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BRAND PERFORMANCE CHECK Stanley and Stella S.A. PUBLICATION DATE: JUNE 2017 PUBLICATION DATE: JUNE 2017 this report covers the evaluation period 01-01-2016 to 31-12-2016

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BRAND PERFORMANCE CHECK

Stanley and Stella S.A.PUBLICATION DATE: JUNE 2017PUBLICATION DATE: JUNE 2017

this report covers the evaluation period 01-01-2016 to 31-12-2016

ABOUT THE BRAND PERFORMANCE CHECK

Fair Wear Foundation believes that improving conditions for apparel product location workers requires changeat many levels. Traditional efforts to improve conditions focus primarily on the product location. FWF,however, believes that the management decisions of clothing brands have an enormous influence for good orill on product location conditions.

FWF’s Brand Performance Check is a tool to evaluate and report on the activities of FWF’s member companies.The Checks examine how member company management systems support FWF’s Code of Labour Practices.They evaluate the parts of member company supply chains where clothing is assembled. This is the mostlabour intensive part of garment supply chains, and where brands can have the most influence over workingconditions.

In most apparel supply chains, clothing brands do not own product locations, and most product locationswork for many different brands. This means that in most cases FWF member companies have influence, butnot direct control, over working conditions. As a result, the Brand Performance Checks focus primarily onverifying the efforts of member companies. Outcomes at the product location level are assessed via auditsand complaint reports, however the complexity of the supply chains means that even the best efforts of FWFmember companies cannot guarantee results.

Even if outcomes at the product location level cannot be guaranteed, the importance of good managementpractices by member companies cannot be understated. Even one concerned customer at a product locationcan have significant positive impacts on a range of issues like health and safety conditions or freedom ofassociation. And if one customer at a product location can demonstrate that improvements are possible, othercustomers no longer have an excuse not to act. The development and sharing of these types of best practiceshas long been a core part of FWF’s work.

The Brand Performance Check system is designed to accommodate the range of structures and strengths thatdifferent companies have, and reflects the different ways that brands can support better working conditions.

This report is based on interviews with member company employees who play important roles in themanagement of supply chains, and a variety of documentation sources, financial records, supplier data. Thefindings from the Brand Performance Check are summarized and published at www.fairwear.org. The onlineBrand Performance Check Guide provides more information about the indicators.

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 2/32

BRAND PERFORMANCE CHECK OVERVIEW

Stanley and Stella S.A.Evaluation Period: 01-01-2016 to 31-12-2016

MEMBER COMPANY INFORMATION

Headquarters: Brussels, Belgium

Member since: 15-12-2011

Product types: Fashion, Workwear, Promotional, Corporate wear

Production in countries where FWF is active: Bangladesh, China

Production in other countries: Portugal

BASIC REQUIREMENTS

Workplan and projected production location data for upcoming year have beensubmitted?

Yes

Actual production location data for evaluation period was submitted? Yes

Membership fee has been paid? Yes

SCORING OVERVIEW

% of own production under monitoring 100%

Benchmarking score 81

Category Leader

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 3/32

Summary:Stanley & Stella S.A. (hereafter Stanley & Stella) meets FWF's requirements regarding the implementation of FWF's Code of Labour Practices and goesbeyond. Stanley & Stella has monitored 100% of its production in the last three years. The brand purchases over 90% of its production volume from supplierswhere it has significant leverage. Stanley & Stella has a stable supplier base and tries to establish long term business relationships with current suppliers.

Over 90% of Stanley & Stella' products are made in Bangladesh. The local office visits the factories frequently to prevent unauthorised subcontracting andfollow up on corrective action plans from FWF audit reports. Stanley & Stella meets FWF's requirements on establishing an enhanced monitoring system. Thelocal Bangladesh office urges and supports the factories to improve fire and building safety based on inspection reports of the Bangladesh Fire and BuildingSafety Accord. All factories supplying Stanley & Stella have participated in FWF's factory management training on safety. Two factories have set up functional anti-harassment committees. Committee members negotiate with factory management to handle workplace grievances using internal process.

