Frequently Asked Questions – FAQ
Frequently Asked Questions – FAQ
What should I do?
There are essentially two steps to start the program:
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Why has a Licensing Company notified me that my company is being required to participate in the Ethical Supplier Engagement Program in order to remain licensed with a University(ies) for whom my license was recently reviewed at renewal
A: This step has been taken in response to a Questionnaire submitted by your company, as part of the annual review of your license with the University(ies). The Ethical Supplier Engagement program is being required in order to help your company fully assess, implement, and credibly verify the codes of conduct required by the university(ies) throughout your company’s supply chain. Sumerra, a corporate social responsibility and compliance management company, is conducting the program.
A: This step has been taken in response to a Questionnaire submitted by your company, as part of the annual review of your license with the University(ies). The Ethical Supplier Engagement program is being required in order to help your company fully assess, implement, and credibly verify the codes of conduct required by the university(ies) throughout your company’s supply chain. Sumerra, a corporate social responsibility and compliance management company, is conducting the program.
Q: What is Sumerra and what do they do?
A: Sumerra is an ethical compliance consulting company that helps organizations manage implementation of their codes of conduct throughout their businesses. From small and medium sized licensees to large multinational corporations, Sumerra provides resources and assistance to help manage internal monitoring of supply chains. Sumerra’s website (www.sumerra.com) has additional information regarding who they are and the nature of their work.
A: Sumerra is an ethical compliance consulting company that helps organizations manage implementation of their codes of conduct throughout their businesses. From small and medium sized licensees to large multinational corporations, Sumerra provides resources and assistance to help manage internal monitoring of supply chains. Sumerra’s website (www.sumerra.com) has additional information regarding who they are and the nature of their work.
Q: Why is my company being asked to be in the Ethical Supplier Engagement Program?
A: At the sole discretion of the University(ies) that request your company’s participation, various factors were considered in making this decision, including, among other criteria, a demonstrated need for credible monitoring of your company’s supply chain partners. The Ethical Supplier Engagement Program was created in response to requests from licensees/vendors to get assistance in credibly monitoring the workplaces within their supply chains. The reason that this is important is as follows: without credible monitoring as a starting point, an organization is not able to fulfill on its contractual agreement to implement University(ies) codes of conduct throughout the supply chain.
A: At the sole discretion of the University(ies) that request your company’s participation, various factors were considered in making this decision, including, among other criteria, a demonstrated need for credible monitoring of your company’s supply chain partners. The Ethical Supplier Engagement Program was created in response to requests from licensees/vendors to get assistance in credibly monitoring the workplaces within their supply chains. The reason that this is important is as follows: without credible monitoring as a starting point, an organization is not able to fulfill on its contractual agreement to implement University(ies) codes of conduct throughout the supply chain.
Q: How is my company’s performance in corporate responsibility awareness, engagement and management measured?
A: Your company’s annual response to the Licensing Questionnaires, responsiveness to publicly available monitoring reports, and accuracy and frequency of factory disclosure information and updates to these data are all reviewed in measuring performance.
A: Your company’s annual response to the Licensing Questionnaires, responsiveness to publicly available monitoring reports, and accuracy and frequency of factory disclosure information and updates to these data are all reviewed in measuring performance.
Q: My company is a Fair Labor Association (“FLA”) Affiliate in good standing. How does this requirement fit in?
A: Many universities are affiliates of the FLA and require that their licensees affiliate with the FLA in the appropriate collegiate licensee affiliation category. The FLA is an organization whose work involves verification that its large company affiliates have compliance programs that meet FLA criteria, and its role does not extend to conducting monitoring of each affiliate’s entire supply chain.Universities expect their Licensees/Vendors to fulfill their institution’s code of conduct requirements throughout the Licensee’s/Vendor’s supply chain. This requires the licensee to have systems and processes implemented that credibly assess the degree to which University Codes of Conduct are in operation throughout their supply chain, that any gaps in compliance that the monitor finds are remedied, and that these steps are verified to have been sustained over time. The Ethical Supplier Engagement Program is designed to help Licensees/Vendors begin the monitoring process in a credible, guided manner.
A: Many universities are affiliates of the FLA and require that their licensees affiliate with the FLA in the appropriate collegiate licensee affiliation category. The FLA is an organization whose work involves verification that its large company affiliates have compliance programs that meet FLA criteria, and its role does not extend to conducting monitoring of each affiliate’s entire supply chain.Universities expect their Licensees/Vendors to fulfill their institution’s code of conduct requirements throughout the Licensee’s/Vendor’s supply chain. This requires the licensee to have systems and processes implemented that credibly assess the degree to which University Codes of Conduct are in operation throughout their supply chain, that any gaps in compliance that the monitor finds are remedied, and that these steps are verified to have been sustained over time. The Ethical Supplier Engagement Program is designed to help Licensees/Vendors begin the monitoring process in a credible, guided manner.
Q: How much will the Sumerra program cost?
A: There will be a cost associated with the Sumerra program. The cost will be variable; it is based on the size of the supply chain that is included in the program, as each monitoring engagement will have an individual charge. Sumerra will provide detailed information as you register for the program and any sources that your company may have in common with other licensees or brands for which Sumerra works are identified. In cases where there is overlap, cost savings can be realized.
A: There will be a cost associated with the Sumerra program. The cost will be variable; it is based on the size of the supply chain that is included in the program, as each monitoring engagement will have an individual charge. Sumerra will provide detailed information as you register for the program and any sources that your company may have in common with other licensees or brands for which Sumerra works are identified. In cases where there is overlap, cost savings can be realized.
