Transparency in Supply Chains
General Requirements
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FLTR, Inc. (“FLTR”) is a fast-paced, vibrant, and design-centric organization supplying personal protective equipment (PPE) to the largest retailers in the world. Our mission is to make effective PPE widely available and help contain the crisis through our retail product lines, charitable giving initiatives, and consumer education. FLTR is committed to designing, developing, manufacturing, and selling quality products that are produced under ethical conditions that protect worker rights and safety. Derived from the policies, standards, and conventions of the United Nations (UN) and the International Labor Organization (ILO), as well as other leading independent standards, the FLTR Code of Conduct defines requirements that partner factories must meet, and these requirements ensure that worker rights, safety, and security are maintained. Practices related to human trafficking, physical or verbal abuse, sexual abuse, restricted freedom of movement, passport and personal document control, excessive or forced overtime, child or prison labor, failure to pay adequate minimum or overtime wages, and many other aspects related to worker welfare are all addressed in the Code of Conduct. Our Compliance program is an extensive program of internal, third-party, and customer-driven audits and training programs at our partner factories that ensure that product and social compliance issues are reviewed and addressed throughout our supply chain.
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It should also be noted that FLTR fully complies with the California Transparency in Supply Chains Act (SB657), which seeks to eradicate slavery and human trafficking in the supply chain. Sub-suppliers are generally outside the scope of the audit program. The requirements of this Act cover the five major areas identified below. FLTR is fully compliant with the Act and our ongoing efforts are described below:
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1: Verification
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FLTR conducts internal and independent third-party risk assessments of our factories to identify risks related to human trafficking, slavery, and other labor issues, such as child and migrant labor. Risk Assessments are also based on an analysis on a country by country basis, with special emphasis on countries that pose an increased risk. This verification also involves audits of FLTR partner factories. FLTR auditors are constantly on-site at factory locations to review compliance status and to address any product or social compliance issues that may exist.
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2: Auditing
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FLTR conducts announced and unannounced audits, whether internal or through independent third-party audits for Customers, at all of its partner factories to ensure that the factory does not violate any areas of the Code of Conduct, including the risk of human trafficking and slavery. FLTR also accepts independent third-party audits following internationally recognized standards, such as Sedex Members Ethical Trade Audits (SMETA) and Business Social Compliance Initiative (BSCI) audits.
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3: Certification
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Direct suppliers to FLTR are required to certify that the materials incorporated into our products comply with the local laws on slavery and human trafficking. In addition, FLTR suppliers certify that the manufacturing process at their facility, and their sub-supplier’s facilities, does not involve any form of slavery or human trafficking.
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4: Internal Accountability
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All FLTR employees and contractors throughout the supply chain are held accountable to the FLTR’s standards on slavery and human trafficking. Employees, Vendors, and Contractors are required to reports any incident to the Compliance team. The Compliance team is committed to investigating all reported incidents. In addition, the Compliance team works with partner factories on the development and execution of Corrective Action Plans (CAPs) to address any violations to the Code of Conduct.
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5. Training
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The FLTR Compliance team is responsible for training all company employees regarding mitigating the risk of slavery and human trafficking throughout our supply chain. In addition, FLTR conducts Supplier training with its partner factories to review product and social compliance issues, including issues related to slavery, human trafficking, child labor, prison labor, and other compliance issues.
For additional information regarding the FLTR’s program, please feel free to email Compliance@fltr.com.
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Updated October 10th, 2020