In the next financial year, Stanley & Stella is recommended to take a step further to work towards payment of living wages and addressing excessiveovertime at the suppliers, especially where it has high leverage and stable working relationship. Stanley & Stella is encouraged to gain more insights oflabour cost per product in order to take steps forward in paying living wages.

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 4/32

PERFORMANCE CATEGORY OVERVIEW

Leader: This category is for member companies who are doing exceptionally well, and are operating at anadvanced level. Leaders show best practices in complex areas such as living wages and freedom ofassociation.

Good: It is FWF’s belief that member companies who are making a serious effort to implement the Code ofLabour Practices—the vast majority of FWF member companies—are ‘doing good’ and deserve to be recognizedas such. They are also doing more than the average clothing company, and have allowed their internalprocesses to be examined and publicly reported on by an independent NGO. The majority of membercompanies will receive a ‘Good’ rating.

Needs Improvement: Member companies are most likely to find themselves in this category when majorunexpected problems have arisen, or if they are unable or unwilling to seriously work towards CoLPimplementation. Member companies may be in this category for one year only after which they should eithermove up to Good, or will be moved to suspended.

Suspended: Member companies who either fail to meet one of the Basic Requirements, have had major internalchanges which means membership must be put on hold for a maximum of one year, or have been in NeedsImprovement for more than one year. Member companies may remain in this category for one year maximum,after which termination proceedings will come into force.

Categories are calculated based on a combination of benchmarking score and the percentage of ownproduction under monitoring. The specific requirements for each category are outlined in the BrandPerformance Check Guide.

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 5/32

1. PURCHASING PRACTICES

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.1a Percentage of production volume fromproduction locations where member companybuys at least 10% of production capacity.

90% Member companies with less than 10% of aproduction location’s production capacitygenerally have limited influence onproduction location managers to makechanges.

Supplier informationprovided by membercompany.

4 4 0

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.1b Percentage of production volume fromproduction locations where member companybuys less than 2% of its total FOB.

2% FWF provides incentives to clothing brands toconsolidate their supplier base, especially atthe tail end, as much as possible, andrewards those members who have a small tailend. Shortening the tail end reduces socialcompliance risks and enhances the impact ofefficient use of capital and remediationefforts.

Production locationinformation asprovided to FWF.

3 4 0

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.2 Percentage of production volume fromproduction locations where a businessrelationship has existed for at least five years.

27% Stable business relationships support mostaspects of the Code of Labour Practices, andgive production locations a reason to invest inimproving working conditions.

Supplier informationprovided by membercompany.

2 4 0

Recommendation: Stanley & Stella is recommended to continue its business relation with existing suppliers tobuild long term relationships.

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 6/32

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.3 All new production locations are requiredto sign and return the questionnaire with theCode of Labour Practices before first bulkorders are placed.

No newproductionlocationsadded in pastfinancial year

The CoLP is the foundation of all workbetween production locations and brands,and the first step in developing acommitment to improvements.

Signed CoLPs are onfile.

N/A 2 0

Comment: Stanley & Stella prefers to work with existing suppliers. It did not have any new productionlocations in 2016.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.4 Member company conducts human rightsdue diligence at all new production locationsbefore placing orders.

No newproductionlocationsadded in pastfinancial year

Due diligence helps to identify, prevent andmitigate potential human rights problems atnew suppliers.

Documentation mayinclude pre-audits,existing audits, othertypes of riskassessments.

N/A 4 0

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.5 Production location compliance with Codeof Labour Practices is evaluated in asystematic manner.

Yes, andleads toproductiondecisions

A systemic approach is required to integratesocial compliance into normal businessprocesses, and supports gooddecisionmaking.

Documentation ofsystemic approach:rating systems,checklists, databases,etc.

2 2 0

Comment: Stanley & Stella holds quality control meetings monthly to discuss performance of suppliers.Sustainability is a crucial part of the discussion, especially on health and safety and harassment in theworkplace. In addition to FWF audits, Stanley & Stella also collects data on wages and working hours to trackperformance of suppliers.

