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Animal Welfare Policy Development Guidelines for Fashion Brands and Retailers Last updated 02.06.2020

Alongside human rights and environmental protection, good animal welfare is a crucial component of due diligence and ‘ethical fashion’. Animal welfare issues and business risks can arise within any animal-based supply chain. Animals used by the textiles industry may be subjected to inadequate living conditions and diets, restricted movement, painful mutilations, long term mental stress, poor breeding choices and more. In today’s world, consumers care about how brands value animals and expect them to uphold an adequate level of animal welfare. International guidelines, such as those by the Organisation for Economic Co-operation and Development (OECD) reflect this sentiment, encouraging businesses to investigate the extent to which they could be implicated for animal welfare violations. Brands can influence the way animals are kept, by understanding the welfare risks in their supply chains, setting goals and establishing effective animal protection policies. When taking such steps, companies are proactively showing what they stand for, which practices they want to be identified with, and importantly, can greatly improve the lives of animals. FOUR PAWS is calling on brands to take responsibility for the welfare of the animals in their supply chains, and also to begin reducing animal product overall due to the inherent risks involved in commercial systems. FOUR PAWS encourages brands who use animal derived materials to publish a clear animal welfare policy and ideally an animal welfare strategy or implementation plan to ensure the policy is fulfilled.FOUR PAWS has put together the information and recommendations contained within this document to assist brands in developing these vital assets.

Contents 1. FOUR PAWS animal welfare principles

2. What makes an effective animal welfare policy

3. The Five Provisions and Aligned Animal Welfare

Aims

4. Animal derived materials policy

recommendations

5. What makes a robust assurance scheme

6. Policy implementation and monitoring

recommendations

7. Animal welfare policy examples

8. Contribution to the UN Sustainable

Development Goals Image: Shutterstock

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1. FOUR PAWS animal welfare principles

1. Animals should not be killed for the purpose of textiles.

With an increasing prevalence of high welfare and plant-

based textile alternatives available, killing animals solely for

the purposes of clothing is unnecessary, and cruel.

2. Wild animals should not be used for the purposes of

textiles.

Wild animals cannot be farmed in a way that meets their

basic physical and behavioral needs. FOUR PAWS also has

zero tolerance to using animals hunted or caught from the

wild, due to the direct and indirect suffering caused during

the capture and slaughter process. This includes, the potential

impact their absence has on the welfare of their offspring and

wild populations overall.

3. Any company using products derived from domesticated (traditionally farmed) animals must ensure adequate husbandry is provided. Brands should use robust certified schemes to ensure compliance to standards. Animal welfare policies should be developed in consideration of the Five Domains Model, and the according Five Provisions and Aligned Animal Welfare Aims designed to assess and encapsulate both the physical and mental state of animals (see table on page 5). 1 4. Traceability and transparency are vital to ensure adequate animal welfare standards as well as sustainable and ethical sourcing overall. Animal derived materials should not be used unless an adequate standard of animal welfare can be credibly verified and the supply chain can be traced via audits and documentation from the point of birth of the animal, to the point of sale of the finished product. Consumers want access to information on the welfare of animals from which materials are sourced, as well as the animal welfare standards that are upheld and certifications applied. It is the role of brands to ensure ethical sourcing, which is backed by robust traceability and transparency overall.

5. Efforts should be made to reduce the use of animal derived materials, because any use of animals within commercial systems brings inherent risks to their welfare. The animal friendliest choice is the use of sustainable and responsibly sourced plant-based alternatives. However, while domesticated animals are being used, all efforts to end cruel practices, minimise harm and encourage higher welfare should be a priority for brands and retailers sourcing animal derived materials.

1 Mellor. D 2016, ‘Moving beyond the “Five Freedoms” by Updating the “Five Provisions” and Introducing Aligned “Animal Welfare

Aims”’, Animals (Basel). 6 (10):59 doi: 10.3390/ani6100059

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2. What makes an effective animal welfare policy? For brands continuing to use animal derived materials, FOUR PAWS encourages the development of an animal welfare policy which includes the following: Vision and goals

✓ Best practice for companies using animal derived materials begins by defining a vision on

animal welfare. This should encapsulate the overall use of animals in accordance with the

brands’ values. For example, some brands may choose to reduce the use of animal products

over time, while others may aim for the highest welfare and traceability possible, and some

may do both while also committing to invest in broad industry animal welfare or traceability

initiatives.

