Fair Labor Association Annual Report: FLA Accreditation of Reebok Footwear's Labor Compliance Program

FLA Accreditation of Reebok Footwear's Labor Compliance Program

In April 2004, the FLA Board of Directors voted to accredit Reebok footwear's compliance program. The decision was based on the FLA staff's assessment that included audits both at headquarters and at the field level, and visits to a number of footwear supplier facilities. Staff interviewed Reebok personnel; inspected files; observed the annual compliance staff training; reviewed factory records in the database; observed Reebok field staff in footwear factories; and analyzed findings from a total of 9 independent external monitoring visits conducted at Reebok footwear facilities over the course of the past two years.

This accreditation assessment focused exclusively on Reebok footwear's compliance program during the initial implementation period, which lasted from July 2001 until December 2003. The compliance program implements FLA Standards in the factories that produce Reebok footwear around the world (totaling 45 in Year One, later consolidated to 41 in Year Two - click here to see where they are located). While many of the activities undertaken by Reebok relating to footwear also applied to Reebok apparel, the footwear compliance program is distinct in many ways from the apparel program. It is for this reason that Reebok submitted two separate Monitoring Plans for footwear (with a 2-year implementation period) and apparel (a 3-year period). The apparel program will be eligible for accreditation next year, along with several other companies' programs.

By accrediting Reebok footwear, the FLA Board formally recognized that the program has fulfilled the requirements set forth by the FLA and in the Monitoring Plan that Reebok footwear submitted upon entering the FLA. Accreditation should not be mistaken to mean that a program is perfect, however. When accrediting a program the FLA stresses the need for continued improvement at the level of the factory and the company. In the event that the FLA finds that a company is not acting in good faith to uphold its obligations, it retains the right to retract accreditation.

Click here for more information about FLA accreditation.

FLA Assessment of Reebok Footwear's Compliance Program - In Brief

The FLA determined that Reebok Human Rights staff has considerable involvement in footwear factories. The program deals with a relatively small number of facilities (41 in total), and has generally long-term relationships with them. The staff undertakes all monitoring and remediation in footwear factories, visiting major suppliers at least once a month and subcontractors at least once annually. Regular presence in the majority of footwear factories provides the opportunities for staff to coach factory management to make long-term improvements in compliance. Especially notable during the implementation period were Reebok footwear's efforts to experiment with various approaches to improve labor-relations systems in factories, particularly in two Chinese footwear factories where workers democratically elected worker representatives (read more about the projects in the FLA Year One Public Report). These two pilots are widely referred to as models for improved freedom of association in China.

Despite the fact that Reebok's footwear program fulfilled or surpassed the minimum requirements for each of the ten criteria below, there is still room for improvement in the program's efforts. The FLA staff believes that ongoing training is necessary for Reebok Human Rights staff, and that improved mainstreaming of compliance into sourcing and other business departments may further increase the impact of the program. The footwear program can also continue to improve by applying to smaller and subcontractor facilities the lessons learned through projects focused mainly at major footwear facilities.

Overall, the company is a notably active participant in the FLA, and has encouraged footwear facilities to participate and increasingly take the lead in ongoing and new activities that promise to bring about improved workplace conditions. Please see the chart below for a brief summary of ways in which Reebok footwear fulfilled particular FLA requirements for accreditation.

