Corporate Responsibility
RG Barry incorporates its core values of integrity, quality, innovation, leadership, teamwork and community in all of its business dealings. The Company's Team Members constantly strive to achieve the highest business and personal ethical standards, as well as compliance with all applicable governmental laws, rules and regulations. We believe that it is the responsibility of a good corporate citizen to positively embrace social, environmental and governance factors as part of the overall business strategy. We demand this, not only of ourselves, but of all who provide us with goods and services.
Accessibility Statement
At RG Barry we are committed to providing exceptional customer service to all of our customers. Ensuring that persons with disabilities have access to our products and websites is a vital part of this commitment. If you are using a screen reader, magnifier, or other assistive technologies and are experiencing difficulties using this website, please call our TOLL- FREE support line (614) 864-6400 or contact us for assistance.
Transparency in Supply Chain
Element 1
Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.
RG Barry's written policies incorporate our intolerance of all types of forced labor to our suppliers. Suppliers are audited by an independent third party to help insure adherence to our expectations.
Element 2
Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was an independent, unannounced audit.
RG Barry utilizes professional third party audit firms to complete social audits on our behalf and on the behalf of our customers. Auditors perform comprehensive investigations. Announced and unannounced visits are performed at random.
Element 3
Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
RG Barry requires all suppliers to comply with all laws regarding all forms of forced labor including but not limited to: slavery, indentured, bonded, child or prison labor and human trafficking. This is detailed on our Terms of Engagement, a document that must be signed by all suppliers and posted in a location visible to all their employees at all facilities.
Element 4
Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
RG Barry Corporation requires suppliers and factories to sign our Terms of Engagement. This document requires all government, industry, and RG Barry standards be met. Our TOE, which must be posted in a visible and accessible location within the facility, contains several forms for supplier employees to contact our Global Ethics Office and report any violation of these standards. RG Barry will not tolerate doing business with suppliers that are noncompliant.
Element 5
Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within supply chains of products.
RG Barry's Code of Ethical Business Conduct is published annually. This document outlines our expectation for ethical behaviors throughout our organization. RG Barry also utilizes a standard operating procedure when selecting suppliers. RG Barry relies on the audit reports from our independent auditors. Should there be any concerns raised by these auditors, RG Barry would address at that time.
Terms of Engagement
Key Beliefs
R.G. Barry Corporation (“R.G. Barry”) is successful by adhering to three basic beliefs since its founding in 1947:
1. Respect for the Individual
2. Service to our Customers
3. Strive for Excellence
R.G. Barry strives to conduct its business in a manner that reflects these three basic beliefs and expects its suppliers to adhere to these beliefs in their contracting, subcontracting and other business relationships. Additionally, because the conduct of R.G. Barry’s Suppliers can be attributed to R.G. Barry and its reputation, R.G. Barry has adopted the FDRA’s Production Code of Conduct. R.G. Barry requires its Suppliers, and their Contractors, to meet the following standards, and reserves the right to make periodic, unannounced inspections of Suppliers’ facilities and the facilities of Suppliers’ Contractors to ensure Suppliers’ compliance with these standards.
Following the FDRA’s Production Code of Conduct, R.G. Barry has expounded upon environmental concerns, restricted substances, and regulations.
After you have thoroughly read this Terms of Engagement, sign the last page and return to the Compliance Dept.
A copy of these terms should be posted in a common area for all employees to review and be aware of.
A full copy of the FDRA Production Code of Conduct can be obtained by contacting R.G.Barry’s Compliance Dept.
Thank you for your partnership.
Sincerely,
Kathleen Woods, R.G. Barry Corp Compliance Manager
Zero Tolerance Issues
Human Trafficking, Slavery, Forced Labor, or Child Labor
Transparency
Production Units shall maintain complete and accurate records and information so that compliance can be effectively assessed. Production Units must not falsify or understate any aspects of their operations to FDRA or its representatives.
Management Systems
Policies and procedures are in place to ensure the Production Unit and their subcontractors are aware of and comply with applicable laws, regulations and, where stricter, the FDRA Code of Conduct.
Business Integrity
Business must be carried out with a high degree of ethics, honesty and fair dealings; ensuring staff is familiar with the FDRA Code of Conduct and does not engage in threats, bribery or corruption practices. The supplier can be held responsible for unethical actions committed by their external partners. Therefore, it is very important that suppliers only work with well‐qualified companies and representatives with a good reputation.
