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Reebok's 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

Reebok's Human Rights Program is responsible for implementing Reebok's Human Rights Production Standards, which correspond with the FLA's Workplace Code of Conduct. In Year Two, the Human Rights team was comprised of 16 full-time and 7 part-time staff members, who were based around the world. Reebok divided its apparel and footwear sourcing base into three regions: South Asia/Europe/Middle East; East/North Asia; and Latin America/Mexico/United States. The program is headed by the Vice President of Human Rights Programs, who is based in the US and reports to Reebok International Ltd.'s CEO and Chairman of the Board.

In Year Two, all of the internal monitoring visits to Reebok footwear's facilities, as well as the majority of internal monitoring visits to Reebok apparel's facilities, were conducted by Reebok's Human Rights staff. (See FLA Year One report for details about Reebok's monitoring approach.) Reebok also contracted third-party monitors to monitor 19 apparel facilities (click here to see the list). Furthermore, sourcing agents contracted by Reebok were required by the company to conduct audits in apparel factories before recommending them for production. Sourcing agents were held accountable for labor compliance, facing financial or other penalties from Reebok if they did not make good faith efforts to ensure Reebok Standards were upheld in factories in their purview.

The Human Rights Program cooperated with other departments at Reebok to improve compliance in factories. Reebok's senior management participated in discussions about implementing the company's Standards, while sourcing managers attended annual trainings to learn about Reebok's Human Rights policies and practices. Moreover, the Human Rights headquarters team provided sourcing and production managers with factory compliance data, and Human rights field staff met regularly with country managing directors. On various occasions, sourcing managers supported remediation efforts required of factories by the Human Rights Program.


Features of Reebok's Labor Compliance Program in Year Two1

A. Compliance Systems Developed in Year Two

1. Worker Participation Programs

The FLA Year One report described two pilot projects that Reebok undertook in China, which created the space for legal, democratic elections of worker representatives in two footwear factories. In Year Two, Reebok continued to monitor the situation in these facilities, and applied its experiences there in another apparel facility with a view to creating an environment for free elections there as well. Moreover, the company actively shared its experiences and strategies with other companies with a view to developing broader acceptance of alternative forms of worker representation in China. Reebok took several other approaches to involving workers in processes to improve workplaces:
  • Reebok instituted the Worker Communication Skill Transfer Program, which targeted existing worker organizations (either unions or welfare committees) in eight facilities. In Indonesia, Reebok trained representatives from two factories to conduct worker interviews and record worker responses systematically. In China, one factory's union committee members learned about wage calculation and how to check time-recording devices in order to respond more effectively to workers' complaints about wages and working hours. In Thailand, welfare committees learned about local laws and ways to address common problems in the five footwear facilities where they worked.
  • In order to encourage local actors to play a leading role in factory compliance, Reebok monitors discussed compliance findings with worker representatives in footwear factories, and occasionally in apparel factories. Reebok also instructed factory management to arrange regular meetings with worker representatives, if they were present in factories, in order to develop channels for direct communication. The goal was for workers and management to address issues without Reebok's direct and sustained intervention. In a footwear factory in China, for example, Reebok monitors relayed complaints relating to overtime noncompliance from workers to the worker committee. After investigating and documenting the situation, the committee reportedly was able to influence management to discipline the supervisor responsible for illegal overtime, and ultimately end the practice.
  • Reebok asked factories to develop and then implement action plans for worker training on the Reebok Standards, and verified that such training took place during internal monitoring visits by Reebok staff. According to Reebok's calculations, most footwear facilities have instituted worker training programs, and 40-50% of all apparel facilities have training programs in place.
Findings from FLA independent external monitoring visits support Reebok's self-assessment of the need for improved systems of worker representation in the company's applicable facilities. In addition to limited freedom of association in many facilities, findings from apparel factories in South and Southeast Asia, in particular, highlighted the need for continued management and worker education of Reebok's Standards and workers' rights. Reports from FLA independent external monitoring in Reebok's applicable facilities illustrate how the company applied some of the programs described above to address these issues. Click here to access the reports.

2. Capacity-Building in Factories

  • Reebok conducted training sessions in 12 factories in the Philippines to educate factory populations about Reebok Standards. In Year Two, the company also developed regional trainings for managers (sometimes accompanied by union leaders or worker representatives), which enabled participants to learn about common noncompliance and different approaches to remediation from one another. Reebok offered six such regional training sessions in Indonesia, the Philippines, Turkey, and Italy.
  • Through its Compliance Problem Resolutions (CPR) program, Reebok also experimented with a new regional approach to preventing noncompliance. If a pattern of noncompliance appears in a region, the CPR program requires all Reebok applicable factories in a given country or region to institute policies and procedures to address the noncompliance issue. For example, in Honduras, a CPR communication was sent to suppliers requesting them to investigate union blacklisting and inform Reebok of their findings. Factories were expected to demonstrate that non-discrimination policies and hiring and termination procedures were in place. CPR communications were also sent to factories in China relating to inaccurate record-keeping, and in Indonesia relating to harassment and intimidation of union members. Factories have reportedly been responsive to CPR communications; however, evidence about the effectiveness of the program had still to be collected at the time of reporting.
  • During Year Two, Reebok targeted factories with long-standing relationships with the company and a high-volume of Reebok business in order to help them integrate compliance into overall management systems. The staff developed a training module for agents, factory owners, and management and compliance staff, which focused on sustainability. At the Los Angeles meeting, participants worked through small-group exercises and case studies to develop remediation plans that provided long-term solutions to common noncompliance issues. Factories were then required to implement these policies. This program will be rolled out further in Year Three.
Particular examples of Reebok efforts to implement long-term corrective action plans through training, in particular, can be seen in reports from FLA independent external monitoring in Reebok applicable facilities.

Click here to see the Year One report on Reebok.

B. Improvements in Implementing the FLA Requirements

  • Reebok added four labor compliance professionals to its team in the field and at headquarters during the reporting period. New staff was added in China, Sri Lanka, and at headquarters in the US.
  • Reebok hired consultants to conduct a training needs assessment for all of its Human Rights staff, which concluded that monitors wanted to improve their capacity for training others about implementing the Standards. As a result, Reebok hired a Hong Kong-based training organization to conduct a two-day "Train the Trainers" workshop to increase Reebok monitors' abilities to train agents, management, and workers to develop remediation plans that have sustainable solutions. Human Rights monitors were videotaped and critiqued while presenting issues such as preventing harassment in factories, developing non-discrimination policies, and factory problem-solving systems.
  • Reebok Human Rights staff participated in a week-long training session in Sri Lanka, which covered new directions and regional teams' experiences with pilot programs, including: sustainable monitoring; factory self-evaluation; Reebok's human rights tracking system; benchmarking compliance within and across regions; approaches to improved worker representation; health and safety developments; and integration of human rights into Reebok's business structure.
  • Reebok held trainings for agents in Korea, Japan, Hong Kong, Australia, United States and Canada to teach them about Reebok Standards and the company's systems for implementing them.
  • Reebok took a more systematic approach to some aspects of its monitoring program. Reebok conducted unannounced visits to selected factories with a view to analyzing a particular issue, and visited all footwear factories to monitor freedom of association. Based on monitoring findings across a region, the Human Rights staff was then able to design remediation efforts that would address the issue on a regional basis, rather than by factory.
  • The Human Rights team updated The Guide to Reebok Human Rights Production Standards, which is a reference tool for factory managers. The team also revised the manual used to educate sourcing managers and Human Rights monitors about the new factory selection process.
Click here to review Reebok'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.
Copyright 2004 by the Fair Labor Association