Forever New’s Supply Chain

Forever New works in a partnership approach with our suppliers, (updated July 2023), some of which we have worked with for as long as fourteen years.

We regularly visit our suppliers around the world to audit working conditions and processes and monitor adherence to our Supplier Code of Conduct. This forms the minimum expectations with regard to the labour standards and workplace conditions of our supply chain partners.

This enables us to work collaboratively with our suppliers to understand, measure, report on, and help improve their organisations social and environmental performance.

Our goal is to drive continuous improvement within our supply chain and to help improve the lives of the workers that make our products. Forever New employs dedicated in-house ethical compliance teams in our main manufacturing countries. Our auditors are highly experienced and qualified to conduct audits against BSCI, SA 8000, ICS and SMETA methodologies.

In FY21 we conducted 59 audits with 120 compliances checked against at each audit. 5 non compliances were found on average in each audit. To ensure continuous improvement of workplace conditions and drive progress on issues identified in audits, suppliers are required to engage in time bound corrective action remediation plans which are overseen and managed by our in-country compliance managers . 50% of all corrective action plans raised were closed same financial year. The most prevalent findings of non compliances were related to working hours, social insurance payments and safety such as overtime, waste not segregated, aisle marking faded, goods stacked too high and workers not wearing sufficient/correct PPE.

In addition to checks by our own auditing teams, many of our factories commission independent audits conducted by a variety of third party auditors including Elevate, Accordia, Algi, Bureaux Veritas, Intertek, SGS and UL.

Many of our factories are also Sedex members. Sedex is a platform which allows audits and corrective actions to be shared between multiple retailers. This multi-stakeholder approach allows for greater transparency of the factory’s objectives and progress and reduces audit fatigue.

In partnership with an established NGO, we have implemented a confidential worker hotline in strategic factories in China to accompany existing factory-level grievance mechanisms. Findings from this programme inform our supplier engagement strategy.

For those suppliers who fully embrace our Code and Values, we commit to a continuous improvement approach over time, whereby we use our commercial leverage to influence and support any necessary improvements.

Whilst we will always prioritise this approach, Forever New reserves the right to terminate relationships with suppliers who do not commit to our values or demonstrate meaningful change when gaps in adherence to our Code of Conduct are discovered.

Our suppliers are very important to Forever New and integral to our work towards increased supply chain transparency and ethical trade.

In addition to expectations outlined in the ETI base code, Forever New does not tolerate bribery or corruption in any form and expects transparency from our suppliers at all times, including during audits conducted by or on behalf of Forever New.

Non-Discrimination and Gender Equity

Discrimination in any form, including on the basis of gender, is not tolerated.

Forever New is committed to addressing any gender inequality in our supply chain. Our compliance programme monitors gender profile across permanent, temporary and migrant workers and provides special assessment of home workers [if applicable].

We are committed to collaborating with our industry peers to collectively identify and resolve systemic issues.

GENDER EQUALITY IN THE SUPPLY CHAIN POLICY

Compliance with legal wage requirements is assessed as part of our factory audit and monitoring programs. Forever New monitors national minimum wage increases in the countries in which we operate and engages with our suppliers as well as buying teams to ensure they are across these increases for costing conversations.

Beyond these minimum requirements, Forever New is committed to providing living wages for all workers within our supply chain, a requirement which forms part of our Code of Conduct, agreed to by all suppliers.

Living Wage Definition

A living wage should be earned in a standard work week (no more than 48 hours as a maximum) by a worker and be sufficient to afford a decent standard of living for the worker and her or his family. Elements of a decent standard of living include adequate nutritious food, housing, healthcare, clothing, transportation, energy, water, childcare, education, other essential needs including some discretionary money and provision for unexpected events. A living wage should allow individuals to work and thereby lift themselves and their families out of poverty.

Our Commitment and Milestones

Whilst we recognise there is no globally agreed living wage methodology, we acknowledge and benchmark our wage data against the Global Living Wage Coalition (Anker) calculations. In 2022, we completed a benchmarking exercise and wage gap analysis for the first tier of our supply chain.

We have used this data and learnings from the implementation of our Responsible Purchasing Policy to inform the development of our living wage strategy and ongoing discussions with suppliers. Forever New is committed to working with our suppliers to itemise wage levels in price negotiations. We will include all direct and indirect labour cost components in costing calculations. We are currently piloting this with core suppliers and anticipate extending fully by 2023/2024. We remain committed to promoting freedom of association, collective bargaining and effective wage management systems and recognize that a multi-stakeholder approach to living wages is vital. We continue to work in collaboration with industry organisations, NGO’s, peers and initiatives working towards best practice approaches to living wages.

Forever New works in cooperation with our suppliers with open dialogue, some of whom we have worked with for over a decade. We hold direct relationships and do not use agents nor engage in price bidding.

