California Transparency in Supply Chains Act
Warby Parker is committed to making sure that working conditions throughout our supply chain are safe and that employees are treated with dignity. We require that our products comply with all applicable local and international laws, including laws related to labor, human rights, public health, and workplace safety.
Research by the International Labor Organization shows that there are nearly 21 million victims of forced labor around the world, and that women and children are particularly vulnerable to this type of abuse. This issue is not new, but recent legislation in California has given companies like ours an opportunity to explain how they address the risk of human rights violations in their supply chains. Our disclosure for the California Transparency in Supply Chains Act (SB657) outlines the steps we’re taking to make sure that all our direct suppliers (i.e., the manufacturers who take raw materials and turn them into Warby Parker products) meet internationally recognized labor standards and also adhere to our own Vendor Code of Conduct.
These steps include:
1. Verifying our supply chain to evaluate and address the risk of human trafficking and slavery
Our efforts to make sure that our supply chain is free of human trafficking and slavery begin with thoroughly mapping out our direct suppliers, and the secondary suppliers with whom they work. We then regularly work with independent organizations and other brands to assess the risk of forced labor throughout our supply chain (looking at various factors such as each supplier’s location and employee demographics) and tailor our efforts to prevent it accordingly.
Our primary safeguard against human trafficking is simple: We work only with manufacturing partners who share our commitment to ethical labor practices. Compliance with our Vendor Code of Conduct is a non-negotiable precondition to start and maintain any direct business relationship with us. The Code, which you can read below, outlines our requirements for the fair treatment and compensation of all workers, and expressly prohibits specific abusive labor practices. We work with the independent fair-labor monitoring group Verité to ensure that these standards are being met, and members of our own supply chain, social innovation, and design teams regularly visit our suppliers’ factories to supplement Verité’s work.
2. Auditing our direct suppliers on a regular basis
To ensure that our vendors uphold the requirements set out in our Code of Conduct, we partner with Verité to regularly audit our direct suppliers’ facilities. These scheduled audits are an opportunity for us to strengthen our relationship with vendors throughout our supply chain and work together on preventing any substandard work conditions. We audit all of our direct suppliers’ factories at least once a year, and each audit is conducted over two or more days, depending on the size of the facility. During an audit and any follow-up visits, Verité’s independent auditors meet with the management of each facility, tour every part of the site, review any pertinent documents, and interview employees at all levels of the organization. These audits give us a clear and comprehensive picture of employees’ working conditions and allow us to hold our direct suppliers accountable to the specific labor standards outlined in our Vendor Code of Conduct.
3. Certifying that the raw materials used by our suppliers have not been produced with forced labor
Our Vendor Code of Conduct applies to all of our direct suppliers. Of course, these suppliers have their own suppliers, who provide them with the various materials and components needed to manufacture our products. As an added safeguard against the threat of human trafficking and slavery, we audit many of those suppliers as well. This allows us to know whom those suppliers employ and to ensure that they’re also being employed per the labor standards set out in our Code of Conduct.
To maintain a complete picture of our supply chain and the labor involved in it, we have a zero-tolerance policy toward unapproved subcontractors, facilities, and homework, and we do not work with vendors who are not transparent and cooperative on the matter. Every one of our direct suppliers must be able to prove that its supply chain and all the materials incorporated into our products comply with national and international laws prohibiting slavery and human trafficking. And whenever there’s a difference between the requirements of local law, international law, and our Vendor Code of Conduct, the most stringent standard always applies.
4. Holding ourselves and our suppliers accountable
Our policy against forced labor is one of zero tolerance. If one of our suppliers were found to be complicit in any form of forced labor whatsoever, we would require the supplier to address and correct the problem immediately, and we would launch an extensive investigation into the issue.
We reserve the right to terminate our business relationship with any supplier who violates these terms—because ethics override economics.
5. Training and education
To further protect the integrity of our supply chain and the safety of the people working in it, we make a concerted effort to educate our vendors, auditors, and internal teams on the realities of human trafficking and modern-day slavery. We also regularly engage with industry organizations and other companies to stay abreast of the latest developments and regulations surrounding the issue. This makes everyone involved in our supply chain better able to identify and effectively address any potential infractions.