Reebok Footwear's Fulfillment of FLA Requirements for Program Accreditation July 2001 through December 2003
Adopted and Communicated the Workplace Code of Conduct to Workers and Management at Applicable Facilities.
Reebok's Human Rights Production Standards exceed the FLA Workplace Standards. Reebok's "Notice to Workers" presents the Standards in simple and clear language. The "Notice" is posted in all footwear facilities, and has been translated into the respective languages spoken by the workers and managers in each factory.
The program is notable in that it provided employees of all major footwear facilities with Code handbooks, and most footwear facilities had Code and worker rights training for employees in 2003. The Human Rights staff also encouraged union members to give the trainings in factories where they were present. The FLA looks forward to seeing these education efforts carried out in all Reebok footwear facilities in the future.
FLA IEM findings indicate that factory education programs may indeed have improved Code awareness in Reebok footwear factories. While there were several cases where workers were not aware of the Code in Year One (based on 7 IEM visits), FLA monitors found no cases of a lack of awareness in the 2 factories visited in Year Two. Further monitoring in footwear facilities can provide more conclusive information about the impact of these programs.
Trained Internal Compliance Staff to Monitor and Remediate Noncompliance Issues
Among other less formal training activities, Reebok Human Rights staff participated in week-long annual trainings. The second annual training built on the first by focusing discussions on methods for long-term solutions to noncompliance. In Year Two, Human Rights staff also participated in a 3-day "Train the Trainers" program, which aimed to develop the skills of the staff to train business partners. The FLA observed that more Human Rights staff training is needed to implement Reebok footwear's ambitious plans effectively and to build factories' problem-solving and compliance capacity.
Conducted Internal Monitoring of Applicable Facilities
Reebok Human Rights staff monitored major footwear facilities at least once a month, while it monitored subcontractors at least once annually. The FLA recommends that Reebok footwear evaluate its targeted, "risk-based" approach to monitoring with a view to measuring the extent to which all Code Provisions are implemented in all footwear facilities, regardless of a factory's size, location, or sourcing importance to the company.
Submitted to Unannounced, Independent External Monitoring (IEM) Visits to Factories Throughout its Supply Chain
Reebok footwear provided factory lists, factory profiles, and related information to the FLA as required during Years One and Two. Reebok ensured that no FLA monitors were denied access to footwear factories, records, and workers during unannounced visits. The company also cooperated with FLA staff following IEMs to ensure that remediation and follow-up took place and were reported in FLA factory tracking charts, which are available for review on the FLA website.
Remediated Noncompliance Issues in a Timely Manner
Following FLA IEM visits, the Human Rights staff developed remediation plans with footwear factories, which were implemented in a reasonable timeframe (usually 60 days). FLA staff also visited several factories that were internally monitored by Reebok Human Rights staff and observed that remediation had been completed.
Reebok footwear also has begun to experiment with new approaches to "sustainable compliance." As discussed elsewhere in this report, this approach focuses on developing management structures and labor relations systems in factories that can lead to long-term labor compliance. The program is relatively new, so FLA encourages its continued development.
Taken Steps to Prevent Persistent Patterns of Noncompliance, or Instances of Serious Noncompliance
The company used data from internal monitoring visits to track trends in noncompliance, and reported its findings to the FLA. The FLA observed that findings from Reebok footwear's internal monitoring in Year One impacted systematic compliance efforts in Year Two. Reebok footwear's preventive programs included an Air Quality Testing Program in footwear facilities, which led to measurable improvements in the air quality. Similarly, Reebok footwear focused on improving workers' understanding of chemical hazards in order to increase use of personal protective equipment.
Reebok footwear's efforts relating to worker participation are especially notable with regard to the prevention of noncompliance. Pilot projects in two Chinese footwear factories, where worker representatives were freely and democratically elected, stand as models for many working in the labor rights field. Also noteworthy were Reebok footwear's projects in Southeast Asia that allowed for worker representatives from footwear factories in different countries to meet with each other and learn through exchanges and training.
Reebok footwear experimented with a new "Compliance Problems Resolutions" (CPR) program. The program sought to prevent common noncompliance issues on a regional basis by requiring that all factories institute certain personnel and management policies and procedures in order to prevent noncompliance issues. The CPR program also addressed freedom of association in footwear facilities in Indonesia and problematic time-recording practices in China.
Additional details about Reebok's projects can be accessed by clicking the "Compliance Program" tab above, or in the FLA's Year One report on Reebok.
Collected and Managed Compliance Information Effectively
Reebok footwear uses a database, the Human Rights Tracking System (HRTS), to collect and organize factory compliance information. The database can be accessed worldwide by relevant Reebok employees, who use it to record monitoring results and remediation progress and to analyze trends in noncompliance. The FLA noted that the HRTS is separate from Reebok footwear's sourcing database, which may hinder the exchange of factory information between the Human Rights staff and other departments.
The Reebok Human Rights staff provides progress reports to the FLA on a quarterly basis.
Provided Workers with Confidential Reporting Channels to Report Noncompliance Issues to the Company
The contact information of the local Reebok footwear monitor appears on all "Notice to Workers" posters. In Year One, the company distributed mailers to all footwear workers to report noncompliance, and suggestion boxes were used in many footwear facilities. In the past year, Reebok also created a webpage for individual complaints. FLA staff has observed footwear workers calling or text messaging Reebok monitors' cell phones to report noncompliance. By entering all worker complaints into the compliance database, Reebok footwear can improve its data collection and monitor the effectiveness of staff follow-up on various issues.
Consulted with Non-governmental Organizations, Unions, and Other Local Experts in Its Labor Compliance Work
Reebok footwear monitors are responsible for managing NGO contacts in their respective regions or countries. Reebok held NGO consultations in India, China, Indonesia, and Thailand. Two substantial projects in China - i.e., the aforementioned pilot in 2 footwear facilities and a health and safety training project in a number of large footwear facilities -- were conducted in collaboration with leading NGOs from Hong Kong during Reebok footwear's initial implementation period.
Reebok Human Rights staff was instructed to consult with union leaders and worker representatives whenever they were present in a factory.
Paid FLA Dues and Met Other Procedural and Administrative Requirements
All Reebok footwear dues and administration and monitoring fees were paid on time; all contracts were duly signed; and all required factory lists were submitted as required by the FLA.


			Copyright 2004 by the Fair Labor Association