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 7/32

Factories' willingness to collaborate and continuous improvements are criteria for being suppliers of Stanley &Stella. In 2016, Stanley & Stella has phased out a supplier because of their reluctance to discuss onremediation after audits. Stanley & Stella had lower leverage at the supplier. The supplier did not want to joinWEP and refused to be transparent to FWF audit team. After two years of negotiation, Stanley & Stelladecided to leave the supplier.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.6 The member company’s productionplanning systems support reasonable workinghours.

Strong,integratedsystems inplace.

Member company production planningsystems can have a significant impact on thelevels of excessive overtime at productionlocations.

Documentation ofrobust planningsystems.

4 4 0

Comment: Stanley & Stella makes production plannings together with suppliers. Regular forecasting isannounced six month in advance. The production forecasting is updated every month. If suppliers do not agreewith the deadline of an order, they can negotiate with Stanley & Stella.

Most orders produced by Stanley & Stella are for stock purposes. Therefore, Stanley & Stella does allow acertain degree of delay. Local office of Stanley & Stella visits the suppliers weekly and makes sure productionprocess status is updated and shared with the headquarter.

Stanley & Stella is aware that material delays are usually the cause of production delays, which might resultin excessive overtime at factories. When encountering significant yarn delay, Stanley & Stella has a policy touse airfreight on its own costs to help suppliers meeting the deadline.

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 8/32

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.7 Degree to which member companymitigates root causes of excessive overtime.

Intermediateefforts

Some production delays are outside of thecontrol of member companies; however thereare a number of steps that can be taken toaddress production delays without resortingto excessive overtime.

Evidence of howmember responds toexcessive overtimeand strategies thathelp reduce the riskof excessive overtime,such as: root causeanalysis, reports,correspondence withfactories, etc.

3 6 0

Comment: Stanley & Stella acknowledge that long working hours is a common compliance issue in thegarment supply chain. Thus the company prefers to work with FWF audit team to make sure excessiveovertime is found. FWF has audited three factories supplying Stanley & Stella. Overtime work at auditedfactories are about average comparing to other factories in the countries - 70-85 total working hours per weekin Bangladesh; 60-65 hours per week in China. FWF audits have observed a slight reduction (5-10%) inovertime hours at one factory in Bangladesh. At all three audited factories, the management commented thatStanley & Stella did not cause overtime.

Stanley & Stella is of the opinion that the most common cause of excessive overtime is capacity overbook atthe factories. Better planning at factory level could help reducing overtime. In order to support suppliers,Stanley & Stella uses the following strategies:

- Plan production and lead time in advance together with suppliers; - Frequent communication with suppliers and help them on factory production planning, especially when thereis energy shortage in the country. - Allow some delay in production and do not penalise suppliers for delays.

Recommendation: Stanley & Stella is recommended to conduct overtime root causes analysis at brand leveland at factory level to find out more. When assessing capacity of factories, the brand should make sure thecapacity is based on regular working hours. Only when overtime root causes are addressed, it is possible toreduce overtime at the factories.

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 9/32

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.8 Member company’s pricing policy allowsfor payment of at least the legal minimumwages in production countries.

Country-levelpolicy

The first step towards ensuring the paymentof minimum wages - and towardsimplementation of living wages - is to knowthe labour costs of garments.

Formal systems tocalculate labourcosts on per-productor country/city level.

2 4 0

Comment: Stanley & Stella does not use labour minute cost to calculate price of orders. Suppliers usuallyoffer a lump-sum price for Stanley & Stella to consider. Stanley & Stella knows minimum wages in the areaswhere they produce. Stanley & Stella also collect and compare wage data at suppliers to find out the exacttotal payment of workers.

Recommendation: When Stanley&Stella is able to investigate further and determine more precisely the labourminute costs for its products, it should have a better understanding whether its FOB prices support payment ofat least minimum wages, and moving towards living wages.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.9 Member company actively responds ifsuppliers fail to pay legal minimum wages.

