Code of Conduct for Occidental College Garment Contractors   (Adopted May 12, 1999)

I.  Introduction: Occidental College, 1600 Campus Road, Los Angeles, California 90041committed to conducting its business affairs in a socially responsible manner consistent with its employee personnel policies and expects its garment contractors to conduct their business in a manner consistent with, and follow workplace standards that adhere to, this Code of Conduct (the Code).

 II. Notice: This Code shall apply to all garment contractors of Occidental College. Throughout this Code the term "college" refers to Occidental College. Throughout this Code the term "Garment Contractor" shall include all persons or entities who have been authorized by the College to provide garments bearing the name, trademarks and/or images of Occidental College and therefore have entered into a written Garment Contractor Agreement with the College most often through the mechanism of accepting a Purchase Order. Throughout this Code, the term "subcontractor, vendor and/or manufacturer" shall include each subcontractor, vendor, and/or manufacturer that is engaged in a manufacturing process that results in a finished garment for the consumer. "Manufacturing process" shall include assembly, packaging, shipping and receiving.

As a condition of being permitted to produce and/or sell garments bearing the name, trademarks and/or images of the College, each Garment Contractor must comply with this Code and ensure that each subcontractor, vendor, and/or manufacturer comply with this Code. All Garment Contractors upon acceptance of a college purchase order acknowledges and agrees to comply with this Code.

III. Remediation: If the College determines that any contractor has failed to remedy a violation of this Code, the College will consult with the Garment Contractor to examine the issues and determine the appropriate measure to be taken. If consultation and agreed upon measures fail to adequately resolve the violations within a specified time period, the College and the Garment Contractor will implement a corrective action plan on terms acceptable to the College. The College reserves the right to terminate its relationship with any Garment Contractor who continues to conduct its business in violation of the corrective action plan.

Employees of the Garment Contractor or their subcontractors, vendors and/or manufacturers are the third party beneficiaries of this Code and may enforce this Code against the Garment Contractor or its subcontractors, vendors and/or manufacturers in a forum of their choosing, such as a court of law, before any governmental agency with quasi-judicial powers, through binding arbitration, or by any other fair and impartial trier of fact in the countries in which they reside, including but not limited to recovery of unpaid wages and obtaining injunctions against violations of this Code. However, nothing herein grants any third-party beneficiary rights to any person to bring claims against the College in the event that any Garment Contractor or other person fails to abide by any provision in this Code.

IV. Standards: Occidental College seeks Garment Contractors who take a leadership role on these issues and, to the extent practicable, exceed the standards of this code. Garment Contractors must operate workplaces, and ensure that their subcontractors, vendors and/or manufacturers operate workplaces, that adhere to the following minimum standards and practices:

A. Legal Compliance: Garment Contractors must comply, at a minimum, with all applicable legal requirements of the country in which garments are manufactured. Where this Code and the applicable laws of the country of manufacture conflict or differ, the higher standard shall prevail. Such compliance shall include compliance with all applicable environmental laws.

B. Ethical Principles: Garment Contractors will commit to conduct their business according to a set of ethical standards which include, but are not limited to, honesty, integrity, trustworthiness, and respect for the unique intrinsic value of each human being.

C. Employment Standards: The College will only do business with Garment Contractors whose workers are present at work voluntarily, are not at undue risk of physical harm, are fairly compensated and are not exploited in any way. In addition, the following specific guidelines must be followed:

1. Wages and Benefits: Garment Contractors must provide wages and benefits which comply with all applicable laws and regulations, and which provide for essential needs and establish a dignified living wage for workers and their families. A living wage is a "take home" or "net" wage, earned during a country’s legal maximum work week, but not more than 48 hours. A living wage provides for the basic needs (housing, energy, nutrition, clothing, health care, education, potable water, childcare, transportation and savings) of an average family unit divided by the average number of adult wage earners.

