OUR GUIDING PRINCIPLES
At VF, our Purpose and Guiding Principles influence everything we do. Modeling these behaviors and attitudes in a holistic manner helps our associates and business partners navigate even the most complex situations. We believe in partnering with others who share our values and who understand the importance of conducting business ethically. Within our Made for Change sustainability and responsibility framework, worker well-being is a key priority. To this end, we set a goal to measurably improve the lives of two million workers and others within their communities by Fiscal Year (FY) 2031. In addition, as part of our focus on workers, we are committed to taking steps to address modern slavery.
Our Modern Slavery Statement discusses the activities of VF Corporation and its current consolidated subsidiaries (collectively, “VF,” “we,” “us” and “our”) during FY2022 to address forced labor, human trafficking, slavery and servitude, debt bondage, child labor, deceptive recruiting for labor or services and other similar conduct (collectively, “modern slavery”) in our business and supply chains. All data below relates to VF’s continuing operations as defined in our Annual Report, excluding Supreme®, which publishes a separate statement. This statement is published pursuant to both the California Transparency in Supply Chains Act and the UK Modern Slavery Act and relates to the fiscal year from April 4, 2021 to April 2, 2022.
We are committed to respecting all human rights as outlined in the United Nations Guiding Principles on Business and Human Rights, the Ten Principles of the United Nations Global Compact, and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises and other applicable OECD guidance. This commitment to respecting human rights includes freedom from modern slavery. For additional information, see our Human Rights Commitment, Responsible Recruitment and Anti-Forced Labor Commitment and our 2020 Human Rights Report.
Our Business and Supply Chains
VF is a global leader in lifestyle apparel, footwear and accessories, and sourced approximately 408 million units across our brand portfolio last year. Our products were primarily obtained from approximately 250 independent contractor manufacturing facilities in approximately 37 countries. These contractors are engaged through VF sourcing hubs in Singapore (with satellite offices across Asia) and Panama. These hubs are responsible for managing the manufacturing and procurement of product, supplier oversight, product quality assurance, sustainability within the supply chain, responsible sourcing and transportation and shipping functions. We do not operate any manufacturing facilities.
For additional information on VF, download our Annual Report. Find out more about our supply chain platform on our website.
Policies, Principles, STANDARDS and Initiatives
Code of Business Conduct
All VF associates must comply with our Code of Business Conduct, which explicitly forbids the use of forced or involuntary labor in any of our locations or in the operation of facilities that produce goods for us. Violation of our Code of Business Conduct by an associate can result in disciplinary action, including termination of employment.
Global Compliance Principles
Our contracted supplier factories are expected to comply with VF’s Terms of Engagement. Contracted factories are also bound by our Global Compliance Principles. Our Global Compliance Principles are informed by the International Labour Organization, the Fair Labor Association, and other international standards on human rights. Consistent with internationally recognized labor standards, the Global Compliance Principles specify minimum working conditions for employees of our suppliers. The Global Compliance Principles expressly provide that any factories producing goods for VF and the factories’ suppliers must not use involuntary or forced labor, including indentured labor, bonded labor, state-imposed forced labor, or any other form of forced labor, including human trafficking. The Global Compliance Principles also address child labor, wages and benefits and working hours. Failure to comply with the Global Compliance Principles may result in termination of the relationship between VF and the contracted factory.
Contracted factories are prohibited from engaging subcontractors to produce VF products without the written permission of VF, and only after the subcontractor has agreed to comply with VF’s Global Compliance Principles.
Vendor Terms of Engagement
We evaluate potential contracted factories against our standards and require them to agree to VF’s Terms of Engagement, prior to entering our supply chain. Our Terms of Engagement require contracted factories to conduct business in full compliance with all applicable laws, rules and regulations, which include those relating to modern slavery, and comply with the terms of VF’s Global Compliance Principles. A contracted factory’s breach of the Terms of Engagement can result in VF taking corrective action, including termination as an approved contracted factory.
To promote uniform standards regarding our Global Compliance Principles, VF Corporation Global Assurance has developed the Facility Compliance Standards for establishing, auditing and monitoring facilities across the globe. The standards are based on existing international conventions, guidelines and principles used around the world. The Facility Standards are updated periodically.
The Facility Standards, including the Principle prohibiting forced labor, prohibit certain recruitment or employment practices that could result in forced labor. The Facility Standards prohibit deducting recruitment fees and expenses from wages, access to or control over bank accounts and withholding identity documents. The Facility Standards also require freedom of movement and access to grievance mechanisms. In addition, the Facility Standards contain specific requirements regarding migrant labor if it is used by the contracted factory.