✓ The next step is to define your measurable animal welfare goals. These should include:

• timely targets to identify and reduce animal welfare risk overall,

• supply chain traceability goals to increase insight into sourcing and rule out cruel

practices, and

• targets to reduce, recycle and/or refine the use of animal derived materials.

Policy content Animal welfare

✓ Within the policy, all materials of animal origin that a company either uses or actively

excludes should be listed and addressed.

✓ Cruel practices and farming systems such as mulesing, live feather plucking, factory farming

and fur production should be strictly banned as soon as practicable, and in the interim,

phased out, while aiming for the highest standards of animal welfare overall.

✓ Animal welfare policies and minimum keeping standards, should be based on the most up-to-

date and independent animal welfare research (i.e. The Five Domains Model – and aligned

Welfare Aims) and should be reviewed at least every three years to keep up to date with

advances in technology, animal welfare knowledge, and customer preferences.

✓ Companies should familiarise themselves with animal welfare legislation in their respective

country of residence and the countries where the animal derived materials are sourced.

Companies should ensure that these standards are met as an absolute minimum due

diligence measure. However specific animal welfare certifications or guidelines should be

listed within animal welfare policies, as country legislation can often be inadequate.

✓ With regards to imagery used within marketing materials, companies should ensure imagery

used is sensitive to animal welfare issues. Using live animals in photoshoots should be

avoided. If animals are used, all care should be taken to reduce harm, stress and fear. Wild

animals shouldn’t be used at all for photoshoots.

✓ Avoid including images of products which go against the Animal Derived Materials Policy

Recommendations listed below.

✓ Lastly, policies should take into consideration internationally agreed upon guidelines for

responsible business conduct and animal welfare risk mitigation, such as the

recommendations provided in the OECD-FAO Guidance for Responsible Agricultural Supply

Chains (page 63 onwards) https://bit.ly/2Q76igS

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Traceability ✓ Companies cannot rely solely on voluntary

self-declarations as proof of compliance to

their animal welfare policy. Companies

should employ robust certification and

assurance schemes to verify claims made

with regards to animal welfare. Assurance

initiatives approved for use by the company

as well as future aims with regards to

utilising increasingly stronger certification

options should be listed within the animal

welfare policy, (i.e. RWS targets, over the

NWD). For more on ‘What makes a robust

assurance scheme’ see page 7.

✓ For some supply chains, animal welfare

traceability solutions are not yet widely available (e.g. leather); in this instance companies

should seek information about their supply chains as an initial step. This is so that companies

may be able to establish transparency and identify risks in their supply chains and make

direct changes for those animals.

✓ However, until entire supply chains can become credibly certified, FOUR PAWS encourages

companies to avoid using such materials long term. In addition, FOUR PAWS urges

companies to support the commercialisation of sustainable, animal-free alternatives which

are innovative and of interest to a growing number of consumers.

✓ Company policy should explain how consumers are enabled to make informed decisions,

including how a company verifies responsible sourcing and whether information about the

certification of raw materials is applied to individual garments (e.g on product swing tags),

online, or via other means.

Reporting

✓ Animal welfare policies should specify the frequency of specific and overall external

reporting, and the method of information distribution (e.g. annual report and website),

ideally this would be on an annual basis.

✓ Reporting should include the ratio of product sales containing animal-based vs.

alternative/recycled textiles, as well as the proportion of certified vs. unknown/non-certified

animal-based materials and any other relevant information. This enables consumers and

advocacy groups to measure progress overtime.

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3. The Five Provisions and Aligned Animal Welfare Aims

The updated set of Five Provisions and Aligned Animal Welfare Aims (Mellor, 2016) are an evolution of the original animal welfare principles the Five Freedoms. The Five Provisions are supported by the animal welfare community and incorporate positive experiences as well as aim to minimise negative ones. It is important to encourage and seek assurance systems that utilise this methodology. The updated Five Provisions and aligned Animal Welfare Aims.

