OUR COMMITMENT TO CORPORATE RESPONSIBILITY

As one of the most trusted names in licensed sports merchandise, The Northwest Company values the contributions of its licensors, employees and manufacturers, and undertakes a serious commitment to respect those who manufacture its products, and to operate in a sustainable and environmentally sound manner.

To honor this commitment, The Northwest Company believes it is its responsibility to empower and recognize employees, to identify social and environmental risks in all aspects of business operation, and to apply its influence to address those risks, resulting in a continuous-improvement workplace environment and reduced environmental impacts. The Northwest Company builds a foundation for implementing these commitments through strategic alliances with partners who share its values, and in collaboration with trusted individuals and organizations with reliable and consistent expertise in the required areas.


CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

    STATEMENT

  1. The California Transparency in Supply Chains Act requires full disclosure of company efforts to eradicate slavery and human trafficking from supply chains. The Northwest Company is fully committed to this process. Human trafficking and slavery are results of coercion and exploitation that can occur both during the recruitment process and within the workplace. We engage strictly with business partners who comply with all applicable national laws and international principles aimed at preventing and eradicating trafficking and slavery as described in the 2000 United Nations Polermo Protocol and the 1926 Slavery Convention.

ASSESSING RISK.

  1. We place orders in 30+ factories located in China, Pakistan, Mexico, and Egypt. According to the U.S. State Department Trafficking in Persons 2011 report and other sources, there are substantial risks of human trafficking and slavery in these countries. To monitor these risks, we routinely review reports on workplace issues in these countries that are compiled by governments, international agencies and civil society organizations. Using independent external monitoring conducted by the Fair Labor Association, SGS, Bureau Veritas and other certified third-party agencies, we are able to properly assess our ethical sourcing environment risks and maintain vigilance within our supply chain. The assessment is conducted with the assistance of highly qualified corporate responsibility agencies and staff, along with trained and experienced Northwest Company management.

CONDUCTING AUDITS.

  1. The Northwest Company conducts audits of the factories that make its products on a regular basis. Third party auditors, who have been accredited by the Fair Labor Association and other interested parties, conduct the audits and examine the full range of issues contained in The Northwest Company Workplace Code of Conduct, including issues that are indicators of human trafficking and slavery. The first audit in a factory is announced. Subsequent audits are typically unannounced. Audits to verify that remediation plans have been completed are unannounced. In cases where subcontract facilities are used, the primary factory is required to apply The Northwest Company Workplace Code of Conduct to the subcontract factories. The Fair Labor Association independently assesses a subset of the factories that make our products annually.

AGREEMENTS WITH FACTORIES.

  1. The Northwest Company obtains signed affidavits each year from the management of the factories that make our products attesting to their commitments to abide by The Northwest Company Workplace Code of Conduct. Indicators of human trafficking and slavery are contained within the provisions of The Northwest Company Workplace Code of Conduct Code. Additionally, all factories have indicated in writing their commitment to comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

MAINTAINING AND ENFORCING ACCOUNTABILITY.

  1. The Northwest Company maintains and enforces internal accountability procedures for employees and contractors regarding company standards about slavery and human trafficking. In the case of non-compliance, The Northwest Company reserves the right to examine the specific situation and develop a best possible strategy for resolution. In cases where non-compliance is not resolved within a timely manner, The Northwest Company may terminate the business relationship.


CODE OF CONDUCT

    The Northwest Company is committed to conducting its business affairs in a socially responsible manner consistent with its ethical accountability for improving the workplace. This Code of Conduct shall apply to all employees, including contractors, subcontractors, and any person or entity involved with the production of The Northwest Company products.

    At The Northwest Company, we are committed to:

    • • A standard of excellence in every aspect of our business worldwide
    • • Ethical and responsible conduct in all operations
    • • Respect for the human rights of all individuals
    • • Safety in the workplace
    •        • Fire & hazardous materials safety
    •        • Occupational safety
    •        • Safe equipment and working environment
    • • Respect for the environment and sustainable practices
    •        • Sustainable raw materials
    •        • Sustainable energy practices
    •        • Sustainable water treatment practices
    •        • Sustainable waste disposal practices
    • • Secure operations

1. Employment Relationship

  1. Employers shall adopt and adhere to rules and conditions of employment that respect workers and at a minimum, safeguard their rights under national and international labor and social security laws and regulations.

2. Nondiscrimination

  1. No person shall be subject to any discrimination in employment, including hiring, compensation, advancement, discipline, termination, or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group or ethnic origin.

3. Harassment or Abuse

  1. Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological or verbal harassment or abuse.

4. Forced Labor

  1. There shall be no use of forced labor, including prison labor, indentured labor, bonded labor or other forms of forced labor.

5. Child Labor

  1. No person shall be employed under the age of 15 or under the age for completion of compulsory education, whichever is higher.

6. Freedom of Association and Collective Bargaining

  1. Employers shall recognize and respect the right of employees to freedom of association and collective bargaining.

7. Health, Safety and Environment

  1. Employers shall provide a safe and healthy workplace setting to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work, or as a result of the operation of employers' facilities. Employers shall adopt responsible measures to mitigate negative impacts that the workplace has on the environment.

8. Compensation

  1. Every worker has a right to compensation for a regular work week that is sufficient to meet the workers' basic needs and provide some discretionary income. Employers shall pay at least the minimum wage or the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages, and provide any fringe benefits required by law or contract. Where compensation does not meet workers' basic needs and provide some discretionary income, each employer shall work with the FLA to take appropriate actions that seek to progressively realize a level of compensation that does.

9. Women's Rights

  1. Because the overwhelming majority of apparel workers are women, women will receive equal remuneration including benefits, equal treatment, equal evaluation of the quality of their work, and equal opportunity to fill positions as male workers. Pregnancy tests will not be demanded of employees nor will employees be pressured to use contraception. Pregnant workers who are taking maternity leave will not face dismissal nor threat of dismissal, loss of seniority or deduction of wages, and will be able to return to their former employment at the same rate of pay and benefits. Women workers will not be exposed to conditions that may endanger their reproductive health.