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 OUR BUSINESS PRACTICES > OUR COMPLIANCE PROGRAM > PARTICIPATION WITH THE FAIR LABOR ASSOCIATION
 

In this section, we describe the leading role we play in the FLA. We also describe our obligations as a participating company to the FLA, their role in overseeing our program, and how their oversight has identified areas where we can further improve our program, as we strive for ever better ways to meet our human rights commitments.

WHAT IS THE FLA
The FLA is a unique multi-stakeholder coalition of industry, NGOs, colleges, and universities. It was established as an independent monitoring system, holding participating companies and universities accountable for the conditions under which products are produced. We believe a collaboration of this kind—with its inherent tensions—can help drive practical changes and be a model for others to follow.

We are one of the founding company members of the FLA. We serve on the Board of Directors, the Executive Committee and the Communications Committee and we actively participate in the Monitoring Committee.

  OVERSIGHT OF OUR OBLIGATIONS
As an FLA participant, Reebok must agree to commit to the labor standards in the FLA code of conduct, extensive internal monitoring, external monitoring by independent monitors, remediate and prevent instances of noncompliance, public reporting, and participate in the FLA’s third-party complaint system. When joining, we submitted a two-year implementation plan for footwear, and a three-year implementation plan for apparel, for meeting these obligations.
 
 
 

To independently verify the progress and effectiveness of a participating company’s compliance program, the FLA:

• Conducts visits to company headquarters and field offices to review internal procedures and progress of implementation

• Makes field visits to observe the work of local compliance staff

• Sends accredited and independent external monitors (IEMs) to audit approximately 5% of a company’s supply chain on an unannounced basis, covering the full range of code of conduct issues

Information is available at www.fairlabor.org. FLA processes are on public record in order to help assure consumers that participating companies are acting in good faith.

 
 
 

ACCREDITATION
Following an extensive review of the company’s footwear compliance program in April 2004, the Fair Labor Association Board accredited Reebok’s program to improve conditions for footwear factory workers. Reebok became the first company to receive this FLA designation. In

June 2005, the Fair Labor Association Board also accredited Reebok’s apparel compliance program. The FLA Board consists of six industry representatives, six NGO representatives, three university representatives and a chair. Our programs must submit for re-accreditation every two years. Accreditation by the FLA does not mean that the factories we use comply with Reebok’s or the FLA’s standards. Instead, it signifies that Reebok’s compliance program for our branded apparel and footwear products is in substantial compliance with FLA requirements.

 

INDEPENDENT EXTERNAL MONITORING (IEM)
In 2004 and 2005, FLA-accredited independent monitors audited 3–5% of footwear and apparel factories supplying Reebok, without advance notice of the time or location of these monitoring visits. The figure below right displays the breakdown by code provision of the total noncompliance issues reported by FLA in facilities making our products, which Reebok addressed through remediation in 2004 [2005 data is not yet publicly available].

The audits are reported on the FLA website in the form of tracking charts (available at www.fairlabor.org). The tracking charts provide a detailed account of workers’ rights conditions in these factories as well as a narrative about what we are doing to remedy the violations. This type of thorough and systematic disclosure is unusual in the field of workers’ rights.

Our internal findings are consistent with the findings of FLA independent  monitors. In most cases, the type, frequency, number and percentage of issues found were consistent. However, the FLA monitors found more Health and Safety issues than our field staff (53% compared to our 39%). This is because our field staff has primarily focused their audits on threshold issues for new factories and verification of remediation for

 
 
 

CONTINUOUS IMPROVEMENT
As a result of our initial implementation period, we seek to make the

following improvements in our program in the future:

• Improve integration and data flow with sourcing departments

• Apply lessons learned to smaller facilities and subcontractors deeper in the supply chain

• Extend ongoing staff training

• Increase timeliness of follow-up and verification of remediation

• Extend scope of audits to cover all benchmarks over time

• Implement factory segmentation to drive a factory-based risk model for prioritizing assessments and capacity building programs (as well as to drive better rewards for higher performing factories)

 
 

REEBOK 2004 FLA IEM PERCENTAGE FINDINGS BY BENCHMARK AND CODE ELEMENT
Health and Safety issues were the most frequently reported issues, making up 53% of the total noncompliance issues identified. The most commonly reported (and remediated) issues were related to inadequate postings and evacuation procedures, safety equipment, personal protective equipment and chemical safety.

Noncompliance with the FLA’s Wages and Hours of Work issues were also common, with a total of 25% of all findings related to Wages and Benefits (12%), Hours of Work (7%) and Overtime Compensation (6%). The top Wages and Hours of Work issues taken up by Reebok through corrective action plans were related to overtime limitations, recording of overtime hours, voluntary overtime, overtime compensation and the factory’s provision of legal benefits to workers.

There were no findings of forced or bonded labor in facilities producing for Reebok. Likewise, there were no findings of underage workers in these facilities. The Forced Labor (1%) and Child Labor (2%) noncompliance reported above related to other benchmarks categorized under this Code provision.

FLA monitors reported violations of other code provisions with less frequency. As part of our participation with the FLA, we are working to develop systems for more effective assessments and remediation of code provisions that are particularly complex and difficult to assess, such as Freedom of Association, Non-discrimination, and Harassment and Abuse.

Source: www.fairlabor.org