Provisions Animal Welfare Aims

1. Good nutrition: Provide ready access to

fresh water and a diet to maintain full

health and vigour

Minimise thirst and hunger and enable eating to be a pleasurable experience

2. Good environment: Provide

shade/shelter or suitable housing, good

air quality and comfortable resting

areas

Minimise discomfort and exposure and promote thermal, physical and other comforts

3. Good health: Prevent or rapidly

diagnose and treat disease and injury,

and foster good muscle tone, posture

and cardiorespiratory function

Minimise breathlessness, nausea, pain and aversive experiences and promote the pleasures of robustness, vigour, strength and well-coordinated physical activity

4. Appropriate behaviour: Provide

sufficient space, proper facilities,

congenial company and appropriately

varied conditions

Minimise threats and unpleasant restrictions on behaviour and promote engagement in rewarding activities

5. Positive mental experience: Provide

mental experience: Provide safe,

congenial and species-appropriate

opportunities to have pleasurable

experiences

Promote various forms of comfort, pleasure, interest, confidence and a sense of control

2

2 Mellor. D 2016, ‘Moving beyond the “Five Freedoms” by Updating the “Five Provisions” and Introducing Aligned “Animal Welfare

Aims”’, Animals (Basel). 6 (10):59 doi: 10.3390/ani6100059

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4. Animal derived materials policy recommendations

The methodology used to define the recommendations below is largely based on three main criteria: a) Can the species be farmed in a way that enables the animal to have a good quality of life?

b) Is the animal killed specifically for the product?

c) Are there any robust traceability schemes available to assist brands in safeguarding animal welfare? Is

traceability possible?

Materials Recommendation

Fur - Ban use of fur from any animal, regardless of whether they are bred or hunted for their fur or the pelts are

part of industry-owned certification programmes such as WelFur3 or similar initiatives.

- Join the Fur Free Retailer program4.

- If alternatives needed use eco-friendly materials like KOBA® Faux Fur or Satifur

Angora - Ban use of wool/fur from Angora rabbits.

Down feathers - Ensure that down feathers are only sourced post-slaughter from farmed ducks or geese raised for their

meat, and not from wild birds.

- Ban live-plucking and force-feeding and implement robust animal welfare and traceability certification

systems (for example, the Responsible Down Standard, Traceable Down Standard, or Downpass 2017).

Wool - Ban mulesed wool and set a time frame for phasing it out , ideally within the next 3 years.

- Implement the most robust animal welfare and traceability certification systems or audits e.g. Responsible

Wool Standard, or work with a reputable auditing body on a similar high-quality standard or audit system

to ensure sheep are not mulesed and overall animal husbandry is adequate.

Leather/skins - Whether it has been claimed to be ‘certified responsible’ or not, exclude the use of all leather and exotic

skins from snake, crocodile, lizard, ostrich, kangaroo and all other wild land and sea animals, regardless of

their endangered or threatened species listing under the Convention on International Trade in Endangered

Species (CITES) or the International Union for Conservation of Nature’s (IUCN) Red list.Exclude sales of

animal skins from animals solely raised and killed for leather.

- Exclude sales of leather from aborted (sporadic or induced) animals i.e. slink and karakul.

- Avoid the use of domesticated animal leather (including shearling) until robust animal welfare assurance

schemes become available.

- Seek and support alternative sustainable animal-free leather options.

- Oppose the following key welfare issues in the cattle industry including dehorning (polling), long distance

transport, confinement systems including crates and feed lots, and inhumane slaughter.

Alpaca - Avoid the use of alpaca wool until robust animal welfare assurance schemes are in place.

Cashmere & Mohair

- Animal welfare standards for cashmere and mohair are beginning to emerge, however FOUR PAWS is yet to

review these thoroughly, against the realities of the value chain. Due to the animal welfare risks involved,

for now, we recommend brands avoid the use of cashmere from cashmere goats, and mohair from angora

goats.

Hair, feathers, bones or teeth

from wild animals

- Ban use of any wild animal derived materials.

3 https://www.furfreealliance.com/wp-content/uploads/2020/01/CertifiedCruel_FFA-Research-Report.pdf 4 www.furfreeretailer.com

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5. What makes a robust assurance scheme?

FOUR PAWS strongly encourages the use of robust assurance schemes to help verify claims made in relation to animal welfare.