2. Regular Working Hours: Employees shall (I) not be required to work more than the lesser of (a) 48 hours per week, or (b) the limits on regular hours allowed by the law of the country of manufacture; and (2) be entitled to at least one day off in every 7-day period, as well as holidays and vacations.

3. Overtime: All overtime hours must be worked voluntarily by employees. In addition to their compensation for regular hours of work, employees shall be compensated for any volunteer overtime hours at the greater of either (a) the rate of compensation for regular hours of work or (b) as is legally required in the country of manufacture.

4. Child Labor: No person shall be employed at an age younger than 15 (or 14, where, consistent with International Labor Organization practices for developing countries, the law of the country of manufacture allows such exception). Where the age for completing compulsory education is higher than the standard for the minimum age of employment stated above, the higher age for completing compulsory education shall apply to this section. Garment Contractors agree to work with governmental, human rights and non-governmental organizations to minimize the negative impact on any child released from employment as a result of the enforcement of this Code.

5. Forced Labor: There shall not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise.

6. Health and Safety: Garment Contractors must provide workers with a safe and healthy work environment. If residential facilities are provided to workers, they must be safe and healthy facilities. In addition, Garment Contractors must comply with the following provision: The Garment Contractor shall ensure that its direct operations and any subcontractor generate records documenting its health and safety activities on site (such as facility and equipment inspections, workplace air sampling, accident investigations and employee training) and maintain these records for a period of no less than one year.

7. Nondiscrimination: Garment Contractors shall employ individuals solely on the basis of their ability to perform the job. There shall be no discrimination in hiring, salary, benefits, performance evaluation, discipline, promotion, retirement or dismissal on the basis of age, sex, pregnancy, maternity leave status, marital status, race, nationality, country of origin, social or ethnic origin, disability, sexual orientation, religion, or political opinion.

8. Harassment or Abuse: Every employee shall be treated with dignity and respect. No employee shall be subject to any physical, sexual, psychological or verbal harassment or abuse. Garment Contractors will not use or tolerate any form of corporal punishment.

9. Freedom of Association: Garment Contractors shall recognize and respect the right of employees to freedom of association and collective bargaining. No employee shall be subject to harassment, intimidation or retaliation in their efforts to freely associate or bargain collectively. Garment Contractors shall allow union organizers free access to employees. Garment Contractors shall recognize the union of the employees’ choice.

10. Women’s Rights:

a. Women workers will receive equal remuneration, including benefits, equal treatment, equal evaluation of the quality of their work, and equal opportunity to fill all positions as male workers.

b. Pregnancy tests will not be a condition of employment, nor will they be demanded of employees.

c. Workers who take maternity leave will not face dismissal nor threat of dismissal loss of seniority or deduction of wages, and will be able to return to their former employment at the same rate of pay and benefits.

d. Workers will not be forced or pressured to use contraception.

e. Workers will not be exposed to hazards, including glues and solvents, which may endanger their safety, including their reproductive health.

 V. Implementation: Occidental College seeks to foster an environment of labor standards compliance through ensuring adherence to the standards established by this Code.

    A. Garment Contractor Agreement. Upon acceptance of a college purchase order which permits the production and/or sale of garments     
         bearing the name, trademarks and/or images of the College, each Garment Contractor must comply with this Code and ensure that its         subcontractors, vendors and/or manufacturers comply with this Code.

1. Initial Phase-In of the Code: At the direction of the President of Occidental College, all persons or entities who are currently authorized by the College to manufacture garments bearing the name, trademarks and/or images of Occidental College will be notified of the Code.
    1. Upon receipt of notification of this Code, the Garment Contractor must provide such written assurances that it and its subcontractors, vendors and/or manufacturers acknowledge and agree to adhere to this Code.


