Ethical Maturity Framework (EMF)

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.

The EMF also supports brands by:

  • Supporting 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 and, for apparel brands, the proposed Garment Trade Adjudicator.
  • Ensuring the integrity and reputation of the Fast Forward Programme is maintained which in turn benefits all Brand Members through their membership of a well-respected, independent and trusted programme.

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 brands.

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.


Section 1: Brand Engagement

Area Foundation KPI Supporting evidence Additional explanation 
1. Brand Engagement  1.1 Brand lead participates in Steering Group meetings Source: Fast Forward  
Evidence: attendance record 
Brands are expected to demonstrate >60% attendance 
1. Brand Engagement    1.2 Brand Directors regularly receive updates regarding the Fast Forward Programme Source: Brand 
Evidence: communication to Directors on Fast Forward’s developments (e.g., regular update emails, internal newsletter, meeting notes/presentations) 
Brand to show/explain how the requirement is met during the 1-2-1 session 
1. Brand Engagement  1.3 Brand lead participates in at least one Fast Forward learning session per year Source: Fast Forward  
Evidence: attendance record 
Brands can attend the peer-to-peer sessions or the supplier training depending on their learning needs 
1. Brand Engagement  1.4 Brand lead participates in all one-to-one sessions (twice per year) Source: Fast Forward  
Evidence: attendance record 
1-2-1 sessions are held in May and November  


Section 2: Human Rights Due Diligence (HRDD) & Transparency

Area Foundation KPI Supporting evidence Additional explanation 
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.  Source: Brand 
Evidence: Brand’s own tracking system  
Brand to show/explain its tracking system during the 1-2-1 session 
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. Source: Fast Forward  
Evidence: CRM data 
Member Brands need to demonstrate that >85% of Tier 1 supply chain businesses and intermediary suppliers are enrolled into the Supplier Engagement Programme or provisions have been made to have them enrolled 
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 in two stages: 
i. Within 12 months audit 50% of in-scope suppliers 
ii. Within 18 months audit 100% of in-scope suppliers 
 
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. 
Source: Fast Forward 
Evidence: CRM data 
Member Brands need to demonstrate that >85% of Tier 1 CMT supply chain businesses have been audited by Fast Forward or provisions have been made to have them audited. 
2. HRDD & Transparency 2.4 Member updates in-scope supply chain businesses twice per year (by 1st April and 1st October) Source: Fast Forward 
Evidence: site list submission tracker 
Fast Forward will issue links and reminders 
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) 
Source: Brand 
Evidence: link to public site list. Supplier lists should be published in a spreadsheet or other searchable format. Brands should also consider submitting supplier information to the Open Supply Hub. 
Fast Forward will issue the request one month ahead. If the site list is not returned by the deadline, this requirement will be considered not met. 
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. Source: Brand 
Evidence: e.g., site visit log (incl. visit date, delegates’ names, report/briefing on checks carried out and major outstanding issues identified), audits, follow-up audits, desktop/remote follow-up 
The visits can be carried out by the Lead or Shared Brand 
 
The Lead Brand is the ultimate responsible for keeping records of the visits. Fast Forward audits taking place in that year count toward this requirement provided that a brand representative is present during the audit   Brands signs a self-declaration   
2. HRDD & Transparency 2.7 Member has a system in place to identify all UK production locations, including a policy for unauthorised subcontracting Source: Brand 
Evidence: Members need to provide a copy of their policy and process on unauthorised subcontracting  
Methods to identify unauthorised subcontracting include care label, capacity and purchase order checks during (un)announced visits.  
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.   Source: Brand 
Evidence: Pre-audit risk assessment, presence of brand representative during audit  
Brand to explain how the requirement is met during the 1-2-1 session 
2. HRDD & Transparency 2.9 Member acts as Lead Brand as outlined in General Regulations 2.10.1 Source: Brand 
Evidence: Progress update on selected suppliers  
Before the assessment, Fast Forward will make a selection of Tier 1 suppliers the Member is the Lead Brand for 
 
During the assessment, Fast Forward will ask questions to verify the Lead Brand Responsibilities under 2.10.1 of the General Regulations have been met 
2. HRDD & Transparency 2.10 Member acts as Shared Brand as outlined in General Regulations 2.10.2 Source: Brand 
Evidence: Progress update on selected suppliers  
Before the assessment, Fast Forward will make a selection of suppliers the Member is the Shared Brand for 
 
During the assessment, Fast Forward will ask questions to verify the Shared Brand Responsibilities under 2.10.2 of the General Regulations have been met 

Section 3: Remediation

Area Foundation KPI Supporting evidence Additional explanation 
3. Remediation 3.1 Member appoints a person and has a procedure in place to handle whistleblowing cases Source: Brand 
Evidence: Whistleblowing policy and procedure for suppliers’ and workers’ grievances 
Brand submits evidence of whistleblowing policy and procedure. The brand is able to articulate how their whistleblowing procedures work in practice 
3. Remediation 3.2 Member has a system to follow up on audit reports and corrective action plans Source: Brand 
Evidence: Member’s management system (e.g., digital platform, Excel) for audit and progress with corrective actions and a plan for follow-up audits in accordance with audit outcomes/risk 
Brand to show/explain its tracking system during the one-to-one 

Section 4: Purchasing Practices

Area Foundation KPI Supporting evidence Additional explanation 
4. Purchasing Practices 4.1 Brand lead and at least one buying team representative attend Fast Forward Brand Training (once per year)  Source: Fast Forward 
Evidence: CRM data 
2024 Brand training to be confirmed 
4. Purchasing Practices 4.2 Member has a Responsible Exit Policy in place Source: Brand 
Evidence: Responsible Exit Policy  
Brand submits evidence of the responsible exit policy in place. Fast Forward reviews the content of the policy and provides advice on possible improvements if necessary 

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