No minimumwageproblemsreported

If a supplier fails to pay minimum wage, FWFmember companies are expected to holdmanagement of the supplier accountable forrespecting local labour law.

Complaint reports,CAPs, additionalemails, FWF auditreports or otherdocuments that showminimum wage issueis reported/resolved.

2 2 -2

Comment: All three suppliers audited by FWF in 2016 pay at least minimum wages to workers.

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 10/32

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.10 Evidence of late payments to suppliers bymember company.

No Late payments to suppliers can have anegative impact on production locations andtheir ability to pay workers on time. Mostgarment workers have minimal savings, andeven a brief delay in payments can causeserious problems.

Based on a complaintor audit report; reviewof production locationand membercompany financialdocuments.

0 0 -1

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.11 Degree to which member companyassesses root causes of wages lower thanliving wages with suppliers and takes stepstowards the implementation of living wages.

Productionlocation levelapproach

Sustained progress towards living wagesrequires adjustments to member companies’policies.

Documentation ofpolicy assessmentsand/or concreteprogress towardsliving wages.

4 8 0

Comment: Stanley & Stella discuss with factories on wages using wage ladders in audit reports. On its owninitiative, Stanley & Stella also conducts research at suppliers to find out more about payments of wages.Stanley & Stella is in the process of analysing root causes of wages lower than living wages.

Recommendation: Fair Wear Foundation encourages Stanley&Stella to discuss with suppliers aboutpossibilities to work towards higher benchmarks of living wages. Stanley & Stella could consider to join FWF'sliving wage challenge project to advance towards paying living wage.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

1.12 Percentage of production volume fromfactories owned by the member company(bonus indicator).

None Owning a supplier increases theaccountability and reduces the risk ofunexpected CoLP violations. Given theseadvantages, this is a bonus indicator. Extrapoints are possible, but the indicator will notnegatively affect an member company'sscore.

Supplier informationprovided by membercompany.

N/A 2 0

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 11/32

PURCHASING PRACTICES

Possible Points: 38Earned Points: 26

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 12/32

2. MONITORING AND REMEDIATION

BASIC MEASUREMENTS RESULT COMMENTS

% of own production under standardmonitoring (excluding low-risk countries)

99%

% of production volume where monitoringrequirements for low-risk countries arefulfilled

0% FWF low risk policy should be implemented. 0 = policy is not implemented correctly. N/A = noproduction in low risk countries.

Meets monitoring requirements for tail-endproduction locations.

Yes

Total of own production under monitoring 100% Minimums: 1 year: 40%; 2 years 60%; 3 years+: 80-100% Measured as a percentage of turnover.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.1 Specific staff person is designated tofollow up on problems identified bymonitoring system

Yes Followup is a serious part of FWFmembership, and cannot be successfullymanaged on an ad-hoc basis.

Manuals, emails, etc.,demonstrating whothe designated staffperson is.

2 2 -2

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.2 Quality of own auditing system meetsFWF standards.

Membermakes use ofFWF auditsand/orexternalaudits only

In case FWF teams cannot be used, themember companies’ own auditing systemmust ensure sufficient quality in order forFWF to approve the auditing system.

Information on auditmethodology.

N/A 0 -1

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 13/32

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.3 Audit Report and Corrective Action Plan(CAP) findings are shared with factory andworker representation where applicable.Improvement timelines are established in atimely manner.

Yes 2 part indicator: FWF audit reports wereshared and discussed with suppliers withintwo months of audit receipt AND a reasonabletime frame was specified for resolvingfindings.

Corrective ActionPlans, emails;findings of followupaudits; brandrepresentative presentduring audit exitmeeting, etc.

2 2 -1

Comment: Audit reports are shared with factory management timely. Audit reports are not yet shared withworker representatives.

Recommendation: FWF suggests Stanley & Stella to share audit reports with worker representatives whereapplicable.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.4 Degree of progress towards resolution ofexisting Corrective Action Plans andremediation of identified problems.

