| What We Do | FLA Charter | Board of Directors | Meet the Staff and Core Consultants |

Compliance with international labor standards is a process, not an event.

The FLA methodology involves participating companies adopting the FLA Code of Conduct and implementing a comprehensive compliance program, including internal monitoring, throughout their supply chain. The FLA then contracts with accredited monitors to conduct independent monitoring of each company's high risk facilities, works with companies to remediate problems identified in their facilities and independently verifies and accounts for company internal compliance programs.

» code of conduct implementation
» internal monitoring
» independent, external monitoring
» remediation
» verification
» public reporting

code of conduct implementation  The first step for companies is to incorporate a compliance program within their organization. This requires designating a person or division in the company responsible for promoting Code compliance at all levels of the supply chain. Company compliance personnel must be trained and they in turn need to ensure that Code standards are recognized as a basis for continuing business relationships with suppliers and contractors.

internal monitoring  The FLA works with companies to help them establish an internal system of monitoring factory conditions and promoting respect for the Code standards.

The requirements of an internal monitoring program include efforts to:

• Inform workers of their rights under the Code - orally, by posting the Code standards and through other activities to educate workers;
• Establish relationships with local labor and human rights NGOs and unions to assist in identifying situations of noncompliance with the Code;
• Train company monitors about the Code standards, applicable local and international laws, and effective monitoring techniques;
• Provide employees with a confidential reporting channel with which to report noncompliance to the company;
• Conduct periodic announced and unannounced factory visits and audits of wage, hour, and other employee records;
• Establish means of remediation to correct and prevent noncompliance with the Code standards.

independent, external monitoring  In addition to internal monitoring, companies that join the FLA agree to allow independent, external monitors to audit their facilities for compliance with the Code standards. The monitors are accredited by the FLA and conduct audits on an unannounced basis. Upon completion of an audit, the monitor reports their findings to the company and the FLA. The FLA then verifies that the company follows through and remediates any noncompliance identified by the monitor.

remediation  Participating companies must demonstrate a commitment to promote sustainable improvements in factory conditions. When noncompliance is identified by either internal or external monitors, the participating company is responsible for effecting remediation in that facility.

A remediation plan for a facility may involve any combination of the following:

• Making physical changes to the facility, such as installing additional fire exits or improving illumination;
• Building capacity at the management level, such as improving production planning to reduce the need for excessive overtime; and
• Conducting training for management or workers in any or all of the Code provisions.

The FLA maintains that companies should not pull production from factories that are found to be noncompliant with the standards; instead, companies are obliged to work with factory management to improve workplace conditions and protect the rights of the workers responsible for manufacturing their products.

verification  In addition to helping participating companies implement the Code in their supply chains, the FLA verifies and vouches for the remediation process.

This procedure has three essential components. In order to independently verify the company's internal compliance program, the FLA staff:

• conducts an annual audit of the company's compliance program to review internal procedures and documentation;
• makes field visits to observe the work of local compliance staff and assess factory conditions; and
• reviews reports submitted by independent, external monitors to ensure that all noncompliance is remediated by the company in an appropriate and timely manner and, if necessary, schedules further factory visits by monitors.

public reporting  In order to serve as a source of information to consumers and the general public, the FLA will issue an annual public report on the global compliance record of each of its participating companies. We will also disclose on the FLA web site information related to factories that are monitored by independent, external monitors. This information will include the name of the participating company (or companies) using the factory; the country/region of the factory; the product and size of the facility; the name of the monitor; the findings of Code noncompliance; the remediation instituted by the PC; and the status of the remediation. Through candid reporting and transparency, the FLA aims to promote public awareness about workplace conditions and labor abuses around the world, and efforts through the FLA to address them.