Our Vendor Code of Conduct
Below, in full, is the Code of Conduct that we require all of our direct suppliers to comply with. Every expectation outlined in it is intended to make sure that employees are treated fairly, provided a safe work environment, and legally compensated for their work.
Vendor Code of Conduct
Warby Parker has established the general principles below, which represent our minimum expectations and serve only as a starting point for our direct suppliers to evaluate their practices and working conditions, and those of any subcontractors. Failure to do so may result in Warby Parker’s suspension of all production and the termination of any business relationship.
Factories will not employ anyone under the age of 15, and/or younger than the age of completing compulsory education, or under the minimum age for employment established by applicable laws in the countries of manufacture, if higher than the age of 15. Furthermore, factories of any kind will not expose anyone under the age of 18 to a working environment that is hazardous, unsafe, or unhealthy, and will provide necessary and adequate health checks and personal protection to juvenile workers as per law.
Warby Parker will not conduct business with any factory that uses involuntary labor of any kind—including prison labor, indentured labor, bonded labor, or labor obtained through human trafficking or slavery. Upon commencing employment with a factory, employees shall not be required to lodge “deposits” in any forms, or personal identity documents unless it is required by law.
Warby Parker firmly believes people are entitled to equal opportunity in employment. Although the company recognizes cultural differences exist, Warby Parker will not pursue business relationships with factories who discriminate in employment, including hiring, salary, benefits, advancement, discipline, termination, or retirement on the basis of gender, race, religion, age, disability, sexual orientation, nationality, marital or maternity status, work or personal affiliations, political opinion, or social or ethnic origin.
Harassment and Abuse
Warby Parker expects our factories to treat every employee with respect and dignity. No employee will be subject to any physical, sexual, psychological, or verbal harassment or abuse. Factories will not use monetary fines as a disciplinary practice. Furthermore, workers must be free to voice their concerns to Warby Parker or Warby Parker-appointed staff without fear of retaliation by factory management.
Wages and Benefits
Factories shall set wages, overtime pay and legally mandated benefits and allowances in compliance with all applicable laws. Workers shall be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater.
While permitting flexibility in scheduling, we will identify local legal limits on work hours and seek factories that do not exceed them. Working time should not exceed 60 hours per week, including overtime, or legal limits set by applicable local law, whichever is lower except in emergency or unusual situations. Employees should be allowed at least one day off in every seven days.
In the event that dormitory housing and meals are provided as a part of the employment agreement, all housing and sanitation conditions must comply with the applicable laws and regulations. Each dormitory resident is to be provided a locker where he/she can store his/her personal belongings with necessary privacy. Dormitory quarters are to be segregated by gender. Sufficient toilet and washing facilities segregated by gender are to be provided.
Freedom of Association
Each factory must allow employees to associate with, form, and join employees' organizations of their choosing, bargain collectively and seek adequate representation.
Each factory must receive Warby Parker’s prior written approval in each instance for use of subcontractors and ensure that all of its subcontractors comply with this Code of Conduct. Subcontractors are subject to the same oversight, inspection, and auditing as factories. Each factory must keep an account of all records concerning any violations of this Code of Conduct by its subcontractors. No homework is allowed to be assigned to employees unless agreed upon by Warby Parker.
It is essential that each factory abide by all local laws in all aspects of their operations. In the event that there is a conflict between any local law and this Code of Conduct, the factory must abide by whichever rules are more protective for the employees and environment.
Each factory is required to develop a process to obtain continuous employee feedback concerning the implementation of this Code of Conduct in order to cooperatively develop and document best practices. This feedback system must include a fair, transparent, and anonymous method of reporting any observed violation of this code by any employees.
Health and Safety
Warby Parker seeks factories which provide written standards for safe and healthy work environments for their workers, including adequate facilities and protections from exposure to hazardous conditions or materials. These provisions must include safe and healthy conditions for dormitories and residential facilities, and they must comply with local health and safety laws and standards.
Factories must demonstrate a regard for the environment, as well as compliance with applicable environmental laws. Further, Warby Parker actively seeks factories that demonstrate a commitment to progressive environmental practices and to preserving the earth’s resources.
Warby Parker expects its factories to have programs, policies, and training in place to comply with its local and/or applicable international or United States anti-bribery regulations, including without limitation the Foreign Corruption Practices Act (FCPA), and to prevent payments made for the purpose of obtaining or retaining business.