Fanatics recognizes the importance of a socially responsible supply chain. We understand that worker welfare and the creation of high-quality products are not mutually exclusive. As sports fans ourselves, we believe we are uniquely in-tune with our sports fan customer base, and we also recognize the growing interest among consumers to purchase products that are made in socially responsible working conditions.
Fair Labor Association
As a part of our compliance commitment, certain divisions of Fanatics are affiliated with the Fair Labor Association (FLA), an organization that brings together brands, suppliers, civil society organizations and universities that is dedicated to responsible labor practices throughout supply chains. In connection with this affiliation, Fanatics Brands has created The Fanatics Workplace Code of Conduct (the "Fanatics Code"), which defines and describes the standards that we have for ourselves and for our supply chain partners. The Fanatics Code is based on the FLA Code, International Labor Organization (ILO) standards and internationally recognized labor practices. We leverage these standards to evaluate working conditions and collaborate with factories and suppliers if improvements are required.
Social Compliance Program
Fanatics Brands has developed a social compliance program, designed to both regularly evaluate and analyze factory conditions and also establish brand-level management systems that minimize unnecessary pressures placed upon suppliers. Like many apparel industry leaders, it is our goal to understand how to positively impact factory working conditions, how to sustainably remediate any new issues, and how we can incorporate best practices into our core business operations.
Selecting the Right Supplier Partners
Fanatics is also dedicated to implementing a screening and evaluation process for selecting and working with suppliers. Fanatics Brands will conduct a risk assessment for any potential third party that will be manufacturing apparel, headwear or other products on behalf of Fanatics Brands before we approve production of any products by such party. For any such manufacturer, whether new or existing, for which we identify any Fanatics Code violations, the supplier must work to identify the root cause of such violations and implement a comprehensive Corrective Action Plan (CAP) that includes issues to be addressed in the short-term, as well as preventative measures to ensure compliance for the long-term.
Once a manufacturer enters the Fanatics Brands source base, we continue to monitor working conditions, as well as benchmark their improvement and incorporation of social compliance best practices over time. It is our goal that future business is conditioned on (among other factors) social compliance performance and commitment throughout the relationship.
Commitment to Continuous Improvement
The development of a social compliance program is a continuous journey towards enhanced transparency, collaboration, and sustainable improvement. Fanatics is dedicated to this goal. It is not only essential to the success of the brand, but also to the welfare of those individuals working hard to create premier Fanatics product every day.
California's Transparency in Supply Chains Act of 2010 requires certain retailers to provide increased visibility into their efforts to address the global issues of slavery and human trafficking to allow consumers to make more informed choices regarding their purchasing decisions. Fanatics, Inc., through one or more of its subsidiaries ("Fanatics"), including Fanatics Apparel, LLC and the Fanatics Licensed Sports Group, LLC (Fanatics Apparel, LLC and Fanatics Licensed Sports Group, LLC collectively, "Fanatics Brands"), is committed to improving fair labor practices throughout its direct supply chain.
Fanatics Brands uses the services of third parties to manufacture apparel, headwear and other products on behalf of Fanatics Brands (such third parties, "Private Label Suppliers"). Fanatics also purchases merchandise from third party suppliers for resale through Fanatics' owned and operated retail channels (such third parties, "Merchandise Suppliers"). Private Label Suppliers are obligated to comply with Fanatics' Workplace Code of Conduct, which is designed to align with the Fair Labor Association Workplace Code of Conduct, a set of global standards grounded in the standards promulgated by the International Labor Organization (ILO) for working conditions in factories. These standards are designed to protect workers' rights and prohibit, among other things, forced labor. Merchandise Suppliers are obligated to comply with the Fanatics' Vendor Compliance Guide ("Merchandise Supplier Compliance Guide"), which includes a commitment by Merchandise Supplier's to comply with all applicable laws including laws prohibiting child labor, forced labor and unsafe working conditions.
Prior to being on-boarded by Fanatics Brands, new Private Label Suppliers are required to undergo an audit by Fanatics Brands, which, among other things, verifies whether the proposed Private Label Supplier is in compliance with Fanatics' requirements, including the Workplace Code of Conduct and looks for evidence of forced labor.
Prior to doing business with new Merchandise Suppliers, Fanatics' personnel perform an initial assessment of the Merchandise Supplier's business, and the Merchandise Suppliers are required to adhere to Merchandise Supplier Compliance Guide. Fanatics reserves the right to terminate relationships with Merchandise Suppliers, including where such Merchandise Suppliers are not in compliance with applicable laws.
Private Label Suppliers are required to sign an Annual Compliance Commitment Certification, certifying compliance with the Workplace Code of Conduct, and to maintain records that are sufficiently detailed to substantiate its compliance with applicable anti-slavery and human trafficking laws and produce such records upon request. In addition, Fanatics Brands' standard manufacturing agreement requires its Private Label Suppliers to certify that they are in compliance with all applicable laws, rules and regulations.
As a general matter, Fanatics has the right to terminate relationships with Private Label Suppliers and Merchandise Suppliers if Fanatics believes that such third parties are in violation of the Workplace Code of Conduct (if applicable) or applicable law.