Intermediate FWF considers efforts to resolve CAPs to beone of the most important things thatmember companies can do towardsimproving working conditions.

CAP-relateddocumentationincluding status offindings,documentation ofremediation andfollow up actionstaken by member.Reports of qualityassessments.Evidence ofunderstandingrelevant issues.

6 8 -2

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 14/32

Comment: Stanley & Stella uses exclusively FWF audit teams to conduct audits at their suppliers. Thecompany has a local office in Bangladesh which is responsible to follow up on the corrective action plans(CAPs). Besides asking factory management to voluntarily report remediation process, Stanley & Stella localoffice also checks and confirms the status. Issues on overtime and wages are more difficult to solve. Stanley& Stella maintains a dialogue with factory management in order to make improvement gradually. FWFcountry representative is frequently consulted to support the remediation process.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.5 Percentage of production volume fromproduction locations that have been visited bythe member company in the previous financialyear.

100% Formal audits should be augmented byannual visits by member company staff orlocal representatives. They reinforce toproduction location managers that membercompanies are serious about implementingthe Code of Labour Practices.

Member companiesshould document allproduction locationvisits with at leastthe date and name ofthe visitor.

4 4 0

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.6 Existing audit reports from other sourcesare collected.

No existingreports/allaudits byFWF or FWFmembercompany

Existing reports form a basis forunderstanding the issues and strengths of asupplier, and reduces duplicative work.

Audit reports are onfile; evidence offollowup on priorCAPs. Reports ofquality assessments.

N/A 3 0

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 15/32

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.7 Compliance with FWF risk policies. Advancedresult on allrelevantpolicies

Aside from regular monitoring andremediation requirements under FWFmembership, countries, specific areas withincountries or specific product groups may posespecific risks that require additional steps toaddress and remediate those risks. FWFrequires member companies to be aware ofthose risks and implement policyrequirements as prescribed by FWF.

Policy documents,inspection reports,evidence ofcooperation withother customerssourcing at the samefactories, reports ofmeetings withsuppliers, reports ofadditional activitiesand/or attendancelists as mentioned inpolicy documents.

6 6 -2

Compliance with FWF enhanced monitoringprogramme Bangladesh

Advanced 6 6 -2

Compliance with FWF Myanmar policy Policies arenot relevantto thecompany'ssupply chain

N/A 6 -2

Compliance with FWF guidance on abrasiveblasting

Policies arenot relevantto thecompany'ssupply chain

N/A 6 -2

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 16/32

Comment: A large proportion of Stanley & Stella's products are made in Bangladesh. The local office inBangladesh visits the production sites frequently to prevent subcontracting. Stanley & Stella uses FWF auditteam to identify issues regarding working conditions and possible subcontractors. Although not a signatory ofthe Bangladesh Accord on Fire and Building Safety, all Stanley & Stella's suppliers are audited by the Accordand have been in the process of remediation. Stanley & Stella has collected safety inspection reports anddiscussed with suppliers on follow-up actions. All Stanley & Stella suppliers have joined the managementworkshop organised by FWF on raising awareness on fire and building safety. Three of Stanley & Stella'ssuppliers have set up anti-harassment systems with the help of the member company and FWF local trainingteam. The anti-harassment committees at two of the suppliers have been functional.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.8 Member company cooperates with otherFWF member companies in resolvingcorrective actions at shared suppliers.

No CAPsactive, nosharedproductionlocations orrefusal ofothercompany tocooperate

Cooperation between customers increasesleverage and chances of successfuloutcomes. Cooperation also reduces thechances of a factory having to conductmultiple Corrective Action Plans about thesame issue with multiple customers.

Shared CAPs,evidence ofcooperation withother customers.

N/A 2 -1

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.9 Percentage of production volume wheremonitoring requirements for low-risk countriesare fulfilled.

50-100% Low-risk countries are determined by thepresence and proper functioning ofinstitutions which can guarantee compliancewith national and international standards andlaws.