Responsible Sourcing Commitments and Policies
Our business partners are required to adhere to our Human Rights Commitment and Responsible Recruitment and Anti-Forced Labor Commitment. These documents reinforce our commitment to upholding human rights and mitigating the risks of forced labor in our value chain. When we learn of potential human rights issues in our supply chain, we promptly investigate and engage in appropriate remediation. We have ended and will end our business relationships with suppliers who refuse to remediate human rights issues.
We enact responsible sourcing policies as needed to uphold compliance with legal requirements and our commitment to responsible sourcing. See the Policies and Standards section of our website for more information. For example, VF’s Policy on Cotton Fiber Sourcing details our cotton sourcing requirements and mandatory steps that all VF suppliers must take to track the origin and flow of material through each stage of their cotton supply chains.
Consistent with our values, we have signed numerous public pledges demonstrating our firm opposition to the use of forced labor and otherwise collaborate with multi-stakeholder initiatives, including those discussed in this section.
We are signatories to the American Apparel and Footwear Industry (AAFA) and the Fair Labor Association’s (FLA) Apparel and Footwear Industry Commitment to Responsible Recruitment. As such, we commit to work with our global supply chain partners to create conditions so that no worker pays for their job; workers retain control of their travel documents and have full freedom of movement; and all workers are informed of the basic terms of their employment.
VF has also signed the Mekong Club’s Business Pledge Against Modern Slavery. Together with the Mekong Club, VF enhanced the forced labor section of our Global Compliance Principles, which outline our expectations for how every business partner and supplier behaves and treats their workers. This includes criteria on human rights, ethical practices, health and safety, transparency, environmental requirements and subcontracting.
To incorporate our “zero-fee” requirement for migrant labor recruitment, we continue to partner with the International Organization for Migration (IOM) to build capacity within VF and with our suppliers regarding responsible recruitment practices and ethical treatment of migrant workers. With technical assistance from the IOM, we have updated our Facility Standards, our audit scope, the data we collect on migrant workers, and formalized a set of guidelines for the ethical and responsible recruitment of migrant workers.
Risk Assessments, FACTORY Audits and supplier Due Diligence and Traceability
Human Rights Risk Assessments
In line with the expectations of the UN Guiding Principles on Business and Human Rights, we map our human rights risks. This includes periodic Human Rights Impact Assessment (HRIA) to help us identify our most salient issues. We partner with human rights experts to inform our HRIA. In addition to our enterprise-wide risk assessments, we assessed the risks within our top commodities: cotton, rubber, leather, wool, down and our synthetics material supply chain.
In addition, we contracted with Verité to compile and analyze publicly available information on documented forced labor incidents and forced labor vulnerabilities in more than 40 countries. These profiles include countries that supply finished products to VF, as well as countries further upstream in our supply chain. This deeper analysis informed our prioritization of actions to mitigate forced labor risks and identify and engage with credible partners or initiatives to implement solutions.
Our forced labor risk assessments also help us prioritize worker rights engagement at the Tier-2 level (fabric mills). We launched the pilot project “Your Voice Matters” with our partners Ulula and Quizrr, along with support from the IOM. Through this project, we engaged our Tier 2 suppliers in Jordan, Taiwan and Thailand to proactively learn, understand and discuss recruitment processes, conditions for migrant workers, and how we can work together on improvements. Following a successful pilot, we converted “Your Voice Matters” to an ongoing program. To gain additional assurance that we hear from the workers themselves and to understand the impact of the program, we are working in partnership with Ulula and Quizrr to roll out digital solutions for remote impact assessment, more effective communication, and online training for both management and workers.
Factory Compliance Audits
We conduct routine Factory Compliance Audits at every contracted supplier facility to assess their adherence to VF’s principles. Before conducting business with VF, each contracted factory must undergo a Factory Compliance Audit. Our audit process includes scheduled and unannounced audits by our trained factory compliance auditors and third-party auditors. We use our own trained factory compliance auditors, as well as accredited third-party auditors to assess vendor compliance with our Terms of Engagement and Global Compliance Principles. We inspect for evidence of health and safety concerns, wage and social compliance, forced labor and human trafficking, child labor issues, harassment-free workplace policies, and environmental issues. Regarding forced labor, our auditors look for recognized indicators, including excessive recruitment fees, absence of formal contracts, document retention, excessive working hours, payment of on-time wages and restrictions on freedom of movement. Our audit procedures also apply to nominated Tier-2 factories, cutting facilities, sewing plants, screen printers, embroiderers, laundries, licensee factories and key fabric mills.
To receive an “accepted” rating, a factory must not have any serious health, safety or labor issues in its facility. A factory receiving an accepted rating is audited annually. A factory receiving a “developmental” rating may still produce our products, but a follow-up audit will be scheduled after six months, and the factory is expected to have all issues remediated that were noted in the corrective action plan. A factory with persistent safety, health or labor issues that fails to remediate issues in an acceptable manner will be rejected as our supplier and unauthorized to supply product for VF. VF’s Facility Standards provide direction for our contracted factories to assist in compliance with our audit program.
