The Rise of Human Rights Due Diligence (Part III): A Deep Dive into Adidas’ Practices - By Shamistha Selvaratnam

Editor’s note: Shamistha Selvaratnam is a LLM Candidate of the Advanced Masters of European and International Human Rights Law at Leiden University in the Netherlands. Prior to commencing the LLM, she worked as a business and human rights solicitor in Australia where she specialised in promoting business respect for human rights through engagement with policy, law and practice.

 

The tragic collapse of Rana Plaza in Bangladesh in 2013, which killed over one thousand workers and injured more than two thousand, brought global attention to the potential human rights risks and impacts that are inherent to the garment and footwear sector.[1] This sector employs millions of workers within its supply chain in order to enable large-scale production of goods as quickly as possible at the lowest cost as market trends and consumer preferences change.[2] These workers are often present in countries where the respect for human rights and labour rights is weak. This creates an environment that is conducive to human rights abuses. Key risks in this sector include child labour, sexual harassment and gender-based violence, forced labour, non-compliance with minimum wage laws and excessive work hours.[3] Accordingly, brands such as Adidas face the challenge of conducting effective human rights due diligence (HRDD), particularly in their supply chains. 

This third blog of a series of articles dedicated to HRDD is a case study looking at how HRDD has materialised in practice within Adidas’ supply chains. It will be followed by another case study examining the steps taken by Unilever in order to operationalise the concept of HRDD. To wrap up the series, a final piece will reflect on the effectiveness of the turn to HRDD to strengthen respect of human rights by businesses.

 

Company Background

Adidas Group (Adidas) is an apparel, footwear and sporting goods company that is headquartered in Germany. As a business it designs, markets and sells consumer goods globally. Adidas has more than 2,300 retail stores, 14,000 franchise stores and 150,000 wholesale distributors, as well as an online store.[4] It employs more than 57,000 people and produces over 900 million products globally.[5]

Given that it outsources most of its production, it has a complex and large scale supply chain, with approximately 700 independent factories that manufacture products in over 50 countries.[6]  Its supplier factories by region as at 2016 are depicted in the image below. Its top sourcing countries are China, Vietnam and Indonesia.[7]

 

Source: Adidas Sustainability Progress Report 2016, p 61.

 

Adidas has both direct suppliers and indirect suppliers (i.e. material and other service providers that supply goods and services to Adidas’ direct suppliers; licensees which manage the design, production and distribution of specific products to Adidas; and agents that act as intermediaries and determine where products are manufactured, manage the manufacturing process and sell finished products to the group). Approximately 75% of its total sourcing volume comes directly from its supply chain, with the other 25% coming from agents or made under licence. The manufactured products are sold in over 100 markets.[8]

Adidas states that it supports the UNGPs and it is a ‘long time adherent’ to the OECD Guidelines. It considers that the corporate responsibility to respect human rights is a ‘global standard of expected conduct for all business enterprises’ and it states that it has ‘incorporated key elements of the [UNGPs] into its general practice in managing the human rights impacts of its business.’

Adidas’ general approach to human rights is firstly to strive ‘to operate responsibly and in a sustainable way along the entire value chain’, and secondly to safeguard the rights of its employees and those that work in its manufacturing supply chains. HRDD is a key part of this approach. Given the extensive nature of Adidas’ supply chains, it has taken a targeted approach to HRDD by focusing on mitigating and remediating issues that arise in high-risk locations, processes and activities.[9] It also imposes ‘cascading responsibilities’ on its business partners in order to ‘capture and address potential and actual human rights issues upstream and downstream’.[10]

Adidas’ Social and Environmental Affairs team (SEA Team) is tasked with, inter alia, ensuring compliance with the Workplace Standards within Adidas’ supply chains (discussed in further detail below). The Team consists of approximately 70 individuals, including engineers, lawyers, HR managers and former members of NGOs. It is organised into three regional teams covering Asia, the Americas and Europe, Middle East and Africa. The Team collaborates with other functions within Adidas, including Legal and Human Resources. The Team works collaboratively with other functions, including Legal, Sourcing and Human Resources. It engages directly with suppliers, governments and other external stakeholders as and when required.