Documentation ofvisits, notification ofsuppliers of FWFmembership; postingof worker informationsheets, completedquestionnaires.

1 2 0

Comment: Less than one percent of Stanley & Stella's production volume is made in Portugal. FWF couldverify that basic requirements to monitor production locations in low risk countries are met.

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 17/32

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.10 Extra bonus indicator: in case FWFmember company conducts full audits abovethe minimum required monitoring threshold.

90%+ FWF encourages all of its members toaudit/monitor 100% of its productionlocations and rewards those members whoconduct full audits above the minimumrequired monitoring threshold.

Production locationinformation asprovided to FWF andrecent Audit Reports.

3 3 0

Comment: All production locations have been audited according to FWF's requirements.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.11 Questionnaire is sent and information iscollected from external brands resold by themember company.

No externalbrands resold

FWF believes it is important for affiliates thathave a retail/wholesale arm to at least knowif the brands they resell are members of FWFor a similar organisation, and in whichcountries those brands produce goods.

Questionnaires are onfile.

N/A 2 0

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.12 External brands resold by membercompanies that are members of anothercredible initiative (% of external salesvolume).

No externalbrands resold

FWF believes members who resell productsshould be rewarded for choosing to sellexternal brands who also take their supplychain responsibilities seriously and are openabout in which countries they produce goods.

External productiondata in FWF'sinformationmanagement system.Documentation ofsales volumes ofproducts made byFWF or FLA members.

N/A 3 0

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 18/32

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

2.13 Questionnaire is sent and information iscollected from licensees.

No licensees FWF believes it is important for membercompanies to know if the licensee iscommitted to the implementation of thesame labour standards and has a monitoringsystem in place.

Questionnaires are onfile. Contracts withlicensees.

N/A 1 0

MONITORING AND REMEDIATION

Possible Points: 27Earned Points: 24

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 19/32

3. COMPLAINTS HANDLING

BASIC MEASUREMENTS RESULT COMMENTS

Number of worker complaints received sincelast check

0 At this point, FWF considers a high number of complaints as a positive indicator, as it showsthat workers are aware of and making use of the complaints system.

Number of worker complaints in process ofbeing resolved

Number of worker complaints resolved sincelast check

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

3.1 A specific employee has been designatedto address worker complaints

Yes Followup is a serious part of FWFmembership, and cannot be successfullymanaged on an ad-hoc basis.

Manuals, emails, etc.,demonstrating whothe designated staffperson is.

1 1 -1

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

3.2 System is in place to check that theWorker Information Sheet is posted infactories.

Yes The Worker Information Sheet is a key firststep in alerting workers to their rights.

Photos by companystaff, audit reports,checklists fromproduction locationvisits, etc.

2 2 0

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 20/32

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

3.3 Percentage of FWF-audited productionlocations where at least half of workers areaware of the FWF worker helpline.

33% The FWF complaints procedure is a crucialelement of verification. If production locationbased complaint systems do not exist or donot work, the FWF worker helpline allowsworkers to ask questions about their rightsand file complaints. Production locationparticipation in the Workplace EducationProgramme also count towards this indicator.

Percentage ofaudited productionlocations where atleast 50% ofinterviewed workersindicate awareness ofthe FWF complaintsmechanism +percentage ofproduction locationsin WEP programme.

2 4 0

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

3.4 All complaints received from productionlocation workers are addressed in accordancewith the FWF Complaints Procedure

Nocomplaintsreceived

Providing access to remedy when problemsarise is a key element of responsible supplychain management. Member companyinvolvement is often essential to resolvingissues.

Documentation thatmember companyhas completed allrequired steps in thecomplaints handlingprocess.