Companies should employ schemes which:

✓ Are set via a multi-stakeholder process, including representatives from two or more animal protection organisations.

✓ Ensure animal welfare states are evaluated primarily by animal-based parameters and results thereof must add a substantial share to the overall evaluation, if aggregation of single measures is performed.

✓ Include a set of animal welfare standards against which the systems level of ambition to achieve these is measured.

✓ Ensure 100% of all farms are checked on site by a third-party auditor prior to certification, with following on-site checks occurring at species/issue appropriate intervals.

✓ Where possible, require unannounced random audits alongside announced audits of supply

chains.

✓ Ensure separation between the entities writing certification standards, those who are doing the verification against that standard and those issuing the certificates.

✓ Avoid transparency loopholes; for example, it is best to actively exclude parallel farming systems (i.e. where one farm may be farming different groups of animals to different standards within the same property).

✓ Employ a robust chain of custody approach to ensure each batch of product remains traceable throughout the supply chain, and third-party assurance that each member of the supply chain complies and has the capacity to ensure traceability.

✓ Provide both companies and consumers with consistent marketing assets that can be applied to products, for ease of identification.

✓ Standards should be developed in line with the International Social and Environmental Accreditation and Labelling alliance (ISEAL) Principles of Sustainable Standard creation.

✓ Ideally have a third party audit the standard and its processes to ensure ongoing credibility. Additional considerations:

✓ FOUR PAWS acknowledges such schemes are best at providing a strong indication as to

welfare standards but cannot always provide 100% assurance.

✓ Recent research shows that best practice for supply chain assurance is for companies to use

a combination of both internal and external auditing services.5

5 Egels-Zandén, N., Lindholm, H 2014, ‘Do codes of conduct improve worker rights in supply chains? A study of Fair Wear Foundation’,

Journal of Cleaner Production, No. 107, pp. 31-40. DOI: https://doi.org/10.1016/j.jclepro.2014.08.096

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6. Policy Implementation and Monitoring Recommendations

To ensure animal welfare policies are effectively implemented, companies should also set up an implementation plan. High buy-in within the company can be best ensured when senior management gives its support to not only the policy, but also the implementation of it. A team should be assembled to execute the plan and include sustainability/CSR team members and departments involved in procurement and/or design. Together the team should be tasked to:

✓ Regularly review and continually implement the policy to reach animal welfare objectives.

✓ Ensure a clear understanding of the current animal welfare standards upheld within their

supply chains.

✓ Work with and support suppliers to identify animal welfare risks and determine whether

such risks can be appropriately mitigated or if the supplier or textile type should be avoided.

✓ Inform suppliers of the policy and clearly communicate requirements that are binding to

ensure adherence to it (e.g. reporting expectations, consequences of non-compliance, etc.).

✓ Continue to embrace and seek alternatives of non-animal origin.

✓ Set up and distribute a code of conduct with relation to the treatment of animals within

supply chains, and develop and promote a grievance mechanism (hotline, email inbox, etc.)

for reporting breaches of either the code of conduct or the companies’ animal welfare policy.

✓ If resources allow, join multi-stakeholder initiatives to keep up-to-date with industry

advances in animal welfare and help to drive industry solutions.

✓ Provide suppliers with training regarding animal derived materials sourcing, and standards and requirements of the company.

✓ Record animal welfare certificates in a proper order management system e.g. https://modint.nl/2018/07/03/due-diligence-database-supply-chain-oplossing/sim-modint-due-diligence-database/

✓ Continuously monitor supply chains and ensure annual reporting is done to measure and communicate progress.

7. Animal welfare policy examples in practice

Here are four examples of progressive animal welfare policies. There is always room for improvement; however, they may be helpful references to consider when developing a policy. H&M ASOS VF Corporation ESPRIT

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8. Contribution to UN Sustainable Development Goals

By developing a strong animal welfare policy, brands will build a more responsible profile, reduce business and reputational risk, and most importantly, help improve the lives of animals around the world. In doing this, brands can also leverage change across all animal industries, and will contribute to the following UN sustainability goals:

Thank you for collaborating with us on the journey towards better animal protection. For more information contact FOUR PAWS via textiles@four-paws.org