Anti-Bribery
The offering, paying, soliciting or accepting of bribes or kick‐backs, including facilitation payments, is strictly prohibited. Suppliers, representatives and their employees must comply with all applicable anti‐bribery and corruption laws.
Compliance with the Law
FDRA requires all suppliers and Production Units to comply fully with the legal requirements of the countries in which they operate. The standards set forth in this document are a supplement that is also expected to be followed.
Compliance with our Code of Conduct
FDRA member companies reserve the right to conduct announced and unannounced inspections of all Production Units. Suppliers and Production Units are required to cooperate with the entire process
Subcontracting
Suppliers or Production Units may not subcontract any operation in the manufacturing process without prior written consent from the factory’s customer, and only after the subcontractor has agreed to comply with the FDRA Code of Conduct. Suppliers and Production Units are responsible for ensuring compliance with the FDRA Code of Conduct by all approved subcontractors who produce merchandise for sale including but not limited to: cutting, sewing, embroidery, printing, laundry/washing, dry processing, garment dyeing, panel knitting, linking, and f inal assembly/packing.
Environment
In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public. At a minimum, this includes meeting all relevant local and national environmental protection laws, with a goal to meet international environment protection standards. FDRA expects Suppliers and Production Units to work towards the elimination of discharge of hazardous chemicals in the supply chain.
Labor
Suppliers must commit to upholding the human rights of workers, to treat them with dignity and respect, and to improve working conditions within their supply chain.
Employment is Freely Chosen
Production unit does not utilize forced labor, bonded labor, prison labor, slave labor, or victims of human trafficking in the production of the products.
Collective Bargaining
Production Unit respects the rights of workers to freely and peacefully associate and collectively bargain.
Working Conditions
A safe and hygienic working environment shall be provided. The structure of the Production Units, including residential facilities provided by the Production Unit, is stable and safe and does not put people in jeopardy.
Child Labor
There must be no recruitment of “child labor” defined as any work by a child under the age of 14, or the minimum working age set by local law, whichever is greater. Production facilities must comply with all local laws and ILO standards regarding the working conditions and restrictions for “young persons,” also known as “juvenile workers.”
Wages and Benefits
Suppliers are expected to adhere to all local and national laws governing wages, overtime, and time off. It is vitally important that suppliers are transparent upfront about any challenges they face complying with any wage and benefit laws.
Working Hours
Suppliers are expected to adhere to all local and national laws governing working hours. Factories are expected to not exceed 60 working hours in a given week and provide one day off for every seven-•‐day period. Overtime must be on a voluntary basis and shall not be demanded on a regular basis and shall be compensated at a premium rate as stipulated by local laws.
No Discrimination
Suppliers shall not engage in, support or tolerate discrimination in employment including recruitment, hiring, training, working conditions, job assignments, pay, benefits, promotions, discipline, termination or retirement on the basis of gender, age, religion, marital status, race, caste, social background, diseases, disability, pregnancy, ethnic and national origin, nationality, membership in worker organizations including unions, political affiliation, sexual orientation, or any other personal characteristics.
Regular Employment
Work performed must be on the basis of a recognized employment relationship established in compliance with national legislation and practice and international labor standards, whichever affords the greater protection. Regardless of the worker type (part time, student worker, etc.), all employees receive at least minimum wage.
No Harsh or Inhumane Treatment
Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.
To receive the full FDRA Production Code of Conduct or for any questions regarding this Code or FDRA’s Recognized Responsible Footwear Manufacturers please contact info@fdra.org
Concern for the Environment & Restricted Substances
Our Expectation
is that the Supplier knows and adheres to your local government's requirements regarding waste and water consumption and receives certification in these areas if so mandated by your locality.
Suppliers are expected to follow guidelines that will prevent the future depletion of natural resources and ensure the use of safe materials for manufacturing. We encourage Suppliers to reduce excess packaging and to use recycled and nontoxic materials.
Use of any substances listed on the RSLs (Restricted Substances Lists) listed below will result in immediate termination of business by R.G. Barry. Any subsequent lawsuit due to injury or product failure made by government or non-government organizations or end consumers will result in legal action by R.G. Barry. The Supplier will be held liable for any and all lawsuits derived from the Supplier’s non-compliance to the RSLs.
A list of regulated or banned materials can be found at: www.oehha.org/prop65.html
For a list of restricted toxics in packaging visit TPCH at: www.toxicsinpackaging.org
R.G. Barry utilizes the FDRA’s Chemical and Physical Testing Guidebook for RSLs.
