Code Application — Factory Monitoring
Levi Strauss & Co. (LS&CO.) employs 20 full-time factory assessors worldwide, spread out across all regions. These individuals are experts on labor standards and familiar with the languages, cultures, laws and business contexts of the countries in which they work. They conduct annual assessments of all contract factories using the Terms of Engagement (TOE) Guidebook and skills they learn through our rigorous assessor training program to determine if a factory meets the requirements of our TOE and, where applicable, develop a corrective action plan. Regional assessors and directors report to the vice president for global code of conduct, a position only two reporting levels away from the company’s board of directors.
The formal assessment consists of:
- interviews with the facility management;
- a review of personnel, wage and working hour records;
- a physical walk-through and inspection of health, safety and environmental conditions in the factory and dormitories if they exist; and
- informal discussions with workers in the local language both on and off site.
Facility conditions are also informally monitored by field assessors and other LS&CO. employees who visit the facilities on a regular basis as part of their sourcing responsibilities.
An important aspect of the assessment process involves assessors gathering information from workers to identify potential TOE violations and gauge their understanding of the TOE requirements. Conversations with workers are conducted in the workers’ language and are carried out both on factory premises and off site. Where conversations with workers yield information that may indicate violations of the TOE, assessors will verify the information through other sources. Workers are provided the assessor’s local contact information and invited to contact the assessor at no cost to report additional relevant information including any actual or perceived retaliation by the supplier. (See discussion in Assessor Training and Tools)
We work to continually improve our monitoring program. At the same time, we recognize that the key to long-term sustainability of improved working conditions is to move beyond monitoring. To that end, while we work to strengthen our TOE policies and procedures, we are simultaneously testing models of increased supplier ownership, including factory-based management systems.
Use of Third-Party/Independent Monitors:
Currently, LS&CO. is using Verite, a nonprofit monitoring organization to conduct independent, supplementary monitoring of selected LS&CO. supplier factories around the world to validate TOE performance as necessary.
Licensees are required to comply with TOE and to only use monitors approved by LS&CO. to assess factories producing our branded products. In order to be approved, third-party monitors are interviewed and screened for proper qualifications. Once screened, they must attend the LS&CO. assessor training and pass an assessment review which includes a one-on-one, post-training interview with a LS&CO. senior TOE assessor and a "shadow audit" in the field.
There are approximately 70 individual third-party monitors currently approved to conduct TOE assessments in licensee factories.
For more information on TOE factory monitoring, contact Leslie Croshaw at lcroshaw@levi.com.