    B. Written reports: Upon written request of the College, the Garment Contractor shall be required to provide the following to Occidental College:

1. The company names, owners and/or officers, addresses, phone numbers, e-mail addresses and nature of the business association, including the steps performed in the manufacturing process, of all of the Garment Contractors’ contractors and manufacturing plants which are involved in the manufacturing process of items which bear, or will bear, the name, trademarks and/or images of Occidental College;

2. Written assurances that it and its contractors adhere to this Code.

3. A summary of the steps taken, and/or difficulties encountered, during the preceding year in implementing and enforcing this Code at each site.
    1. If these reports are provided to the College in a language other than English, the Garment Contractor must provide the original report as well as English translation.
5. Such written reports shall become the sole property of Occidental College, filed with the Director of Occidental College Emblematic Contracting and shall be available to the Occidental community as stated in Section VI. Disclosure. C. Notification. All Garment Contractors and their subcontractors, vendors and/or manufacturers shall notify their employees of the existence of the Code and make copies of the Code available to employees upon request, written in languages(s) which employees understand.

D. Pricing. The Garment Contractor must assure that they are paying their subcontractors, vendors and/or manufacturers a sufficient price to meet production costs while complying with this Code and to make a reasonable profit.

 VI. Disclosure: Information provided by the Garment Contractor, as described in Section V. Implementation, shall become the sole property of Occidental College.
  1. Information provided in Section VB 1.: The company names, owners and/or officers, addresses, phone numbers, e-mail addresses and nature of the business association, including the steps performed in the manufacturing process, of all of the Garment Contractors’ contractors and manufacturing plants which are involved in the manufacturing process of items which bear, or will bear, the name, trademarks and/or images of Occidental College will be filed with the Director of Occidental College Emblematic Contracting.
    1. The information will be made available to the Occidental Community through any or all of the following: the Board of Trustees, Officers of the College, President of the ASOC, President of the Faculty Council, Convenor of the Administrative Council, Convener of the Staff Council and the Director of Occidental College Emblematic Contracting.
  1. Information provided in Sections V.B.2 and V.B.3. Will be filed with the Director of Occidental College Emblematic Contracting and be available to the Occidental Community.
VII. Verification and Compliance Mechanism: It shall be the responsibility of each Garment Contractor to ensure its compliance with this Code, and to verify that its subcontractors, vendors and/or manufacturers are in compliance with this Code. It shall be the responsibility of the college to ensure its compliance with this Code and verify that the Occidental Community adheres to this Code.
  1. Internal Monitoring and training: The President of Occidental College will establish an Emblematic Contractors Review Board. It will be the responsibility of this Board to advise the President regarding the provision of training and the establishment of internal monitoring procedures to insure adherence to the Code by members of the Occidental community.
  1. Membership of the Review Board shall include but will not be limited to three representatives of the ASOC and one representative from each of the following: the Office of Student Life, Athletics, Facilities, Campus Dining, Admissions, Development, Bookstore, Business Office and the Faculty. ASOC representatives will be nominated by the ASOC and all others will be nominated by CAC. The President will appoint membership from those nominations submitted.
  2. The Review Board in conjunction with the ASOC and CAC insure that:
    1. The Occidental Community is provided with adequate training regarding the Code.
    2. A method of internal monitoring is established and maintained.
  1. External Monitoring: At the direction of the President, the Review Board in conjunction with the ASOC and CAC will explore a means of independent external monitoring, investigation, receipt and processing of Garment Contractor employee complaints, adjudication of disputes, and mechanisms for external enforcement of this Code. These findings will be presented to the President.
  1. Public Accountability. Occidental College shall establish a procedure to include students, faculty, staff and administrators in the development of this Code and the oversight of its verification.
  1. The Code of Conduct for Occidental College Garment Contractors shall be published on the College website
  2. A listing of authorized Occidental College Garment Contractors shall be maintained by the Director of Occidental College Emblematic Contracting and shall be published on the College website.
IX. Funding A. All expenses incurred for the establishment, implementation and maintenance of this Code will be funded at the discretion of the President of Occidental College.


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