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Eddie Bauer - Labor Compliance Program in Year Two

Overview of the Program
Program Features

  1. Compliance Systems Developed in Year Two
  2. Improvements in Implementing the FLA Requirements

Overview of the Program

In Year Two, Eddie Bauer's Global Labor Practice Program continued its compliance work with respect to Eddie Bauer's Code of Conduct, which corresponds to the FLA Code of Conduct. The company experienced bankruptcy, however, in Year Two, which had a direct effect on relationships with suppliers, as well as the Global Labor Practices' Program's monitoring plan. As a result, Eddie Bauer Compliance staff members focused on key compliance activities in an effort to uphold the company's FLA obligations despite bankruptcy.

In Year Two, the Global Labor Practices Program was managed by the Director of Public Affairs and Corporate Social Responsibility, who reports to the Divisional Vice President of Sourcing and Production. Two full-time compliance staff members at headquarters coordinated with two full-time compliance staff members in Asia to administer the program. Approximately 14 staff members from various divisions of Eddie Bauer -- including corporate and overseas sourcing staff, merchandising staff, and senior management -- have part-time responsibilities for compliance work. At the field level, merchandising and sourcing staff communicated Eddie Bauer's Code to factories, assisted with internal audits, and followed-up on some remediation plans.

Eddie Bauer contracted the monitoring company Global Social Compliance to conduct 34 first-time monitoring visits to new sourcing facilities in Year Two. Eddie Bauer staff conducted all other monitoring visits during this period.



Features of Eddie Bauer's Labor Compliance Program in Year Two1

A. Compliance Systems Developed in Year Two

In Year Two, Eddie Bauer instituted a pre-sourcing protocol requiring all new contractors to submit to and pay for a complete monitoring visit by a third-party monitor (Global Social Compliance) prior to being accepted into the company's factory base. Eddie Bauer reported that conditioning business on compliance in some instances encouraged factories to take proactive measures to improve their compliance systems in advance of the monitoring visit.

Eddie Bauer reported that it focused much of its compliance efforts in Year Two on China in response to various findings there, relating primarily to hours of work and fair compensation. Fraudulent records kept by factories in China were also a main concern for the company. With a view to addressing these issues, the Global Labor Practices Program conducted unannounced internal monitoring visits more frequently in China, and remediation was overseen through more frequent return visits and follow-up communications. Factories were encouraged to address management systems that contributed to noncompliance issues. In several cases, the company reported having successfully influenced vendors and factories to hire specialized compliance staff or consultants to improve compliance systems.

FLA independent monitoring in four Eddie Bauer facilities in China and Hong Kong supported the company's observation that working hours and overtime compensation are challenging issues in the company's applicable facilities in the region. At the time of drafting this report, Eddie Bauer had completed follow-up visits to at least two of the facilities monitored by the FLA in order to observe the extent to which remediation of issues relating to working hours and other Code provisions had been undertaken. The company reported positive progress in this regard, but added that further follow-up is in order. Click here to review progress in these facilities.

It is worth noting that due to bankruptcy, Eddie Bauer reported having limited resources to fund special initiatives/projects in Year Two. Therefore, the Global Labor Practices Program focused on its core programs, namely monitoring and remediation.

Click here to see the Year One report on Eddie Bauer.

B. Improvements in Implementing the FLA Requirements

  • A new full-time Senior Labor Practices Auditor was hired during the reporting period. She helped to develop Eddie Bauer's compliance program in Asia, and provided training to the Assistant Compliance Auditor based in the region.
  • In Year Two, the Global Labor Compliance Program conducted half-day compliance training seminars in Hong Kong, China (Dongguan and Shanghai), Thailand and Taiwan for approximately 60 Eddie Bauer staff members. The seminars addressed local labor law and compliance challenges, FLA participation requirements, and monitoring methods. The trainer also conducted onsite factory trainings with selected staff members as a supplementary compliance exercise.
  • Eddie Bauer participated in a two-day interactive training that focused on worker interview techniques. The training was conducted by Verite and took place in Portland, OR. The two Global Labor Compliance Program staff members who attended the training used their new skills to train other staff members at headquarters and in Asia.
Click here to review Eddie Bauer's activities in Year One.



1Please note that this section in no way seeks to capture all of the compliance activities reported to the FLA by companies. Instead, the FLA considers it an overview of company activities that will provide the reader with a better understanding of each company's approach and focus in Year Two.