General Policy: It
is the firm policy of Oxford Industries, Inc. and its subsidiaries to do
business only with contractors who adhere to the laws of their host
countries. It is the responsibility of the Oxford contract manager or
employee who hires the contractor (1) to insure that each contractor
understands and agrees to abide by Oxford's policy in this regard, (2)
to take reasonable steps to ascertain that the contractor is in fact in
compliance with Oxford's policy, and (3) to document the steps taken to
comply with this policy.
Contractors: This policy covers all manufacturing contractors,
including, but not limited to, cutting, sewing, printing, embroidery,
finishing, dyeing and laundry con tractors. Also covered are
manufacturers who sell packages, i.e. completed garments whose price
includes fabric and trim.
Domestic and Foreign Policies: Oxford has two versions of its
Sourcing Policy, one for the United States and another for the rest of
the world. The two versions are attached. The Sourcing Policy (United
States) specifically requires adherence to the Fair Labor Standards Act,
and federal, state and local child labor and fair employment laws. It
also prohibits a contractor from hiring a worker who cannot legally work
in the United States. The Sourcing Policy (Worldwide) prohibits the use
of prison labor and addresses the issues of contractor-provided housing
Implementation: It is the responsibility of the contract
manager or Oxford employee who hires the contractor to:
- Explain Oxford's Sourcing Policy to the contractor's officers
- Give a copy of the Sourcing Policy to the contractor.
- Obtain a copy of the Contractor's Acknowledgement and Agreement
(copy attached) that has been signed by an officer of the contractor
and maintain this document in a safe and readily accessible place. The
relevant version of the Sourcing Policy should be attached.
- Periodically remind the contractor of its commitment to adhere to
the Sourcing Policy.
- Take reasonable steps to ascertain the contractor's compliance
with the Sourcing Policy. Depending on the location of facility these
steps may include reviewing the age documentation of workers who
appear to be underage, inspecting contractor-provided housing,
speaking directly with workers about wage payments and other working
conditions and randomly checking per sonnel files.
- Report all violations and suspicions of violations to the
appropriate Oxford manager.
Questions: Any questions about the Sourcing Policy and its
implementation should be directed to Oxford's Legal Department.
OXFORD INDUSTRIES, INC.
Oxford Industries, Inc. expects each of its manufacturing contractors
to treat its employees in a fair and equitable manner. To that end
Oxford will only employ those contractors who abide by the following
Children and Prisoners: No contractor shall use prison labor
or the labor of children below the minimum working age in the host
Wages and Benefits: Each contractor must pay its employees at
least the minimum required wages and benefits mandated by the laws of
the host country. Wages and benefits must be calculated and paid
according to the laws of the host country.
Health and Safety: Each contractor must provide a safe and
healthy work place to its workers.
Employee Living Conditions: If a contractor provides housing
or sustenance to its employees, these shall be at least to the normal
standards of the host country.
Subcontracting: No contractor may subcontract work without the
express written permission of Oxford and then such subcontracting shall
only be permitted to companies that abide by this Sourcing Policy.
Transshipping: All work shall be performed in the country of
origin which has been identified by the contractor.
Violation of this Sourcing Policy may lead to the immediate
cancellation of production contracts with the contractor.
ACKNOWLEDGEMENT AND AGREEMENT
____________("Contractor"), with a facility address
of_________________, hereby acknowledges that it has received and
understands the Oxford Industries, Inc. Sourc ing Policy, a copy of
which is attached to this Acknowledgement and Agreement, and in
consideration of being hired to manufacture certain products for Oxford
Industries, Inc., Contractor agrees to comply in all respects with the
requirements of the Oxford Industries, Inc. Sourcing Policy.
(Name of Contractor)