VERIFICATION
To ensure that Poncho's product supply chains do not use goods produced by forced or child labor, factories are required to go through an approval process before joining our supply chain. This includes working with our Production and Quality departments to confirm factories meet company standards.
As part of this process, new and existing factories are audited by independent, third-party monitoring firms, which includes evaluating potential risks for human trafficking. The auditors are also monitoring to ensure that if the factory uses an employment agency, the factory and employment agency are in compliance with all local laws and legislations. Any non-compliance is immediately brought to the attention of our leadership, and Poncho requires the factory’s immediate action towards correction. New factories must hold 3rd party audit verification prior to beginning Poncho production. Existing factories are audited once per year but can visited or inspected more if required based on the factory’s performance.
AUDITING
To ensure all the factories within Poncho’s supply chain are fulfilling their obligation to Poncho’s Vendor Code of Conduct, we require that all vendors utilize independent, third-party monitoring firms for regular internal inspections. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). All factories are audited once per year, but we can visit more or less depending on the factory’s performance. To maintain the integrity of the audit, all audits are unannounced with no prior notice given to the factory team towards audit timing.
CERTIFICATION
Vendors are required to maintain certification which warrant that the products they supply to Poncho are manufactured in accordance with all applicable laws, regulations and standards – both of the United States as well as their country of origin. When a vendor accepts a purchase order, they are confirming their compliance with our Poncho’s Code of Conduct and our zero-tolerance stance on human trafficking and forced labor.
INTERNAL ACCOUNTABILITY
Poncho has a zero-tolerance policy for forced labor, human trafficking, and child labor. If any of these findings are uncovered during an audit, the factory will take immediate corrective actions to remediate the issue prior to beginning production. The factory is required to alert Poncho to all actions taken to correct the issue and work directly with the Poncho Director of Production and Senior Quality Manager to ensure there are no recurrences. In addition, subsequent audits performed at the factory will reference the factory’s corrective plan to confirm the issue has been resolved.
TRAINING AND AWARENESS
All managers directly involved in Supply Chain or Production Management are required to take a training course on human trafficking and slavery that discusses the risks of human trafficking for business, and actions that can be taken to mitigate the risks.
All Poncho vendors have dedicated compliance teams responsible for ensuring compliance against Poncho Code of Conduct. Vendor compliance teams are also responsible for internal training on human trafficking and slavery, particularly with respect to mitigating risks within their own networks.
