Zephyr Graf-X - Labor Compliance Program in Year Two1Overview of the Program
Program Features
- Compliance Systems Developed in Year Two
- Improvements in Implementing the FLA Requirements
Overview of the Program
In Year Two, Zephyr completed the first year of its three-year initial implementation period of the FLA program. Zephyr adopted the FLA Code of Conduct as the basis for implementing its compliance program. Being a relatively small participating company, Zephyr does not have a designated compliance department within its company structure. The key person responsible for carrying out the functions of Zephyr's compliance program is the CEO of the company, who is assisted by the Licensing Director. The CEO, who speaks Korean, communicates daily with the factories, conducts internal monitoring, and follows up with the factories directly regarding remediation.
In 2003, Zephyr had one main supplier which operates four facilities. The CEO conducted one full compliance audit of the main supplier and one follow-up audit of the facility monitored by an FLA-accredited monitor. The CEO also visited three of the four facilities in Year Two, which included meetings and interviews with factory management and employees from different departments. The active involvement of Zephyr's CEO in compliance work facilitates the mainstreaming of compliance into the core business of the company.
Features of Zephyr Graf-X's 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, Zephyr's compliance program focused on establishing systems and developing materials for implementing FLA company obligations.
- In Year Two, Zephyr initiated various efforts to create an informed workplace, as required by the FLA. A "Welcome Packet" was created and distributed to Zephyr's main supplier outlining the Code standards and the company's expectations of compliance. The supplier was requested to submit a signed statement committing to the Code on an annual basis. Responding to findings from the FLA's independent monitoring visit, Zephyr required the supplier to post the Code of Conduct in the local language and provide individual copies of the Code to all workers, and to obtain signatures from workers stating that that they had read and understood the Code.
- Zephyr took steps to establish a confidential reporting channel that would allow employees to report non-compliance to Zephyr without fear of retaliation. This initiative consisted of installing suggestion boxes in areas outside the purview of management where employees could register their complaints. Zephyr's CEO oversaw and confirmed the installation of the suggestion boxes in two of the four production facilities.
- Zephyr has also identified areas in which it aims to improve in the next few years of FLA implementation. In 2004, Zephyr will conduct full compliance audits of the two facilities that were not audited in 2003. Zephyr also recognizes the need for compliance training of its staff, such as improving monitoring techniques and knowledge of local laws where its supplier facilities are located.
B. Improvements in Implementing the FLA Requirements
In Year Two, Zephyr 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.
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