CPSIA: In 2008 the CPSC set forth legislation known as the Consumer Product Safety Improvement Act (CPSIA of 2008) regulating the use of lead and phthalates in the manufacturing of children’s product. Suppliers are expected to follow these guidelines during production of merchandise for R. G. Barry.
For more information about the CPSIA please refer to the CPSC’s website: www.cpsc.gov/en/About-CPSC/
Right of Inspection
R.G. Barry or a third party designated by R.G. Barry will take actions, such as inspection of production facilities, to implement and monitor these standards and to monitor for use of restricted substances during manufacturing. Suppliers will be responsible for all costs associated with audit/inspection failures due to non-compliance for any reason noted on this Terms of Engagement. During the course of inspection it is against R.G. Barry’s ethical standards to approach an R.G. Barry or third party employee with bribes, kickbacks or other similar unlawful or improper payments in order to obtain or retain business. This type of action will result in a failed audit and termination of business by R.G. Barry. Likewise, if an R.G. Barry or third party employee should solicit the Supplier for any type of gratuity R.G. Barry fully expects the Supplier to report the incident immediately to the Global Ethics Office.
Confidentiality
Suppliers shall not disclose to others and will not use for its own purpose or the purpose of others any trade secrets, confidential information, knowledge, designs, data, skill or any other information considered by R.G. Barry as “confidential”.
The “Terms of Engagement” must be posted in a location visible to all employees at all facilities that manufacture products for R.G. Barry. If you know of a violation of these standards by a supplier, factory, or R.G. Barry associate, it is the responsibility of the supplier to contact the R.G. Barry Global Ethics Office.
Call toll-free hotline: 1-800-826-6762. The hotline is operated by a third party provider and will forward your confidential, anonymous submission of concerns or complaints to the Chairman of the Audit Committee. Southern China call: 10-800-711-1188
Conflict Minerals Policy
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 requires publically traded companies to assert reasonable due diligence within their supply chain to determine if “Conflict Minerals”, defined as tin, tantalum, tungsten and gold (3TG), used in their products are being sourced from mines controlled by non-government or unlawful military groups within the Conflict Region. The “Conflict Region” is defined as the Democratic Republic of the Congo (DRC) and surrounding countries.
The due diligence process of tracing materials back to their mine of origin is a complex endeavor. Due to this complexity, the R.G. Barry Corporation has engaged a third party with expertise in this area of supply chain compliance. Our commitment includes:
Developing policies and processes to prevent the use conflict minerals within our products that are mined from the Conflict Region.
Not knowingly procure conflict minerals that from facilities in the Conflict Region that are not certified as conflict
Requesting suppliers whose products contain conflict minerals to complete a the RG BARRY Conflict Mineral Survey and assist in establishing policies, due diligence frameworks, and management systems consistent with the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains Minerals from Conflict- Affected and High Risk-Areas that are designed to accomplish this goal, and requiring their suppliers to do the same.
The R.G. Barry Corporation strives to establish and maintaining long-term relationships with suppliers. However, if we determine that any supplier is, or a reasonable risk exists that it may be, violating this policy, we will require the supplier to commit to corrective action to move to a conflict free source. If corrective action is not taken, we will look to alternative sources for the product. If it is determined that any of the components of our products contain minerals from a mine or facility that is “non-conflict free”, we will strive to transition to products that are “conflict free”.
Corporate Sustainability
RG Barry works to promote sustainable, environmentally healthy business practices by identifying and sharing practical, innovative conservation methods; adopting appropriate environmental policies; and encouraging all of it's team members, vendors and customers to incorporate green practices into their lives.
We consider the environment to include every social, natural and cultural surrounding that impacts the health of our minds, bodies and spirits. We promote sustainable business practices by identifying and sharing innovative methods, offering policy recommendations, and encouraging team members to incorporate green practices wherever possible.
Through recommendations of the ENERGY STAR program of the U.S. Environmental Protection Agency and the U.S. Department of Energy, we have taken steps such as: replacing light bulbs at our facilities with more efficient bulbs that use half the energy; installing motion detectors to control room lighting; installing new, energy-saving HVAC and hot water units; and replacing computers with more energy-efficient models.
We also encourage our suppliers to: reduce excess packaging and to use recycled, nontoxic materials; to follow guidelines that will prevent the future depletion of natural resources; and to ensure the use of safe materials in manufacturing. The use of any restricted substance/material by a supplier will result in immediate termination of its business with RG Barry.