coercion, and human trafficking. rue21 strives for improvement and transparency in our supply chain because our customers know that social responsibility is always in fashion. Below are the five disclosure categories of the California Transparency in Supply Chains Act and our efforts to comply with each aspect of the law:
Engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery.
rue21 engages in third-party audits to verify details about our suppliers and evaluate the potential risks of forced labor in our supply chain. Documentation is requested from new vendors upon the first communication. We follow up quarterly and ensure that all documentation and audits have been completed within the last 12 months. Since the presence of labor brokers may increase the risk of slavery and human trafficking, rue21 refrains from using labor brokers to keep the recruitment of workers under our own control.
Provide company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.
At rue21, the Vendor Relations Department is trained on the Vendor Compliance Manual, which includes specific chapters on social compliance and factory social audits. The department is also trained on ways to identify trafficking and how to follow up with vendors to ensure that risks of forced labor are diminished. rue21 trains the Vendor Relations employees upon their entry to the company, and we are thereafter open for questions and suggestions on ways to better safeguard against slavery and human trafficking in our supply chains.
Conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.
rue21 conducts quarterly, third-party supplier audits of all of our active vendors. We request copies of the audit documentation from all factories that manufacture rue21 merchandise, and we keep up-to-date factory audit documentation on file to ensure current compliance.
Maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
To ensure that our standards on forced labor are met, an extensive list of Terms and Conditions accompanies every Purchase Order. The Employment Standards section of the Terms and Conditions states that the seller “represents and warrants that Seller and Seller’s subcontractors, if any, shall comply with any and all applicable international, national, federal, state, and local laws, rules and regulations governing labor or employee relations including, but not limited to, Sections 6, 7, 12 and 14 of the Fair Labor Standards Act, as amended, all labor standards set forth in any treaty or international convention, and any and all applicable child labor laws.”
Require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
Prior to purchasing merchandise from a vendor, rue21 requires suppliers to sign our Vendor Compliance Agreement, which states that the vendor “agrees that all merchandise purchased by rue21 from the Vendor will be manufactured, packaged and shipped or transported in accordance and in compliance with all laws and regulations of any applicable country of origin, including, without limitation, all applicable child labor laws.” Should a vendor fail to strictly comply with the Agreement with respect to any transaction, rue21 may cancel the transaction, reject or revoke acceptance of any goods that have been delivered with respect to that transaction, and cancel any other transaction with the vendor for goods that have not been accepted by rue21.
We also request that each supplier provide documentation that raw materials used in the manufacturing process are produced in compliance with applicable laws on forced labor and human trafficking. The types of documentation we request include payroll files, proof of age of workers, paid overtime records, employees’ timesheets, and documents regarding the number of employees working at a given time. Third party auditors also enter the factories to complete safety checks and to give employees opportunities to participate in anonymous interviews regarding their conditions of employment.