On January 1, 2012, California enacted a new law requiring companies of a certain size to publicly disclose the steps they are taking to identify and eradicate forced labor in their supply chains. ANN INC.’s Global Supplier Principles & Guidelines and Social Compliance Program aligns with the intent of the legislation and we are pleased to share our continuous work towards sourcing products free of slavery and human trafficking.

At ANN INC., our client genuinely cares about the conditions under which Ann Taylor, LOFT and Lou & Grey products are manufactured. It is important to us and to her that materials used in our products are obtained through ethical labor conditions. ANN INC.’s Global Supplier Principles & Guidelines provide suppliers with our expectations for responsible manufacturing standards. We only align ourselves with suppliers who share this commitment. Our Guidelines clearly state that our Suppliers must not use involuntary or forced labor, whether indentured, bonded, prison or labor obtained through slavery and human trafficking.

We are taking the following actions to address human trafficking and slavery in our direct product supply chain:

1.  VERIFICATION OF PRODUCT SUPPLY CHAINS: ANN INC. has a robust on-going internal risk assessment program conducted by our CSR department. Our team reviews the U.S. Department of State’s annual report on Trafficking in Persons as well as the recommendations put forward by the Department of Labor’s List of Goods Produced by Child Labor and Forced Labor. When considering new sourcing countries, we follow a strict approval process involving multiple departments and based on various criteria, including social compliance risks. Additionally, all new factories must be reviewed by the CSR department for social compliance before production may begin. ANN INC. is proud to be a buyer partner of the Better Work Program, a collaborative factory monitoring initiative led by the International Labour Organization (ILO). We utilize audits conducted by the Better Work inspectors to assess factory compliance in key manufacturing countries where the program is active.

2.  INDEPENDENT, UNANNOUNCED AUDITING: We regularly conduct independent, unannounced audits using third party service providers against ANN INC.’s code of conduct for responsible sourcing, known as the Global Supplier Principles and Guidelines. We survey our suppliers to assess their use of migrant and foreign contract workers and our service providers follow procedures to identify non-compliance issues found specifically with these classes of workers, such as hiring process issues and access to grievance systems. An important aspect of the auditing process is worker interviews, conducted both on-site and off-site. When non-compliance is identified, we require suppliers to respond to each issue with a root cause analysis and timeline for remediation. In addition, we apply our rating system, AT Scale, which impacts business volumes, and provides guidance to Sourcing, assisting them in placing business with suppliers that achieve favorable compliance scores, and reducing business for poor performers. We have and will terminate factories with significant issues when there is insufficient evidence of improvement.

3.  SUPPLIER CERTIFICATION: Suppliers annually recertify their commitment to ANN INC.’s Global Supplier Principles & Guidelines thereby attesting that products are free from slavery and human trafficking. ANN INC.’s suppliers provide assurances that they are in compliance with legislation pertaining to slavery and human trafficking in the countries where they operate.

4.  MAINTENANCE OF INTERNAL ACCOUNTABILITY STANDARDS AND PROCEDURES: ANN INC. maintains strong internal accountability procedures for our associates. Our Code of Conduct establishes what actions ANN INC. takes in case our associates or contractors fail to meet company standards. In addition, our agreements with Buying Agents include requirements to follow ANN INC. compliance standards. ANN INC. provides the Compliance & Ethics Hotline to anyone (including associates, vendors, suppliers, consultants, advisors and service providers) who wish to report a complaint or concern regarding potential violations of ANN INC.’s practices. In cases of non-compliance, we have strict policies in place, including termination.

5.  STAFF TRAINING ON IDENTIFYING AND PREVENTING SLAVERY AND HUMAN TRAFFICKING: ANN INC. provides regular training on compliance matters, including E-learning, on slavery, human trafficking, and related risk mitigation to our associates who have direct responsibility for supply chain management, including our CSR team, our Global Sourcing team, merchandisers, and our Buying Agents. We have strong alignment internally, communicating compliance updates through regular meetings and reporting.