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GEAR For Sports - Labor Compliance Program in Year Two1

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, GEAR for Sports ("GEAR") completed the first year of its initial implementation period of the FLA program. GEAR's Global Human Rights Program is the department responsible for ensuring compliance with the GEAR For Sports/Champion Custom Code of Conduct, which corresponds to the FLA Code of Conduct. During the reporting period, the Global Human Rights Program consisted of one full-time staff member, the Director of Logistics, Customs, and Global Human Rights, who managed and directed all the functions of the program. This position was supported by two staff members at corporate headquarters who assisted with managing FLA program requirements on a part-time basis. The Director of Logistics, Customs, and Global Human Rights reports to the Senior Vice President of Sourcing, Inventory Management, and Logistics, who in turn reports to the President/Chief Operating Officer.

The Global Human Rights program relied on the Quality Control staff of the company's agents/buying agent to communicate the Code to factory management, and conduct internal monitoring and remediation follow-up. In this first year of implementing FLA requirements, internal monitors conducted compliance audits of 20 facilities, which represented 60% of the company's factory base. In addition, GEAR reported that its Quality Control staff visited all contract factories on a weekly basis and, as such, were responsible for conducting informal reviews of workplace conditions in the course of their work.



Features of GEAR For Sports' Labor Compliance Program in Year Two1

A. Compliance Systems Developed in Year Two

In the first year of its initial implementation of the FLA program, GEAR's Global Human Rights Program focused on implementing FLA company obligations -- particularly factory monitoring and remediation -- and training its staff and internal monitors (i.e., Quality Control/Buying Agent staff) about FLA standards.
  • Those engaged in internal monitoring and remediation were introduced to the FLA monitoring protocol and audit instrument requirements, as well as some regional and country-specific labor issues.
  • Internal monitors conducted compliance audits of 20 facilities, which represented 60% of GEAR's factory base.
  • In Year Two, the staff responsible for monitoring in Honduras and Guatemala attended a meeting of multi-stakeholder participants in the FLA Central America Project. Suppliers for GEAR also attended the meeting, upon a strong recommendation from GEAR.

B. Improvements in Implementing the FLA Requirements

In Year Two, GEAR For Sports completed the first year of its initial implementation of the FLA program. Progress on its fulfillment of FLA requirements will be reported on in next year's report.



1 Please 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.