 

Identification and Assessment of Risks

Adidas engages in a range of processes to identify and assess its human rights risks and impacts on a continuous basis within its supply chains. Adidas’ SEA Team engages commissioned third party experts and independent audits as part of this process where necessary.[11]

Adidas completes annual Country Risk Assessments (CRAs), which are not publically available, in the countries in which it sources products whereby it reviews the salient human rights issues and risks in a particular country. CRAs are informed by various people, including Adidas’ field teams, its engagement with local stakeholders, concerns raised by international NGOs, as well as an examination of regional human rights reports (as necessary). The risks identified in these CRAs inform its priorities and guides its prevention and mitigation strategies, particularly in relation to its supply chain monitoring.

Entry into new countries

Where Adidas plans to enter a new sourcing country, in-depth assessments are normally undertaken over a period of one to two years. The process involves engagement with government departments, international agencies and civil society groups to determine country level risks and issues. This process informs whether Adidas should or should not enter a particular country, as well as whether additional processes should be undertaken to safeguard against particular adverse human rights impacts that are common within a country arising within Adidas’ supply chains.

Engaging with new suppliers

All new supplier relationships must be disclosed to Adidas’ SEA Team for approval.

The process followed by Adidas when considering entering into direct supplier relationships is illustrated below.

Adidas conducts an initial assessment, which consists of a document check whereby prospective suppliers are assessed against the Workplace Standards (discussed below) and may include a factory visit. As stated in Adidas’ Enforcement Guidelines, Adidas checks prospective suppliers against a set of zero tolerance issues (e.g. prison labour, repetitive and systematic abuse, life-threatening health and safety conditions)[12] and threshold issues (e.g. fraud and exploitation issues, serious labour issues).[13] Zero tolerance issues are severe breaches that ‘may threaten the lives or well-being of workers, suppress fundamental rights, or result in irreparable damage to the environment’, whereas threshold issues are ‘those types of breaches or workplace issues which are considered to be extremely serious in nature, requiring enforcement action to be taken against existing suppliers.’[14]

Where a zero tolerance issue exists, Adidas will reject a relationship with that particular prospective supplier, whereas where a threshold issue exists, if the issue can be fixed, a prospective supplier will be given a timeline to rectify the issues. If they are found to have improved after a subsequent check, they will be approved.[15] In 2018, Adidas conducted initial assessments of 221 factories. As a result, approximately 25% were rejected directly after the initial assessment due to the presence of zero tolerance issues or after a second visit due to the presence of threshold issues that they failed to rectify between the initial and subsequent visits.[16]

With respect to Adidas’ indirect supply chain, external audit firms are commissioned to carry out initial assessments. Adidas provides detailed guidance to these external monitors so that assessments are carried out in a consistent manner. Where these assessments identify the need for remediation processes, the SEA team oversees them.[17]

Once a supplier, agent, licensee or subcontract has been approved, they enter into a formal legal agreement (e.g. manufacturing agreement). Adidas’ Workplace Standards are an integral part of such agreements – parties are contractually bound to uphold the Workplace Standards and act in a manner that safeguards human rights, workers’ employment rights, safety and the environment. They are also required to assist in identifying issues as and when they arise.[18] Suppliers are encouraged to share the Workplace Standards with their subordinate relationships, including external service providers. Additionally, Adidas incorporates human rights-related clauses into its direct supplier contracts, as well as clauses relating to labour, workplace health and safety and the environment.

