MEC is committed to the fair treatment of workers throughout our MEC Label supply chain. One important part of this effort is to eliminate the potential for forced labour.
We expect our supply chain partners to treat all workers – including foreign migrant workers – fairly, ethically, and in line with local laws and international standards. One of our critical requirements is that no workers pay for their employment. Paying for employment increases the vulnerability of foreign workers and can put them at risk for involuntary employment. MEC believes in the employer pays principle, which means it is the employer’s responsibility to pay for any costs associated with recruiting and hiring employees, as well as fees during employment.
In 2018, MEC signed the American Apparel & Footwear Association and the Fair Labor Association’s Commitment to Responsible Recruitment to address these issues. We’re working 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
- Every worker knows the basic terms of their employment before leaving home.
Standards we have in place
Any supplier that wants to do business with MEC needs to uphold our supplier code of conduct, which sets out our minimum standards for workers’ rights and environmental responsibility.
If suppliers are hiring workers from other countries, they also need to commit to the MEC Foreign Migrant Worker Standards and Guidelines. These standards act as a step-by-step guide for contracted facilities to familiarize themselves on the subject, and how to appropriately and ethically recruit or manage foreign migrant workers. The goal is to eradicate all forms of forced labour.
MEC policies on slavery and human trafficking are incorporated into our supplier code of conduct and the foreign migrant worker standards. The policies include:
- There shall be no use of forced labour, whether in the form of prison labour, indentured labour, slave labour, bonded labour, or other forms of forced labour.
- Acts of human trafficking are prohibited.
- Employers are required to monitor their internal practices and any third-party entity, such as labour recruitment agencies, to ensure employees are not compelled to work through force, deception, intimidation, or punishment.
- Employers are responsible for any employment eligibility fees for migrant workers, including recruitment fees.
- All work must be voluntary, and workers must be free to terminate their employment at any time, without penalty.
Who created our foreign migrant worker standards?
MEC’s standards were adapted (with permission) from foreign migrant worker guides and plans that Patagonia and Lululemon created. They’re the culmination of legal requirements and international standards created by credible organizations, such as the United Nation’s International Labour Organization, the Institute for Human Rights and Businesses, and the Fair Labor Association. The standard is approved by the MEC senior management team, and our global sourcing and social and environmental responsibility teams work with suppliers to uphold the standards.
Ways we assess potential risks
MEC Label products are manufactured in factories around the world, and we use raw materials from dozens of vendors.
There are many factories and suppliers involved in our supply chain. When we explore suppliers beyond tier one (the final cutting and sewing of products), we take a country risk analysis approach. This approach gives us a comprehensive view of potential risks in different geographic areas and where we can have the greatest impact, which helps us prioritize work throughout the MEC Label supply chain.
We monitor where we source products and materials, and assess each country’s human rights and environmental records to minimize potential risks to workers and commercial interests in unstable parts of the world. In 2015, MEC partnered with British Standards Institution (BSI) to provide us with real-time data about country risk assessments, focusing on human rights, environment, child labour, women’s rights, working conditions and forced labour. The country risk data from BSI helps us make decisions for our social responsibility and responsible sourcing programs.
Along with the country risk assessment, MEC also assesses what local NGOs or local groups exist in the sourcing countries that can help provide a closer perspective on what’s happening in the region. We also have our own sourcing onboarding procedure and audit program to vet factories before we start working with them.
MEC first learned about risks of forced labour in our supply chain in the 2000s through our social responsibility and auditing program, when we found restrictions to the freedom of movement of foreign migrant workers with the practice of holding passports and mandatory saving accounts in Taiwan.
How we’ve made a difference so far
Fixing issues like these takes time and involves many people. After we uncovered forced labour in our supply chain in Taiwan, we continued to audit factories and made sure corrective action plans were in place to stop the practice of holding onto passports and mandatory savings accounts.
We also met with the Taiwanese and Canadian governments to understand what protections they can put in place from a national point of view, and connected with the International Organization for Migration to understand what areas MEC can focus on to have the biggest impact.
In 2015, we partnered with outdoor industry brands to share third-party assessments conducted by Verité. These assessments focused on identifying, assessing and managing risks and human rights violations that foreign migrant workers may face related to human trafficking. Part of the scope is to identify where there are labour brokers in our supply chain, so we can understand all the fees a foreign worker pays when they leave their country to work in a different country. All the pieces come together – country risk assessments, Verité assessments, audits and partnering with outdoor industry brands – to create action plans for suppliers. We’re supporting these action plans to help eliminate recruitment fees.
Through our audit program, we’ve identified and remediated some forms of forced labour in Taiwan related to restriction of movement by holding foreign migrant worker passports and mandatory savings accounts. In partnership with Verité, MEC led a training session on forced labour for our Taiwan supply chain, specifically around holding passports and mandatory savings accounts. Each facility was given a timeline to return all personal documents and to provide a safe, secure and accessible place where foreign migrant workers could access and control their documents at any time. After the training, we did formal audits and confirmed that all factories met our requirements.
What’s next for recruitment
We still have open areas of non-compliance around recruitment fees and are finding ways to fix these issues.
Along with signing the Commitment to Responsible Recruitment, MEC and six other brands joined forces in 2018. These six brands and MEC made a commitment toward advancing respect for human rights. Together, we sent a joint letter about the employer pays principle to our shared raw material suppliers who are hiring foreign migrant workers and have a risk to modern day slavery. These facilities also received a copy of our foreign migrant worker standards and guidelines, and have been creating and implementing action plans to correct the problems around recruitment fees. When possible, we’ll work with other brands to support each supplier through this work.
MEC will continue to support ethical recruitment practices in our supply chain by:
- Assessing our supply chain through a foreign migrant worker focused audit
- Requiring factories to audit and monitor recruitment agencies
- Requiring factories to educate their employees, so that workers know they shouldn’t be charged illegal recruitment fees and understand the terms and conditions of their employment rights
- Eliminate recruitment fees throughout MEC Label’s entire supply chain (tier one to tier four) by 2025