Under our Global Compliance Principles, contracted factories must allow VF representatives full access to production facilities, employee records and employees for confidential interviews in connection with monitoring visits.
Audit Results and Response
In fiscal year 2022, approximately 1,300 audits were conducted globally. The audits included an assessment of compliance with our labor standards, among other issues. Factories were rejected for failing to meet one or more of our standards, including issues related to health and safety, wages and benefits, and environmental requirements.
In some parts of the world, supplier factories may face unique challenges in conforming to our Global Compliance Principles. In these cases, we work to help those factories understand their deficiencies and how to resolve the issues that exist. Our Sustainable Operations Team members also work with factory management to build capacity so that the factories can meet VF’s compliance requirements. However, if a factory has persistent safety, health or labor issues that they fail to remediate, we will terminate our business relationship in a responsible manner.
We developed a multi-pronged approach to address certain challenges created by the global COVID-19 pandemic. We introduced virtual auditing, deployed third-party auditors in countries where VF auditors could not conduct on-site audits, adopted desktop verifications of certain data points and conducted continuous virtual monitoring. There was an increase in findings related to unauthorized subcontracting and wage payment issues given the many business disruptions caused by COVID-19. We worked to remediate these issues when they occurred.
Supplier Due Diligence and Traceability
VF conducts supplier due diligence and supply chain tracing to support and enforce our prohibition on the use of forced labor in our supply chain. Prior to onboarding any new factory, VF screens the factory against various prohibited entity lists and reputable public sources and identifies entities potentially implicated in forced labor. VF also initiated several technology pilots to enhance our ability to proactively identify and mitigate forced labor risk in our supply chain. VF maintains a heighted focus on due diligence, supplier screening and traceability for any countries or regions with a higher reported risk of forced labor. VF monitors and responds to new legal requirements related to forced labor as they are enacted.
Tracing the origins of our cotton fiber is critical to aligning with VF’s Cotton Sourcing Policy and complying with customs laws. Our cotton traceability survey is distributed to all Tier 1 factories producing cotton-based product and nominated Tier 2 fabric mills producing cotton or cotton-blended fabric. Starting at Tier 1 product manufacturing, we trace the material through each tier of the supply chain, identifying Tier 2 fabric mills, Tier 3 yarn spinners, Tier 4 cotton gins and Tier 5 cotton farms, as well as any trader or agent involved in the transfer between these tiers. For additional specifics regarding cotton, please see our Policy on Cotton Fiber Sourcing.
VF continues to expand its traceability work beyond cotton to cover other commodities. Increased supply chain visibility enables us to better connect with and communicate requirements on traceability, so our suppliers can provide the required documentation to verify chain of custody of raw materials used for VF products.
VF associates are required to complete online and facilitator-led training on our Code of Business Conduct during their first 30 days and sign an agreement to abide by its principles, including those related to modern slavery. For our associates and management who have direct responsibility for monitoring, auditing and enforcing our Global Compliance Principles, we provide additional training conducted by our staff or a third party. Training includes topics such as identifying child labor, involuntary or forced labor and preventing human trafficking. Over 4,500 associates have received training on human trafficking.
In fiscal year 2022, our relevant on-the-ground teams also completed two modules of capacity building training with the IOM regarding forced labor indicators, the migrant worker journey and best practice guidance for responsible recruitment.
In addition, our Sustainable Operations Team assists factory management at VF-owned and contracted factories in understanding how they can make improvements to meet our modern slavery compliance requirements.
Grievance mechanism and ethics helpline
VF is committed to fostering dialogue and communication through multiple channels, including our Open-Door Policy and our Ethics Helpline. Labor issues can be reported through the VF Ethics Helpline, which includes multiple channels for raising concerns. The Helpline is a free, confidential way for anyone to seek guidance, ask a question or raise a concern. It is available 24 hours a day/seven days a week in every country where VF has associates. Reporters can contact the Helpline in over 100 languages, and anonymous reporting is available where allowed by law. Each report is reviewed by a member of our Ethics and Compliance team and assigned to an appropriate investigator. To contact the helpline, call 1-866-492-3370 or visit ethics.vfc.com.
VF’s Ethics Helpline and other grievance mechanisms are available to the entire supply chain, including workers in the second or third tier of the supply chain. VF prohibits suppliers from taking retaliatory action against workers using these mechanisms. VF also encourages suppliers to establish their own grievance mechanisms.
VF is committed to upholding human rights globally. We believe it is the responsibility of every person who touches our business to assist in upholding those rights as outlined throughout this statement.
This statement covers the period from April 4, 2021, to April 2, 2022, and has been approved by the Board of VF Corporation.
Director and Interim Chief Executive Officer
 VF audit data disclosed after March 2021 includes all brands in the VF portfolio.