Engaging with existing suppliers

Once direct suppliers have been approved and have entered into a contractual relationship with Adidas, Adidas monitors their compliance through auditing, factory visits, worker feedback mechanisms, partnerships with external organisations (such as ILO Better Work, the Bangladesh Accord and the Fair Labor Association) and stakeholder outreach, including engagement with government regulators, unions, employer federations, workers and civil society groups at the country level. This process enables Adidas to monitor its supply chain risk to ensure that its suppliers manufacture in a socially and environmentally responsible manner.[19]

The CRAs that Adidas conducts results in the categorisation of countries as either high or low risk, factories located in high-risk countries are more likely to be audited regularly (the full list of countries by category is not publicly available). Factories located in low-risk countries are excluded from Adidas’ audit coverage.[20] Factories are assessed based on their commitment to and performance against the Workplace Standards. During 2018, Adidas conducted 546 factory visits in order to engage to ‘improve working conditions and … empower workers’[21], and 1,207 social compliance audits and environment assessments. Additionally, for suppliers that were considered to be ‘compliance mature’ 102 self-governance audits and collaboration audits were conducted, which were reviewed by Adidas. 

Where non-compliances are identified, if the relevant issue is a zero tolerance issue a warning and potential disqualification of a supplier will be triggered. If the relevant issue is a threshold issue, Adidas will see whether the issue can be addressed in a specified timeframe through remedial action. It may also take enforcement action against the supplier, which includes the termination of the relationship, stop-work notices, third party investigations and warning letters. In 2018, Adidas issued a total of 39 warning letters across 16 countries, and terminated agreements with one supplier on the basis that it refused to grant the SEA team access to audit the factory.[22]

The top 10 labour and health and safety non-compliance findings during the 2018 audits are depicted in the image below.


Source: Adidas Annual Report 2018, p 99.

External monitors that have been approved by Adidas audit indirect supply chain factories that work with Adidas’ licensees and agents. Audits are conducted at least once a year, but will be conducted more frequently when additional follow up assessments are required to monitor remedial action.

Adidas has also implemented a Crisis Protocol so that business entities and factories can report on high-risk issues, which in turn inform Adidas’ site visits, audits and engagement with the business entities and factories.[23]

Stakeholder Engagement Channels

Adidas’ Stakeholder Relations Guidelines define its stakeholders as ‘those people or organizations who affect, or are affected by, [its] operations and activities.’ Its stakeholders include employees, shareholders and investors, authorisers (e.g. governments and trade associations), business partners (e.g. unions and suppliers), workers in supplier factories, customers and opinion-formers (e.g. journalists and special interest groups). Adidas claims to utilise stakeholder engagement in order to identify human rights risks and impacts through its supply chains. In order to obtain the views of these different stakeholders, frequent forms of engagement utilised by Adidas include stakeholder consultation meetings with workers, NGOs and suppliers, meetings with investors and Socially Responsible Investment analysts, employee engagement surveys and programmes, responding to inquiries from consumers and the media and participating in multi-stakeholders initiatives (e.g. the Better Cotton Initiative). Adidas aims to ensure that its engagement is balanced and inclusive.

Adidas captures and addresses complaints from third parties through its third party grievance mechanism. The mechanism allows third parties directly affected by an issue, including workers within its supply chains, to raise complaints. Complaints may be raised in relation to violations of Adidas’ Workplace Standards, or any potential, or actual, breach of human rights linked to Adidas’ operations, products or services. As part of this, Adidas also has an SMS hotline in the countries in which it sources its products so that workers can voice their concerns in an easy manner. From 2014 to 2018, Adidas has received a total of 52 complaints relating to labour and human right concerns by third parties. Third parties may also lodge complaints through the Third Party Complaint Process of the Fair Labor Association and the OECD National Contact Point for Germany.

Additionally, Adidas’ SEA Team regularly meets and interviews supply chain workers and tracks feedback from independent worker hotlines and from its suppliers’ own internal complaint systems.

Identified risks

Through the processes set out above Adidas has identified various human rights risks in its supply chains. Salient human rights risks include: freedom of association and collective bargaining, working hours, health and safety, fair wages, child labor, forced labor, resource consumption, water (including chemical management), access to grievance mechanisms, diversity, mega sporting events, procurement, product safety, as well as data protection and privacy security. 

Other risks identified include right of assembly, freedom of expression, migrant workers, human trafficking, discrimination, Indigenous peoples’ rights, occupational health and safety and environmental pollution.[24] A number of these risks are common to the garment and footwear industry as noted by the OECD Guideline on Responsible Supply Chains in the Garment and Footwear Industry.

