This document sets forth the expectations and guidelines for all vendors and factories that provide merchandise to G-III APPAREL GROUP, LTD. (“G-III”).
G-III has a long-standing commitment of conducting its business in accordance with high moral, ethical, and legal standards, and in compliance with all applicable laws. We choose vendors and factories who share this commitment. While G-III recognizes that there are different cultural, legal, and ethical environments in the countries throughout the world in which merchandise purchased by G-III is manufactured, this Vendor Code of Conduct sets forth the basic minimum requirements that all G-III’s vendors and factories must meet in order to do business with G-III. G-III strongly encourages vendors to exceed these standards and promote the best practices in all factories in which they manufacture merchandise.
When differences or conflicts in standards arise, vendors and factories are expected to apply the highest standard. G-III will use either, an on-site Internal Compliance Monitoring (“ICM”) Audit or engage a third-party firm to assess its business partners to ensure compliance with these standards.
G-III’s vendors and factories must operate in full compliance with the applicable laws, regulations, rules and local legal requirements relevant to the conduct of their business. They must adopt and adhere to rules and conditions of employment that respect workers and, at a minimum, safeguard their rights under applicable national and international labor and social security laws and regulations. We will seek vendors and factories who respect the legal and moral rights of the employees.
The use of Child Labor is strictly prohibited. Employees of G-III’s vendors and factories must be over the applicable minimum legal age requirement — generally 16 years old — But no persons shall be employed under the age of 15, or under the age for completion of compulsory education, whichever is higher. The vendors and factories must observe all legal requirements for work of authorized minors, particularly those pertaining to hours of work, wages, minimum education, work type and working conditions. Facilities must maintain proper documentation of each worker’s date of birth. G-III supports the development of lawful, legitimate workplace apprenticeship programs.
Forced or Compulsory Labor and Human Trafficking
The use of forced or compulsory labor is prohibited. Vendors shall ensure all work is voluntary. G-III’s vendors and factories shall not in any way use or support the use of forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise. Vendors shall not unlawfully retain government-issued identity papers, require workers to deposit a bond as a condition of employment, or unlawfully detain or restrict workers’ movements. Mental and physical coercion, slavery, and human trafficking are prohibited throughout our supply chain.
Health & Safety
Vendors and factories shall ensure all applicable laws, regulations, and rules that pertain to health and safety in the workplace are followed. The employer, bearing in mind the prevailing knowledge of the industry and of any specific hazards, shall provide workers a clean, safe, and healthy working environment, including systems and training designed to help prevent accidents, illness, and injury attributable to the operation of the facility and machinery. Responsible measures must be adopted to mitigate negative impacts on the environment. Employers must provide all required and appropriate workers compensation coverage in the event of injury. The employer shall appoint a management representative who is accountable for the health and safety of all personnel.
Freedom of Association and Right to Collective Bargaining
Vendors and factories shall recognize and respect the right of workers to freedom of association and collective bargaining. No worker shall be subject to harassment, intimidation, or retaliation in their efforts to freely associate or bargain collectively. The Employer shall allow union organizers access to employees and shall recognize the union of the employees’ choice in accordance with the law and regulation. When the right to freedom of association and collective bargaining is restricted under law, employers shall not obstruct legal alternative means of workers’ association.
All employment decisions, including but not limited to hiring, job assignment, wages, bonuses, allowances and other forms of compensation, promotion, discipline, work assignments, termination of employment, provisions of retirement, shall be made solely on the basis of education, training, and demonstrated skills or abilities. Employers shall not discriminate in employment, including gender, race, religion, age, disability, sexual orientation, marital or maternity status, nationality, political opinion, social class or ethnic origin. Employers must act in accordance with law and not improperly discriminate.
The employer shall document and communicate to all workers a progressive disciplinary policy, e.g., escalating disciplinary action steps such as verbal warning, written warning, suspension, and termination. Any exceptions to this rule, e.g., immediate termination for theft, assault, sexual harassment or mental harassment, shall be clearly communicated to workers.
Harassment and Abuse
Vendors and factories must treat employees with respect and dignity. G-III will not utilize vendors and factories that use or permit the use of corporal punishment, physical, sexual, psychological, or verbal harassment, or other forms of mental or physical coercion, abuse or intimidation.