N/A 6 -2

Comment: Three factories producing for Stanley & Stella have set up anti-harassment systems. The anti-harassment committees have received complaints and solved them using the factory's internal procedure,with the help of the member company and FWF local team. Therefore, no complaints have been handled byFWF complaints helpline directly.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

3.5 Cooperation with other customers inaddressing worker complaints at sharedsuppliers

Nocomplaints orcooperationnot possible /necessary

Because most production locations supplyseveral customers with products, involvementof other customers by the FWF membercompany can be critical in resolving acomplaint at a supplier.

Documentation ofjoint efforts, e.g.emails, sharing ofcomplaint data, etc.

N/A 2 0

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 21/32

COMPLAINTS HANDLING

Possible Points: 7Earned Points: 5

BRAND PERFORMANCE CHECK - STANLEY AND STELLA S.A. - 01-01-2016 TO 31-12-2016 22/32

4. TRAINING AND CAPACITY BUILDING

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

4.1 All staff at member company are madeaware of FWF membership.

Yes Preventing and remediating problems oftenrequires the involvement of many differentdepartments; making all staff aware of FWFmembership requirements helps to supportcross-departmental collaboration whenneeded.

Emails, trainings,presentation,newsletters, etc.

1 1 -1

Comment: Training on FWF's requirements is part of the induction process of new employees. Stanley & Stellaalso organises regular discussion sessions to raise awareness in the company about FWF membership.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

4.2 All staff in direct contact with suppliersare informed of FWF requirements.

Yes Sourcing, purchasing and CSR staff at aminimum should possess the knowledgenecessary to implement FWF requirementsand advocate for change within theirorganisations.

FWF Seminars orequivalent trainingsprovided;presentations,curricula, etc.

2 2 -1

Comment: Production staff in Bangladesh office are in direct contact with suppliers. The staff are required toknow about FWF membership, discuss CAP implementation and collect information on remediation process atthe suppliers.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

4.3 All sourcing contractors/agents areinformed about FWF’s Code of LabourPractices.

Member does notuseagents/contractors

Agents have the potential to eithersupport or disrupt CoLP implementation.It is the responsibility of membercompany to ensure agents activelysupport the implementation of the CoLP.

Correspondence withagents, trainings foragents, FWF auditfindings.

N/A 2 0

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PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

4.4 Production location participation inWorkplace Education Programme (where WEPis offered; by production volume)

50% Lack of knowledge and skills on bestpractices related to labour standards isacommon issue in production locations. Goodquality training of workers and managers is akey step towards sustainable improvements.

Documentation ofrelevant trainings;participation inWorkplace EducationProgramme.

6 6 0

Comment: Main suppliers of Stanley & Stella in Bangladesh have participated in the Workplace EducationProgramme to set up anti-harassment systems at the factories.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

4.5 Production location participation intrainings (where WEP is not offered; byproduction volume)

Allproduction isin WEP areas.

In areas where the Workplace EducationProgramme is not yet offered, membercompanies may arrange trainings on theirown or work with other training-partners.Trainings must meet FWF quality standardsto receive credit for this indicator.

Curricula, otherdocumentation oftraining content,participation andoutcomes.

N/A 4 0

TRAINING AND CAPACITY BUILDING

Possible Points: 9Earned Points: 9

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5. INFORMATION MANAGEMENT

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

5.1 Level of effort to identify all productionlocations

Advanced Any improvements to supply chains requiremember companies to first know all of theirproduction locations.

Supplier informationprovided by membercompany. Financialrecords of previousfinancial year.Documented effortsby member companyto update supplierinformation from itsmonitoring activities.

6 6 -2

Comment: Stanley & Stella is taking the following actions to identify all production locations:

- Using FWF audits exclusively. FWF audit includes identifying subcontractors; - Working with vertically integrated factories to have more knowledge on the location of various productionprocesses; - Checking if all machines needed for production are in place before production; - Visiting factories daily when production is being carried out.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

5.2 CSR and other relevant staff actively shareinformation with each other about workingconditions at production locations.

Yes CSR, purchasing and other staff who interactwith suppliers need to be able to shareinformation in order to establish a coherentand effective strategy for improvements.

Internal informationsystem; status CAPs,reports of meetingsof purchasing/CSR;systematic way ofstoring information.