Integrating and Acting

Adidas feeds the findings from the identification and assessment processes set out above into its active programmes and they drive prevention and mitigation measures.

The SEA Team reports risks identified in Adidas’ supply chains to executive management on a monthly basis.[25] Reporting highlights the critical issues, investigations and remedial efforts taken with respect to Adidas’ direct and indirect supply chains. This is the ‘primary vehicle through which human rights concerns are shared with senior management and reported progress is tracked’.

Where adverse human rights impacts occur, Adidas seeks to remediate those cases. Corrective Action Plans (CAPs) are put in place, which set out the remedial action, the responsible party and a timeframe to complete that action. The supplier’s specific proposals in the CAP are then tracked and the appropriate documentation, or remedial action(s), reviewed to close-out the non-compliances. CAPs are normally developed through engagement with the suppliers, to define expectations and negotiate appropriate timelines.[26]  The SEA Team closely monitors the development and implementation of CAPs through follow-up audits and record progress and verification status. 

In the past, Adidas has examined and remediated instances of ‘forced labour, child labour, freedom of association, right of assembly, freedom of expression, discrimination, indigenous people’s rights, occupational health and safety, resource consumption and environmental pollution’.[27] It has also dealt with specific cases where workers have been subject to arbitrary arrest and detention and reached out to judicial authorities where human rights defenders have also faced arrest and detention for supporting worker’s rights. It has petitioned governments for their failures in enforcement, particularly in relation to the right to form and join trade unions and the upholding of statutory minimum wages.[28]

In order to prevent adverse human rights impacts from occurring, Adidas binds its suppliers to its Workplace Standards. It continuously monitors those suppliers in which it has a direct contractual relationship and assesses their performance against the Workplace Standards. Adidas also engages in capacity building to strengthen its suppliers’ internal governance and management systems in order to reduce the potential for adverse human rights impacts. With respect to its indirect supply chain, Adidas places expectations on its primary business partners to engage and apply its Workplace Standards.

With respect to grievances raised, in cases where Adidas has caused or directly contributed to the violation, it will seek to prevent or mitigate the chance of the impact occurring or recurring. If an adverse impact is occurring, Adidas will engage actively in its remediation – this may involve site visits, audits or other engagement with a business entity or factory.[29] Where Adidas has neither caused nor directly contributed to a violation, it will encourage the business entity that has caused or contributed to the impact to prevent or mitigate its recurrence.

 

Tracking

Adidas monitors and evaluates the effectiveness of its response to human rights risks and impacts.

Adidas’ Internal Audit team conducts periodic assessments to evaluate the effectiveness of individual departments and programs, with defined timelines for corrective actions. It reports directly to the CEO and Supervisory Board. As part of this, it evaluates the effectiveness of Adidas’ social compliance monitoring system and human rights due diligence processes and their alignment with policy commitments.

Adidas’ social compliance program is subject to annual third party audits and public disclosure of tracking charts by the Fair Labor Association (available here), to determine whether supplier-level remediation is being effectively managed by Adidas. The Fair Labor Association also undertakes a periodic accreditation process whereby it evaluates all elements of Adidas’ labour and human rights work.[30]

For its direct supply chain, Adidas utilises social and environmental KPIs to assess the effectiveness of its suppliers’ systems to protect labour rights, worker safety and the environment. For its licensee partners and agents that manage its indirect supply chain, Adidas uses a scorecard that evaluates and scores a business entities performance in applying its Workplace Standards and associated guidelines. KPIs and scorecards assist Adidas to determine strategic suppliers and influence sourcing decisions. However, it is unclear as to how KPIs and scorecards influence such decisions and the extent to which they do so. Further, both factories and business entities and licensees are required to prepare strategic compliance plans on a regular basis outlining their strategies to meet Adidas’ Workplace Standards. Adidas’ SEA team uses these plans to monitor the commitment and compliance practices of its direct and indirect supply chains.[31]


Communicating

Adidas claims to have regular contact with a diverse range of stakeholders, including vulnerable groups, workers in supply chains, local and international NGOs, labour rights advocacy groups, human rights advocacy groups, trade unions, investors, national and international government agencies, and academics. The stakeholders that Adidas engages with depend on the specific issues and trends at the time. It uses its network to pinpoint areas for dialogue and the applicable parties to engage with. It then prioritises stakeholders depending on action radius, relevance, risk, willingness and capacity to engage. The frequency of dialogue can range from monthly to quarterly or annually.

