Our Approach
The first step in our responsible sourcing process is to carefully vet potential vendors to ensure they are operating
according to the standards, values and goals that we expect. We expect that the products that we buy are made
by suppliers who treat their workers with respect, compensate them fairly, and provide a safe work environment.
We apply a risk-based approach to verify and monitor compliance and identify where risks are higher. We perform
comprehensive pre-factory engineering audits that are used to measure compliance, fit, and suitability to our own
culture and standards, including understanding working conditions for factory workers. Once we enter into a
commercial agreement with a vendor, we ensure factory working conditions standards are maintained or even
improved upon. This is done through a relationship built on mutual respect and shared interests, consistency
and fairness in our own actions and expectations, and monitoring of operational sites.
While we do not own or participate in the manufacturing or production of the goods we purchase, we maintain
and comply with the highest international labour standards to protect workers’ health, safety and human rights.
This is primarily accomplished through our partnership with the amfori Business Social Compliance Initiative
(amfori BSCI), a globally recognized audit and continuous improvement program. The amfori BSCI brings together
over 2,400 retailers, importers, brands and national associations to collaborate to improve both ethical behaviour
with workers and improve the political and legal framework for international trade in a sustainable way. As part of
our partnership with the amfori BSCI, we work with certified global audit firms to conduct ongoing workplace
inspections. We encourage all vendors that sell to us to maintain BSCI certification and we take a zero-tolerance
approach to any critical infractions. We have a long history working with many of our vendors and they are proud
to comply with amfori BSCI standards as well as our own Supplier Code of Business Conduct. Factories may also
submit a third-party audit report produced by an approved social audit standard.
Over the decades, we have discovered that the most effective approach to raising standards is through due
diligence, collaboration, open lines of communication and seeking to understand. It is through this style of
partnership that we have been able to comprehend the unique pressures and social factors faced by global
suppliers that have been tasked with meeting escalating production demands while protecting and building their
quality workforces. Equipped with this greater awareness, we come together with facility owners and like-minded
organizations to uphold human rights, improve working conditions, respect cultural values, and create outcomes
that benefit our stakeholders and the global communities in which we operate.
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Our values are reflected in the standards we set for the treatment of workers within our supply chain
CTC's Merchandising, Sourcing and Product Quality teams select the vendors and factories throughout our global supply chain to manufacture our owned brand products, and work with those suppliers to ensure that the products are sourced, manufactured and transported according to the standards of our Supplier Code of Business Conduct, international labour standards we adopt, and applicable local laws. Some examples of the standards we expect our suppliers to uphold include:
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Fair, in that compensation is paid on time, excessive overtime is not allowed, workers are free from harassment and abuse, and workers do not have to pay for their employment;
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Safe, meaning that the workplace – including dormitories and other worker spaces – are healthy and safe, and fire action plans exist and are practised; and
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Respectful of human rights, where absolutely no child labour, forced labour or discrimination is allowed and where workers have freedom of association and can engage in collective bargaining.
Supporting vendors during the pandemic
When COVID-19 and supply chain issues caused production disruptions and variable demand, we worked continuously to support our factories by maintaining purchase quantities and developing flexible delivery schedules to minimize impacts on vendors' and workers' financial security.
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We collaborate with our suppliers on continuous improvement
We have a duty to ensure that the treatment of workers in our supply chain are in line with global human rights standards, and to see that problems are addressed upon discovery. We consistently engage in third-party audits of vendors supplying owned brand products and keep lines of communication open between our teams and suppliers.
As part of the amfori BSCI, CTC draws on important international labour standards for protecting workers' rights, such as the International Labour Organization; the United Nations; and the Organization for Economic Co-operation and Development. We also recognize other global audit standards such as Social Accountability International (SA8000), Worldwide Responsible Accredited Production, SEDEX Members Ethical Trade Audit, Better Works, International Council of Toy Industries Ethical Toy Program and Social & Labour Convergence Program.
amfori Business Social Compliance Initiative
Since 2003, amfori BSCI has helped companies improve social performance in their supply chains, covering areas ranging from fair remuneration to no child labour. This global audit standard is used by over 2,400 brands and retailers and includes a network of 27,000 factories.
Member of amfori, the leading global business association for open and sustainable trade. We improve the social performance of our supply chain via amfori BSCI. For more information visit www.amfori.org
amfori Business Social Compliance Initiative
Since 2003, amfori BSCI has helped companies improve social performance in their supply chains, covering areas ranging from fair remuneration to no child labour. This global audit standard is used by over 2,400 brands and retailers and includes a network of 27,000 factories. Through our partnership with amfori BSCI and the support of cerified auditors, we monitor and work with our suppliers to continuously improve working conditions around the world. To learn more about these activities, visit the amfori BSCI website.
In 2021, we conducted 787 audits of factories manufacturing our owned brand products through globally-recognized third-party audit firms. As a result of these audits and using our other channels of communication, we investigated 14 different reports of critical infractions, including five attempted briberies, five instances of physical abuse/harassment and four significant safety issues. Our investigations and resolution work involved factory management, the Triangle Ethics Office and the Merchandising Senior Leadership team.
Member of amfori, the leading global business association for open and sustainable trade. We improve the social performance of our supply chain via amfori BSCI.
For more information visit www.amfori.org
Pivoting our audit approach
In light of the COVID-19 pandemic, we worked with one of our audit partners to pilot our first virtual audits with select North American suppliers. Our learnings from this process can improve virtual audits in the future, which may add efficiencies and cost savings for our stakeholders.
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We build alliances within our industry to create improvements
Operating in different countries and holding others accountable is an ongoing effort - a task made especially difficult during the global pandemic. Our collaboration with industry peers and other organizations is a critical and effective way to raise workers' standards around the world.
To reduce the administrative burden and audit fatigue on factories, we conduct our audits periodically with other brands and retailers that also have operations at those locations. By pooling our resources and influence, we are often better able to demand, monitor and achieve improvements for workers.
Partnering with Nirapon
In 2019, we partnered with 25 brands and retailers to establish Nirapon, a members-led organization that supports a culture of workers' safety in Bangladesh, where some of our owned brand products are manufactured. With Nirapon and its members' collaboration, we have helped these factories maintain a safe work environment, support ongoing workers' participation in factory safety, and provide training and helplines for workers so they can have a voice in their rights, health and safety.