Q: Who pays for this service?
A: Sumerra will invoice the Licensee/Vendor directly for this service. All Sumerra fees are paid prior to work commencing. Some Licensee/Vendors choose to pay for this entire service directly, while others share these costs, as appropriate, with their supply chain partners.
A: Sumerra will invoice the Licensee/Vendor directly for this service. All Sumerra fees are paid prior to work commencing. Some Licensee/Vendors choose to pay for this entire service directly, while others share these costs, as appropriate, with their supply chain partners.
Q: May my company manage its own monitoring program as part of the Ethical Supplier Engagement Program?
A: Over time and with experience, it may be possible for a Licensee/Vendor to either manage its own program or remain assisted by Sumerra if it wishes to do so. At the outset of the program, Sumerra will review your company’s current level of involvement and determine the degree to which your program meets University(ies) requirements in sufficient depth and breadth. As your company participates in the program and gains momentum, it may be possible to transition to a program that is managed internally.
A: Over time and with experience, it may be possible for a Licensee/Vendor to either manage its own program or remain assisted by Sumerra if it wishes to do so. At the outset of the program, Sumerra will review your company’s current level of involvement and determine the degree to which your program meets University(ies) requirements in sufficient depth and breadth. As your company participates in the program and gains momentum, it may be possible to transition to a program that is managed internally.
Q: How long will my company be in the Ethical Supplier Engagement program?
A: The program will last at least one year. The university(ies) will assess each renewal independently, therefore, it is unknown how long your organization will be required to be in the program.
A: The program will last at least one year. The university(ies) will assess each renewal independently, therefore, it is unknown how long your organization will be required to be in the program.
Q: What is required as a part of the Ethical Supplier Engagement program?
A: Items may include (Note that Sumerra will assist and manage much of this work): Annual monitoring of the supply chain; mitigating and remediating issues found during the audit; root cause analysis, improvement of licensees’/Vendors’ and/or Licensee/Vendor supplier factories and intermediaries’ code of conduct; and other needed program improvements and facilitation of best practices.
A: Items may include (Note that Sumerra will assist and manage much of this work): Annual monitoring of the supply chain; mitigating and remediating issues found during the audit; root cause analysis, improvement of licensees’/Vendors’ and/or Licensee/Vendor supplier factories and intermediaries’ code of conduct; and other needed program improvements and facilitation of best practices.
Q: What happens if one of our factories “fails” an audit?
A: With the exception of certain “Zero Tolerance” Issues, there is no “failure” at this point. Rather, each finding of a gap between the code and the practices within a factory are opportunities for improvement. University(ies) are committed to ensuring your factories have the opportunity to improve working conditions, including providing the necessary time needed to create and implement sustainable solutions. Factories will be expected to provide realistic improvement plans to any issues arising from an assessment conducted within the program and will be expected to improve through time with your support and encouragement.
A: With the exception of certain “Zero Tolerance” Issues, there is no “failure” at this point. Rather, each finding of a gap between the code and the practices within a factory are opportunities for improvement. University(ies) are committed to ensuring your factories have the opportunity to improve working conditions, including providing the necessary time needed to create and implement sustainable solutions. Factories will be expected to provide realistic improvement plans to any issues arising from an assessment conducted within the program and will be expected to improve through time with your support and encouragement.
Q: What is a Zero Tolerance Issue?
A: Zero Tolerance Issues are those that are causing, or may cause, immediate and serious harm to workers, local communities and/or environments, and/or severe negative impact to associated stakeholders (including Universities and Licensees). Examples include, but are not limited to: safety issues that are a potential cause for loss of life (locked or not enough exits that may cause loss of life, unprotected fire sources, etc.), immediate and severe environmental damage (uncontrolled hazardous materials release, etc.), severe worker mistreatment (systemically under-paying workers, physically abusing workers, etc.), or other similar situations (systemic use of underage workers, extreme overtime, unfairly targeting and mistreating a minority group of workers, etc.). Note: For Notre Dame, a Zero Tolerance issue also includes Freedom of Association (FOA) violations.
A: Zero Tolerance Issues are those that are causing, or may cause, immediate and serious harm to workers, local communities and/or environments, and/or severe negative impact to associated stakeholders (including Universities and Licensees). Examples include, but are not limited to: safety issues that are a potential cause for loss of life (locked or not enough exits that may cause loss of life, unprotected fire sources, etc.), immediate and severe environmental damage (uncontrolled hazardous materials release, etc.), severe worker mistreatment (systemically under-paying workers, physically abusing workers, etc.), or other similar situations (systemic use of underage workers, extreme overtime, unfairly targeting and mistreating a minority group of workers, etc.). Note: For Notre Dame, a Zero Tolerance issue also includes Freedom of Association (FOA) violations.
Q: My Company is not being required to participate in the Ethical Supplier Engagement program in order to remain licensed with a University(ies). Can we choose to participate?
A: Yes. As noted, Sumerra performs this work for many organizations, and would encourage any organization that is interested to contact Sumerra directly about having it assist your organization. In addition, Sumerra offers additional services that you and your suppliers may choose to utilize to improve the conditions in the supply chain.
A: Yes. As noted, Sumerra performs this work for many organizations, and would encourage any organization that is interested to contact Sumerra directly about having it assist your organization. In addition, Sumerra offers additional services that you and your suppliers may choose to utilize to improve the conditions in the supply chain.