Adidas utilises various channels to communicate its human rights impacts, policies and approaches, including:

  • annual Sustainability Progress Report;
  • annual Modern Slavery Statements;
  • individual stakeholder meetings and correspondence;
  • structured stakeholder dialogues;
  • public statements;
  • collaborative engagements with NGOs;
  • multi-stakeholder and partner organizations; and
  • one-on-one worker interviews and meetings.

It also uses FAQs and blogs, as an accessible and understandable way for the public and its internal staff, to grasp its human rights work and specific programme initiatives related to worker rights, safety and the environment.[32] Other vehicles for stakeholder engagement include purpose-built fora such as the OECD Advisory Panel for embedding of Business & Human Rights Due Diligence practices into the Apparel and Footwear sector, the Bali Process Business and Government Forum and the Bangladesh Accord.[33]

Adidas seeks to define and tailor the appropriate level of communications needed for a given target audience. For example, with respect to trade unions, it is Adidas standard protocol that its local monitoring staff engage with the factory-level trade union officials or relevant worker representatives to cross check issues that arise during its compliance audits and discuss the necessary remedial actions that the supplier has to follow-up on.

To ensure clear and effective communications with local stakeholders, affected communities and other vulnerable groups, the SEA Team has embedded local staff in Adidas’ key sourcing countries. The team operates in 18 languages, but employs translators where needed for special investigations, stakeholder outreach or communicating outcomes or mechanisms to improve human rights impacts. For example, Adidas has contracted Arabic translators in Turkey to support its communications with Syrian refugees at risk of exploitation in the supply chain. With respect to complaints, phone calls and direct face-to-face meetings will be used to capture issues and provide feedback. Adidas publishes high-level information regarding the status and resolution of complaints through its third party grievance mechanism on its website (see, for example, a summary of the third party complaints handled by Adidas in 2018 here).

The Gaps Between Paper and Practice

As stated at the outset, brands within the apparel and footwear sector face a plethora of challenges in conducting effective HRDD given the human rights risks inherent in their supply chains. Adidas itself has acknowledged that effective HRDD remains a ‘primary challenge’ of the business, given the ‘breadth and depth of [its] business, which includes tens of thousands of business relationships along a value chain that stretches from smallholders, farming cotton, to the final point of sale in a retail store.’ Nonetheless, Adidas is considered to have leading HRDD practices globally, not only in the apparel sector, but also across the sectors that have been benchmarked to date.[34]

What is clear from a review of Adidas’ human rights approach is that it recognises its responsibility to respect human rights and has sought to take steps to fulfil this obligation along its entire value chain. As part of that, it has developed over a period of over 20 years extensive HRDD practices fleshing out its commitment to upholding human rights.[35] Adidas’ HRDD practices seek to properly identify and assess the human rights risks and impacts that arise in its supply chains, and prevent and mitigate those risks through engagement with suppliers and stakeholders.

Despite this strong commitment and extensive HRDD processes and procedures in its supply chains, Adidas’ human rights track record is not perfect. Over recent years Adidas has featured in headlines where it has been demonstrated that human rights issues exist in its supply chains. Many of these issues relate to the wages paid to its supply chain workers. In 2014, the Clean Clothes Campaign (CCC) released a profile on Adidas with respect to its practices regarding workers’ living wages. The profile noted that while Adidas was assessing its wages practices across Asia, ‘it [was] still not willing to define what a living wage means in its business’ and had passed on responsibility for wages in supplier factories to factory owners. The CCC called on Adidas to ‘engage in identifying a living-wage figure and changing pricing in order to enable its payment.’ This call to action came after workers in factories that supply to Adidas went on strike in Asia.

