CSC requires all finished goods suppliers to sign a supply agreement, which specifies that a vendor has read and understands the Columbia Sportswear Company Standards of Manufacturing Practices Policy and shall ensure that its facilities and the facilities of its subcontractors are maintained in accordance with the SMP Policy standards.
CSC complies with the UN Guiding Principles on Business and Human Rights (UNGPs), which specify that due diligence processes should 'include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed.’ All finished goods suppliers are subject to performance evaluation of audit or assessment data which includes specific criteria around risks for forced labor or human trafficking including the employment of vulnerable worker groups such as foreign migrants, interns and temporary workers and high-risk practices such as payment of recruitment fees or restrictions on freedom of movement. New factories are audited and must meet our minimum standards before production may begin. A re-audit will occur anywhere from 30 days to one year later, depending on the findings in the previous audit or assessment. The majority of SMP performance data comes from unannounced audits completed by our internal SMP auditors as well as designated 3rd party audit firms who are trained to our standards. We also utilize data from audits and assessments performed by
ILO’s Better Work program
the Social and Labor Convergence Program
Fair Labor Association
and a handful of other brands with whom we have built a strong relationship. All data is scored according to our SMP grading matrix and local law. In 2019, we incorporated performance data from 394 audits and assessments, with 220 being completed by our internal team. We work with the suppliers to develop a Corrective Action Plan (CAP) to remediate issues identified during the audit or assessment.
As a member of the Fair Labor Association (FLA), in 2019 we were subject to one independent assessment performed by the FLA at a randomly selected CSC finished goods supplier. The FLA validates the quality of our remediation due diligence of the assessments they perform, and publicly posts the results to their website.