Wages, Compensations, and Benefits
Wages are essential for meeting the basic needs of workers. Every worker has a right to compensation for a regular work week that is sufficient to meet the worker’s basic needs and provide some discretionary income. The employer shall ensure that wages paid for all hours worked meet at least the legal minimum wage required by the local law and regulations or the appropriate prevailing wage, whichever is higher. The employer shall provide all legally mandated fringe benefits and wage requirements to all employees as required by law or contract. Employees shall be compensated for overtime hours at the rate established by law or regulations in the country of manufacture or, in those countries where such laws do not exist, at a premium rate. If the compensation paid does not meet the worker’s basic needs and provide some discretionary income, our business partners are required to take appropriate actions that seek to progressively realize a level of compensation that does.
Vendors and factories must also provide employees with a clear written accounting for every pay period and must not deduct or withhold wages or benefits for disciplinary infractions.
The employees shall not be required to work (inclusive of overtime) more than the local legally prescribed limits. Vendors and factories shall comply with the local applicable laws and regulations that entitle workers to vacation time, leave periods, and holidays.
Employers are prohibited from requiring their employees to work more than the regular and overtime hours permitted under the law of the country where they are employed. In no circumstance may regular hours exceed 48 hours in a week and, other than in exceptional circumstances, the sum of regular and overtime hours in a week must not exceed 60 hours. Employees must have at least 24 consecutive hours of rest in every seven-day period. Employers are not permitted to request overtime on a regular basis. All overtime must be consensual and compensated at a premium rate.
All vendors and factories shall comply with all applicable environmental laws, rules, and regulations in their countries and the communities in which they operate. This is inclusive of those related to emissions, discharge, and disposal of waste, including chemicals, water, energy, hazardous chemicals, and air quality. Responsible measures must be adopted to mitigate negative impacts on the environment. G-III encourages the nurturing of a better environment at the facilities and in the communities in which they operate.
All vendors or factories providing merchandise to G-III must be disclosed. Vendors or factories that outsource or subcontract work in the production of G-III merchandise shall obtain prior written authorization for doing so. If work is done at another location, the outsourcing employer shall be responsible for assuring that the subcontractor is in compliance with standards set forth in this Code of Conduct.
Access to Facilities
Vendors and factories providing merchandise to G-III are prohibited from denying access to auditors engaged by G-III, G-III employees, or its brands or customers at the facilities where G-III merchandise is produced.
Anti-Corruption and Unsolicited Payments
Vendors and factories are expected to share our commitment to integrity and business ethics. Suppliers shall agree to condemn and act against all forms of corruption. Bribes, kickbacks, favors or other similar unlawful payments, in cash or kind, are strictly prohibited whether given or attempted to be given to any employee, employee family member, associate, affiliates or representatives of the company, any governmental official or agent, or any other company, intermediary or person to obtain a business or personal advantage, or any other illegal benefit.
The employer shall designate specific members of management and supervisory personnel to ensure ongoing compliance and training with these requirements.
Vendors and factories shall protect the reputation of all G-III brands and customers. Any illegal activities (such as counterfeiting, diversion and other intellectual property rights violations) are prohibited.
Customs, C-TPAT and Supply Chain Security
Vendors and factories shall be aware of C-TPAT security guidelines and standards, and ensure compliance with security requirements. Vendors and factories shall comply with all applicable import and export customs laws, including those regarding the importation and prohibition of transshipment of merchandise into the country of import. Our suppliers shall implement security policies and procedures in accordance with our participation in the United States Customs-Trade Partnership against Terrorism (C-TPAT).
Monitoring and Documentation
In order to verify compliance, the employer shall allow G-III auditors and representatives free access to all facility grounds, workers interviews and whatever other resource is necessary to verify compliance. The factories must maintain sufficiently detailed records and documents for the past 12 months to enable G-III auditors and representatives to verify their compliance with this Code of Conduct and shall disclose such information, without falsification or misrepresentation. G-III reserves the right to audit vendors, factories, and suppliers unannounced and without prior notice.