In 2014, there was a nationwide strike in Cambodia calling for an increase of the minimum wage for garment workers. Shortly before the strike the CCC reported that the minimum wage in Cambodia at the time did not allow workers to meet their living costs in housing, food, clothing, education, transport and healthcare. During a crackdown in Cambodia, five workers were shot dead and 30 others were injured. Following this event, Adidas backed the development of a minimum wage review mechanism for garment workers. Also in 2014, workers at the Yue Yuen shoe factory in China, an Adidas supplier, went on strike over social security payments and housing fund contributions. In response, Adidas moved some of its orders from the factory in order to ‘minimize the impact on [its] operations’. It did not sever ties with the factory given that ‘China is, and will continue to be, a strategic sourcing country for [it].’ Again in 2015 workers from the same factory went on strike due to changes in its production process, resulting in workers demanding an immediate payout of their housing fund. No information on Adidas’ response to this issue has been located, however, Reuters reported that Adidas did not immediately respond to its request for comment.

The payment of low wages to workers was more recently raised in June last year where Adidas was accused of ‘foul play’ by paying thousands of female workers within its supply chain low wages in order to prepare football shirts and shoes for the Football World Cup that year. In their report, Éthique sur l’étiquette and the CCC compared the costs of Adidas’ current production with that in the 1990s and found that the costs paid to workers had decreased by 30%. Noting that a large proportion of Adidas production occurs in Indonesia, it found that the wages paid to female workers was not sufficient to cover their basic needs, with some women not even receiving the minimum legal wage. The report stated that:

If … Adidas had paid the same amount of dividends in 2017 as they did in 2012, or maintained the level of marketing/sponsorship spending, the resulting proceeds would have allowed for living wages to be paid throughout their entire supply chain in China, Indonesia, Vietnam, and Cambodia.

Outside Asia, concerns were also raised in 2016 in relation to the treatment and serious exploitation of Syrian refugees in Turkish supplier factories, including sexual abuse and child labour. As a result, Adidas was called upon by the Business and Human Rights Resource Centre to respond to these concerns by completing a questionnaire, Adidas’ response to the questionnaire outlined its policies and procedures with respect to employing Syrian refugees and their treatment in supply chains, noting that it does not have any Syrian refugees working for any of its five Turkish first tier Turkish suppliers.

Similarly concerns were also raised in 2016 and 2017 in relation to the poor working conditions in shoe supply chains in Eastern Europe (see for example the CCC’s reports titled ‘Labour on a Shoe String’ and ‘Europe’s Sweatshops: The results of CCC’s Most Recent Researches in Central, East and South East Europe’). Adidas was again called upon by the Business and Human Rights Resource Centre to respond to a series of questions regarding its efforts and work in the area of sustainability and social responsibility, precisely on sourcing policies with regard to Eastern Europe. In its 2016 response, Adidas defended its engagement with leather tanneries stating that it has ‘a well-tested human rights due diligence process, one which considers the severity of country and industry-level risks within our global supply chain.’ However, it also noted that the sourcing of raw hides and finished leather has been identified as a ‘priority area for further assessment and [its] deeper involvement’. With respect to its footwear manufacturing in Eastern Europe, Adidas stated that ‘more should be done to improve wages’ and ‘engagement between local suppliers, unions, governments, and buyers’ is critical to improving the lives of workers. It did not, however, outline what actions it would take to improve worker wages. In its 2017 response, Adidas set out its general approach to ensuring fair wages in its supply chain and provided an example of the processes it has followed to set wages in Georgia and the Ukraine.

