To address the regulations of the California Transparency in Supply Chains Act (SB 657), Danner defines slavery as “the act of holding the worker against his or her will and controlled physically or psychologically by violence or its threat for the purpose of appropriating their labor” as used by Free the Slaves (FTS). FTS is an international non-governmental organization (NGO) that campaigns against the modern practice of slavery throughout the world and is the largest anti-slavery organization in the United States.
Danner defines human trafficking as “any recruitment, harboring, transportation, provision, or obtaining of a person for labor services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery” as defined in the Victims of Trafficking and Violence Protections Act (TVPA) of 2000.
- Danner assesses the risk of slavery and human trafficking thru a preliminary audit of its supply chain in order to qualify that supplier. This audit is performed by Danner on potential suppliers thru factory visits by a contingent of Danner’s employees who work within supply chain functions. Audit includes on-site inspections, vendor profile assessment and Vendor Acknowledgement and Agreement.
- Danner conducts follow up inspections of direct suppliers. We have developed and issued a code of conduct in our Vendor Acknowledgement and Agreement to our direct suppliers. Direct suppliers are evaluated on their compliance to our code though continued factory visits and monitoring.
- Danner’s purchasing agreements require all suppliers to comply with our Vendor Acknowledgement and Agreement and applicable laws within the country, or countries, they do business regarding slavery and human trafficking.
- Danner maintains and enforces internal accountability procedures for employees and contractors regarding company standards in slavery and human trafficking. In the case of non-compliance, Danner reserves the right to examine the specific situation and develop a best possible strategy for resolution. If cases of non-compliance are not resolved within a timely manner, Danner may terminate the business relationship. While Danner wishes to aid in the resolution of incidences of human trafficking and slavery within Danner’s supply chain, it is not possible to effectively solve the issue of noncompliance without the cooperation of the supplier.
- Danner conducts internal training on Danner’s code of conduct to ensure the necessary participants in supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including human trafficking and slavery, with a particular focus on mitigating risks. Danner also encourages employees involved in Danner’s supply chain to participate in external training programs and seminars on social compliance issues, including on the issues of human trafficking and slavery.