We are committed to responsible sourcing and acknowledge that purchasing behaviour can play an important role in influencing working conditions for those making Forever New Products.

In order to build internal capacity across our design, planning and buying teams, in Q2 2019 we implemented comprehensive guidance on responsible sourcing through the development of a Responsible Sourcing and Purchasing Policy, guidelines and staff training. Ongoing, all new design and buying teams will receive this training and must align their practices accordingly. Staff are also required to complete and pass an online e-learning module.

Implementation of this policy across all functions of the design and buying cycle at Forever New includes a commitment to engage in accurate forecasting, mutually agreed lead times, capacity assessment and reservation, fair negotiations and payment terms, delivery flexibility, sampling accuracy, order placement consistency and responsible exiting. We recognise the importance of open dialogues with our suppliers and will seek feedback on our purchasing behaviour through anonymous surveys annually.

Senior Management is responsible for implementation and compliance with this policy, which includes regular evaluation reviews.

OUR RESPONSIBLE SOURCING AND PURCHASING POLICY

All suppliers are required to comply with relevant environmental laws and regulations, including obtaining necessary permits and licences.

Environmental Management Systems, which consider water treatment, waste reduction and disposal, air pollution, carbon emissions and the management of chemicals must be maintained.

Our audits monitor handling and storage of hazardous substances, safe disposal of waste as well as the treatment of wastewater.

Hazardous Substances

All suppliers must comply with all local and international regulations on the use of chemicals, including compliance with REACH and OEKO-TEX standards. Additionally, all suppliers must also comply with Forever New’s Restricted Substance List and testing guidelines.

Our commitment to responsible materials extends to the highest animal welfare standards. Our Animal Welfare Policy strictly prohibits the use of real animal fur in any Forever New products or trims.

Forever New requires all suppliers to meet the requirements of our Animal Welfare Policy.

We expect the highest level of animal welfare as per best practice industry standards and require all animals be afforded the Five Freedoms, as recognised by the RSPCA:

• Freedom from hunger and thirst
• Freedom from discomfort
• Freedom from injury or disease
• Freedom to express normal behaviour
• Freedom from fear and distress

Any animal material used in Forever New products must be a by-product of the food industry. We do not use real animal fur, angora rabbit hair or exotic skins.

FOREVER NEW ANIMAL WELFARE POLICY

Fur Free Retailer

We are a member of the Fur Free Retailer programme, an initiative of the Fur Free Alliance. By joining this international initiative, we are reinforcing our commitment to sourcing alternatives to animal fibres. To be fur free means not to sell or promote any products that contain real animal fur.

International Accord for Health and Safety

We are a signatory to both the 2013 and 2018 Bangladesh Fire and Safety Accords and fully support all efforts towards factory safety for workers in Bangladesh.

In 2021, Forever New signed the new International Accord for Health and Safety in the textile and garment industry. A full list of signatories and details of the International Accord for Health and Safety can be found on the International Accord website.

Our Pledge Against Forced Labour in the Cotton Sector

We are proud to collaborate with this multi-stakeholder coalition to raise awareness of this very serious concern and press for its elimination. As a signatory to both the Uzbek and Turkmen Cotton Pledge, we are stating our firm opposition to the use of forced labour in the harvest of Uzbek and Turkmen cotton.

We commit to not knowingly source Uzbek or Turkmen cotton in the manufacturing of any of our products until the Government of both countries ends the practice of forced child and adult labour in its cotton sector.
Until the elimination of this practice is independently verified by the International Labour Organization, we will maintain this pledge.

BAN ON COTTON HARVEST FROM UZBEKISTAN

To request a copy of our Whilstleblower Policy, please contact:

Whistleblower Protection Officer
Forever New
Botanicca Corporate Park
Building 8, Level 1
584 Swan Street
Burnley Victoria 3121
Australia
Email: [email protected]

During these profoundly challenging times arising from COVID-19, we have worked hard to reduce the impact on our supply partners by honouring our commitments and prioritising the safety of the workers in our supply chain.

The steps we have taken include the following:

• We have committed to take completed orders and all orders in production and continue to pay in full at originally agreed prices.
• Orders which were not yet in production have been rephased according to market demand and supplier capacity rather than cancelled.
• Where we have been able to redistribute seasonal product to other global regions where our product is sold, we have done this to honour purchase orders.
• We are working through commitments to raw materials which were purchased for rephased orders to assist with supplier liabilities.
• Re-ordering has already recommenced, taking into consideration factory capacity and reflective of customer demand.

The health and safety of workers remain paramount, and we continue to work with our suppliers to ensure safety measures are in place across all factories including the provision of training material relating to PPE, social distancing and hygiene. This will be ongoing as more factories resume production.