The Ethical Maturity Framework (EMF) has been developed to support Brand Members* to demonstrate their engagement with the Fast Forward Programme and their continuous efforts and progress in improving labour conditions in their UK supply chains.
Until now, the Foundation Level of the EMF has been developed, which establishes a set of foundational requirements. The EMF supports brands in their wider efforts on responsible sourcing, human rights due diligence, current legal requirements such as Modern Slavery Act reporting, and to future proof for potential new legal requirements such as mandatory human rights due diligence.
Our approach is to work supportively with Brand Members to make continuous improvement and the expectations we set seek to balance meeting and exceeding industry best practice alongside setting realistic timeframes for improvements that reflect the maturity and capacity of each brand.
ETHICAL MATURITY FRAMEWORK – FOUNDATION LEVEL
Section 1: Brand Engagement
| Area | Foundation KPI |
| 1. Brand Engagement | 1.1 Brand lead participates in Steering Group meetings |
| 1. Brand Engagement | 1.2 Brand Directors regularly receive updates regarding the Fast Forward Programme |
| 1. Brand Engagement | 1.3 Brand lead participates in at least one Fast Forward learning session per year |
| 1. Brand Engagement | 1.4 Brand lead participates in all one-to-one sessions (twice per year) |
Section 2: Human Rights Due Diligence (HRDD) & Transparency
| Area | Foundation KPI |
| 2. HRDD & Transparency | 2.1 On joining, Member develops a training and audit plan at a minimum for all Tier 1 CMT businesses and intermediary suppliers (for which it is Lead Brand) within 6 months. |
| 2. HRDD & Transparency | 2.2 On joining Member arranges for >85% of Tier 1 CMT supply chain businesses (for which it is the Lead Brand) to enroll in the Supplier Engagement Programme and attend the Fast Forward Supplier Training within 9 months; and for intermediary suppliers within 12 months. After 3 months in the Fast Forward Programme, any new supply chain businesses (Tier 1 CMTs and intermediary suppliers) should be enrolled and trained within 6 months. |
| 2. HRDD & Transparency | 2.3 On joining, Member arranges for >85% of Tier 1 CMT supply chain businesses (for which it is the Lead Brand) to be audited within 18 months. After 6 months in the Fast Forward Programme, the Members must arrange for any new in-scope supply chain businesses (for which it is the Lead Brand) to be audited within 12 months. |
| 2. HRDD & Transparency | 2.4 Member updates in-scope supply chain businesses twice per year (by 1st April and 1st October) |
| 2. HRDD & Transparency | 2.5 Member provides evidence of public supplier list (in line with the Transparency Pledge standards) twice per year (1st April and 1st October) |
| 2. HRDD & Transparency | 2.6 At a minimum, all Tier 1 CMT supply chain businesses are visited twice per year by the Lead or Shared Brand as part of its systems to continuously monitor human/labour rights risks in their UK supply chain. |
| 2. HRDD & Transparency | 2.7 Member has a system in place to identify all UK production locations, including a policy for unauthorised subcontracting |
| 2. HRDD & Transparency | 2.8 Member and audit body(ies) work in partnership on safe systems of work and provide support to audit bodies in case of high risk sites. |
| 2. HRDD & Transparency | 2.9 Member acts as Lead Brand as outlined in General Regulations 2.10.1 |
| 2. HRDD & Transparency | 2.10 Member acts as Shared Brand as outlined in General Regulations 2.10.2 |
Section 3: Remediation
| Area | Foundation KPI |
| 3. Remediation | 3.1 Member appoints a person and has a procedure in place to handle whistleblowing cases |
| 3. Remediation | 3.2 Member has a system to follow up on audit reports and corrective action plans |
Section 4: Purchasing Practices
| Area | Foundation KPI |
| 4. Purchasing Practices | 4.1 Brand lead and at least one buying team representative attend Fast Forward Brand Training (once per year) |
| 4. Purchasing Practices | 4.2 Member has a Responsible Exit Policy in place |
* Please note, Brand Associates have access to the Ethical Maturity Framework to support their due diligence, but are not obliged to achieve the requirements until they automatically transition to become a full Brand Member in year three, or if they apply to become a Brand Member in year two.
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