Conclusion

The instances of human / labour rights abuses detailed above demonstrate that despite Adidas’ comprehensive HRDD process, there are failings and gaps in that process that create space for human rights violations to occur in its supply chains. It also shows that the paper-based process detailed in this blog has imperfections in practice that need to be ironed out. Literature has demonstrated that there are often considerable discrepancies between HRDD processes on paper and in practice, highlighting gaps in supply chain governance. For example, Genevieve LeBaron has found through her research on ethical audits and the supply chains of corporations, businesses have ‘claimed supply chain monitoring for themselves’ by using audits as a way to ‘preserve their business model and take responsibility for supply-chain monitoring out of the hands of governments.’ As such, they have been able to avoid ‘stricter state and international regulation’ and to take steps to ensure they are perceived as responsible companies. However, while this is benefiting businesses by giving the impression that businesses are taking active steps on the journey to respect human rights, it is failing workers in supply chains. Human rights violations such as labour abuses are still widespread within supply chains. Therefore, in order to avoid going down this path, businesses need to engage with the issues that are arising in their supply chains, consider the root causes of those issues and make adjustments to HRDD processes.

This review of Adidas’ HRDD process and the gaps identified between the process in theory and in practice raises a number of interesting questions. For example – What precise aspects of Adidas’ identification of risks process are not living up to their expectations allowing human rights violations to continue to occur in its supply chains? What steps are Adidas taking in order to continuously improve its HRDD process? To what extent does Adidas look to or gain inspiration from the practices of its peers? What challenges does Adidas currently face in conducting HRDD in its supply chains and how is it seeking to respond to those challenges?


[1] The information in this blog has been obtained from Adidas’ 2018 submission to the Corporate Human Rights Benchmark and from other Adidas sources. Accordingly, it represents Adidas’ views on its HRDD process.

[2] Human Rights Watch, “Paying for a Bus Ticket and Expecting to Fly”: How Apparel Brand Purchasing Practices Drive Labor Abuses, April 2019.

[3] OECD Due Diligence Guidance For Responsible Supply Chains in the Garment and Footwear Sector, p 15.

[4] Adidas Annual Report 2018, p 72.

[5] Adidas Profile.

[6] Adidas Supply Chain Approach.

[7] Adidas Assessment for Re-Accreditation by the Fair Labor Association, p 6.

[8] Adidas Supply Chain Approach.

[9] Ibid.

[10] Ibid.

[11] Adidas Sustainability Report 2010, p 42

[12] Adidas Enforcement Guidelines, pp 4-5.

[13] Ibid, pp 5-7.

[14] Ibid, p 4.

[15] Adidas Supply Chain Approach.

[16] Adidas Annual Report 2018, p 96.

[17] Adidas Sustainability Report 2010, p 49.

[18] Adidas has produced a number of supporting guidelines that aim to ‘make the Workplace Standards understandable and practical, provide additional guidance for [its] suppliers’ and assist in finding effective solutions to workplace problems: Adidas Sustainability Report 2010, p 44.

[19] Adidas Supply Chain Approach.

[20] Adidas Annual Report 2018, p 98

[21] Ibid, p 96.

[22] Adidas Supply Chain Approach; Adidas Annual Report 2018, pp 98-99

[23] Adidas Supply Chain Approach.

[24] Business and Human Rights Resource Centre, Company Action Platform, Adidas.

[25] Adidas Supply Chain Approach.

[26] Adidas Response to KnownTheChain Apparel and Footwear Benchmark, p 16.

[27] Business and Human Rights Resource Centre, Company Action Platform, Adidas.

[28] Ibid.

[29] Adidas Supply Chain Approach.

[30] Adidas was last re-accredited in 2017.

[31] Adidas Sustainability Report 2010, p 49

[32] See for example Adidas’ Human Rights and Responsible Business Practices: Frequently Asked Questions.

[33] Adidas Analysis: Cross Section of Stakeholder Feedback 2017/2018.

[34] See for example: Corporate Human Rights Benchmark 2017 and 2018; Know the Chain 2018; and Fashion Transparency Index 2019.

[35] In 1997, Adidas developed its initial supplier code of conduct (Standards of Engagement, now referred to as the Workplace Standards), which formed part of the contractual obligations under manufacturing agreements, and established a Compliance Team. The Standards of Engagement, which are now called Workplace Standards, reflect international human rights and labour rights conventions. A full timeline of Adidas’ social compliance history is accessible here.


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