1 1 -1

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INFORMATION MANAGEMENT

Possible Points: 7Earned Points: 7

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6. TRANSPARENCY

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

6.1 Degree of member company compliancewith FWF Communications Policy.

Minimumcommunicationsrequirementsare met AND nosignificantproblems found

FWF’s communications policy exists toensure transparency for consumers andstakeholders, and to ensure that membercommunications about FWF are accurate.Members will be held accountable for theirown communications as well as thecommunications behaviour of 3rd-partyretailers, resellers and customers.

FWF membership iscommunicated onmember’s website;othercommunications inline with FWFcommunicationspolicy.

2 2 -3

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

6.2 Member company engages in advancedreporting activities

PublishedPerformanceChecks,Audits, andother effortslead toincreasedtransparency

Good reporting by members helps to ensurethe transparency of FWF’s work and sharesbest practices with the industry.

Member companypublishes one or moreof the following ontheir website: BrandPerformance Check,Audit Reports,Supplier List.

1 2 0

Comment: Brand performance checks are published on the website. Audit reports are shared with customers.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

6.3 Social Report is submitted to FWF and ispublished on member company’s website

Completeand accuratereportpublished onmember’swebsite

The social report is an important tool formembers to transparently share their effortswith stakeholders. Member companies shouldnot make any claims in their social reportthat do not correspond with FWF’scommunication policy.

Social report that is inline with FWF’scommunicationpolicy.

2 2 -1

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TRANSPARENCY

Possible Points: 6Earned Points: 5

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7. EVALUATION

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

7.1 Systemic annual evaluation of FWFmembership is conducted with involvement oftop management

Yes An annual evaluation involving topmanagement ensures that FWF policies areintegrated into the structure of the company.

Meeting minutes,verbal reporting,Powerpoints, etc.

2 2 0

Comment: The CEO and founder of Stanley & Stella leads regular evaluation on sustainability including thediscussion on FWF membership.

PERFORMANCE INDICATORS RESULT RELEVANCE OF INDICATOR DOCUMENTATION SCORE MAX MIN

7.2 Level of action/progress made on requiredchanges from previous Brand PerformanceCheck implemented by member company.

Norequirementswereincluded inpreviousCheck

In each Brand Performance Check report, FWFmay include requirements for changes tomanagement practices. Progress on achievingthese requirements is an important part ofFWF membership and its process approach.

Member companyshould showdocumentationrelated to the specificrequirements made inthe previous BrandPerformance Check.

N/A 4 -2

EVALUATION

Possible Points: 2Earned Points: 2

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RECOMMENDATIONS TO FWF

1. Stanley & Stella would like FWF to communicate more and increase its influence in the market. 2. It is important to encourage more brands, organisations and the society to be involved in eliminatingviolence and harassment at the workplace. FWF should communicate more on its work. 3. Stanley & Stella is glad that FWF is practical but critical. It is crucial that FWF stays critical to the work ofthe brands. This will support Stanley & Stella in making improvement. 4. It would be helpful if FWF could visit customers of Stanley & Stella to explain and promote FWF's work.

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SCORING OVERVIEW

CATEGORY EARNED POSSIBLE

Purchasing Practices 26 38

Monitoring and Remediation 24 27

Complaints Handling 5 7

Training and Capacity Building 9 9

Information Management 7 7

Transparency 5 6

Evaluation 2 2

Totals: 78 96

BENCHMARKING SCORE (EARNED POINTS DIVIDED BY POSSIBLE POINTS)

81

PERFORMANCE BENCHMARKING CATEGORY

Leader

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BRAND PERFORMANCE CHECK DETAILS

Date of Brand Performance Check:

02-05-2017

Conducted by:

Juliette Li

Interviews with:

Bruno van Sieleghem, Marketing Manager Geert de Wael, Sourcing, Sustainability & Quality Manager Jean Chabert, Managing Director Md. Aminur Rahman Shishir, Logistics & Sustainable Officer

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