Sara Lee Knit Products International Operating Principles
Chapter V. Appendices
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Appendix C: Codes of Conduct Provided by Companies Surveyed

Sara Lee Knit Products International Operating Principles

Position Statement

The policies that govern our business are based not only on laws and regulations, but also on dignity and respect for the individual, common sense, fairness, and good business practices/principles and Sara Lee Knit Products (SLKP) operating philosophies. The policies that have traditionally applied to our domestic operations have been, for the most part, applied to our international operations as they have been developed. The only exceptions have been in countries where local laws, regulations, customs or culture have dictated modifications and departures from our domestic practices.


The fundamental principles of our domestic policies, to the greatest extent possible, extend to our international locations. Our workforce has become more diverse and our operations now extend to many countries and regions. In addition to our own international operations, we also buy materials and finished products from international suppliers. The principles that apply to our own operations, also apply, to the greatest extent possible, to our business relationships with suppliers.

While there is a continued need for development and revision of formal policies, it is desirable that we restate the principles under which we have operated in the past and which will continue to apply to our international operations.

Laws and Regulations

SLKP is committed to adherence to laws, practices and regulations which apply to the areas where we conduct business. SLKP will conduct a thorough due diligence of all potential sourcing/joint venture parties and will not enter into business agreements, sourcing agreements or joint ventures where parties to such agreements are in conflict with, or in violation of, local laws or regulations.

Ethical Practice

SLKP believes in conducting all of its business activities with honesty, fair dealing and in conformance with high ethical standards wherever it operates. The company will not make or condone illegal payments or other facilitating payments, nor will it involve itself in activities or practices of questionable ethical standards.


SLKP is strongly committed to the strict adherence to all environmental rules, regulations and standards that are imposed by local, state and national government authorities. In countries where standards differ from those in force in the United States, SLKP will observe environmentally sound practices.

Wages and Benefits

SLKP prides itself on providing employees with competitive wages and benefits. Regardless of location, SLKP offers wages which are competitive and which are at or above wages paid by others within our industry in the area. SLKP believes that an important way to motivate and retain good employees is to pay them at competitive levels without causing undue disruptions of local, regional or national economics.

Working Conditions

SLKP believes in providing employees with superior working environments which are designed, built and equipped to the same high standards everywhere we operate.

Hours worked each day, and days worked each week shall not exceed legal limitations or requirements within each of the countries where we operate.

The company believes that employees are entitled to work in a drug-free environment and is actively implementing an extensive substance abuse policy in accordance with applicable laws to include educational programs, safety sensitive, accident, applicant testing and rehabilitation programs in all places where we operate.

Employee Communications

SLKP operates on the principle that an informed employee is a better employee. The company actively encourages two-way communications between employees and supervisors and supplements such communications with timely publications, bulletin board notices, employee meetings and video communications.

Workplace Safety

SLKP is committed to providing a safe working environment. Unsafe practices will not be tolerated and employees will be trained in safe practices. Safety rules related to the wearing of safety equipment or devices will be strictly enforced.

Open Door Policy

SLKP believes that employees have a right to present complaints, problems, grievances and comments to receive satisfactory responses. If employees are not satisfied with responses at the first level of supervision, they are entitled and encouraged to present their issue to higher levels of the organization.

Labor Unions

SLKP believes in a union-free environment, except where laws and cultures require us to do otherwise. The company treats people with equity and fairness, and believes that employees themselves are best able to voice their concerns directly to management. SLKP is committed to the strict observance of laws and regulations related to union activity and encourages individual freedom and direct dealing between employees and management while actively discouraging union representation of employees where the law allows.

Equal Opportunity and Employee Training and Development

SLKP is an equal opportunity employer. The company actively seeks and promotes diversity within its workforce and strictly prohibits discrimination with regard to race, color, national origin, religion, sex, age or disability.

The company respects employees and believes in the fundamental dignity and worth of the individual. SLKP offers its employees company-paid or subsidized work -related training, which enables employees to improve job skills and to qualify for positions of greater responsibility.

While the legal definition of children sometimes varies from country to country, SLKP will not employ individuals who are under 16 years of age.

Employee Recognition, Empowerment and Treatment

SLKP believes that employees should be recognized and rewarded for good performance, and actively encourages the adoption of suitable programs for this purpose.

SLKP is committed to employee empowerment in the belief that employees have good ideas and should be given the opportunity to voice those ideas and to implement better and more productive procedures and methods. SLKP believes that empowerment directly and significantly contributes to the company's goal of achieving lowest-cost, highest-quality producer status and that this, in turn, enables the company to effectively compete in world markets.

Community Relations

SLKP believes in being a good corporate citizen in every community, locality and country where we operate. All of the company's operating facilities are actively encouraged to become involved in the life of their communities by participating in and sponsoring activities that result in community betterment. Involvement has taken many forms. Some plants have adopted schools; some have promoted drug education programs; others have adopted orphanages; while still others have helped establish child-care centers and community child-care homes.

In some less developed areas, plants have helped establish parks, recreational facilities, health care facilities, drug abuse programs and have contributed to the building of housing and infrastructure. Individual employees are encouraged to become involved in service organizations, school board, chambers of commerce, industrial park associations and local government.

Corporate Contributions

In every community where it operates, SLKP actively seeks out opportunities to contribute money and materials to worthwhile causes. SLKP wants to make the community a better place for its employees to live and work. SLKP is particularly interested in programs that benefit youth, drug education and abuse programs, health, welfare, education, family, culture and art.

The above is a summary of key operating principles for our international operations. For additional detail on covered items, please refer to more detailed international policies, procedures and human resources plans.

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Child Labor Report 2005

Child Labor

This report was developed and provided by the U.S. Labor Department

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