Once engaged, Private Label Suppliers are/will be periodically assessed against the Workplace Code of Conduct through announced and/or unannounced audits by both an internal Fanatics Brands compliance team ("Compliance Team") as well as independent third-party monitors that are retained by the Compliance Team. As part of these audits, Private Label Suppliers are expected to provide relevant records demonstrating compliance and to allow the Compliance Team and/or independent monitors to interview the Private Label Suppliers' personnel. The Compliance Team will work with Private Label Suppliers to remediate issues identified as part of such audits; if such issues cannot be remediated in a satisfactory and/or timely manner or if the Private Label Supplier fails to submit to the audit, then Fanatics Brands' may take action, up to and including termination of the relationship with the Private Label Supplier. At this time, Fanatics does not audit Merchandise Suppliers; but reserves the right to terminate relationships with Merchandise Suppliers, including where such Merchandise Suppliers in not in compliance with applicable laws.
The Compliance Team is trained on human trafficking and slavery laws and related matters. In addition, selected associates and management directly involved in the Fanatics Brands' supply chain and procurement functions receive training on the Workplace Code of Conduct, which includes a review of the forced labor code element and benchmarks, the characteristics of forced labor and human trafficking, and actions to take in response to a suspicion of the presence of forced labor at a Private Label Supplier facility. Fanatics Brands presently expects training to occur on an annual basis. Fanatics is working toward implementing additional compliance training to a broader segment of its workforce.
Associates in the Fanatics' organization are expected to conduct business in a legal and ethical manner. In addition, associates and management who support Fanatics Brands' supply chain and procurement functions are expected to follow procedures regarding notification of suspected slavery and human trafficking. Failure to comply with these requirements may result in disciplinary action.
21 December 2018
This is Fanatics' statement on slavery and human trafficking on behalf of Fanatics International Limited and its subsidiaries (the "Fanatics Group") as required under the Modern Slavery Act 2015 (the "Act").
Fanatics Group is committed to ensuring that it, complies with all applicable legal requirements in relation to the Act, and any other applicable law related to slavery and human trafficking.
The Fanatics Group employs over 1050 people worldwide and operates from various global locations across Europe (including the UK) and Asia.
The Group's commercial activity is related to brand licensing and merchandising and includes the manufacture, promotion and sale (through retail and wholesale channels) of certain apparel on behalf of sports teams, leagues and governing bodies.
Fanatics' Policy on Slavery and Human Trafficking
The Fanatics Group is committed to supporting the aims of the Act-to act ethically and with integrity in its business and commercial relationships. The Fanatics Group endeavors to ensure that no slavery and human trafficking is taking place in its business or supply chains.
Fanatics' Strategy on Slavery and Human Trafficking Prevention
Fanatics strategy on preventing slavery and human trafficking includes the following steps that have been, or will be, taken:
1. continued monitoring of the business and supply chains operated by the Fanatics Groups;
2. ongoing review of our processes and policies related to slavery and human trafficking, ensuring that no slavery and human trafficking takes place in any of our business or supply chains;
3. introducing appropriate anti-slavery and human trafficking language into relevant contracts;
4. monitoring potential risk areas in our business and supply chains as part of our ongoing business-wide practices;
5. updating, maintaining and promoting our internal conduct policy, which requires our employees to uphold the highest ethical standard and to act with integrity in all our business relationships; and
6. establishing a central whistleblowing point of contact to ensure reports of slavery and human trafficking are received and dealt with in accordance with our whistleblowing framework.
The Fanatics Group will continue to review its policies and procedures in relation to the prevention of slavery and human trafficking in its business and supply chains.
Fanatics International Limited
Date: 21 December 2018
Over the past few years, Fanatics has transformed the sports fan gear landscape, offering multi-channel access to premier quality team apparel and jerseys aligned with the 24/7 on-demand expectations of today's mobile-friendly consumers. Our "By Fans, For Fans" approach to making and distributing fan gear relies on a complex supply chain of owned and contracted manufacturing facilities that plays a vital role in ensuring customers have quick access to great product.
While the success of this global network hinges on many factors, one paramount factor is that workers throughout the supply chain are treated fairly and respectfully and without discrimination. We believe that social compliance, aside from being the right way to treat a workforce, recognizes the growing interest among consumers to purchase products that are made in socially responsible working conditions.
As a part of our compliance commitment, some divisions of Fanatics have an affiliation with the Fair Labor Association (FLA), an organization that brings together brands, suppliers, civil society organizations and universities that are dedicated to responsible labor practices throughout supply chains. Fanatics has also developed a social compliance program, designed to meet FLA standards, and regularly evaluates factory operations to identify and sustainably remediate any issues, and to positively impact working conditions and incorporate best practices throughout our business.
The development of a social compliance program is a continuous journey towards enhanced transparency, collaboration, and sustainable improvement. Fanatics is dedicated to this process, which is essential to the success of the brand, but more importantly, to the welfare of those individuals around the world working to bring Fanatics' "The Brand of the Fan" vision to life.