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MODERN SLAVERY STATEMENT 2022

At Under Armour, Inc. (“UA”), we are committed to championing the rights of those who create, make, wear, use, promote, and connect to our products. Ensuring our supply chain and operations are free from modern slavery is our responsibility. As a global brand, we follow the United Nations Guiding Principles on Business and Human Rights (“UNGP”) to guide how we conduct human rights due diligence to prevent and, if applicable, remediate modern slavery in our supply chain. The term modern slavery encapsulates slavery, servitude, forced or compulsory labor, human trafficking, debt bondage, and forced marriage. We are committed to continuously improving our performance and reporting related to our efforts to mitigate risks of modern slavery in our supply chain. This 2022 Modern Slavery Statement is published pursuant to the Modern Slavery Act 2015 (“UK MSA”), the California Transparency in Supply Chain Act of 2010 (“CA TSCA”) and the Australian Modern Slavery Act 2018 (“AUS MSA”). Although our Australian subsidiary, UA Australia Pty Ltd (“UA Australia”), has not met the relevant financial threshold in its most recent reporting period to qualify it as a reporting entity under the AUS MSA, consistent with our commitment to tackle modern slavery, we have made the decision to report voluntarily. Our social and labor compliance program and human rights due diligence processes and procedures described in this statement apply equally to UA Australia and its operations. This statement has been approved and signed by the Boards of Directors of our subsidiaries in the United Kingdom, Under Armour UK Limited (“Under Armour UK”) and UA UK Retail Limited (“UA UK Retail”), and UA Australia. It summarizes steps taken by UA and its subsidiaries during the fiscal year ending 31 December 2021 to assess and address risks of modern slavery in our business and supply chain.

OUR VALUES

Our team works to make products that power the performance of athletes for a better world. We expect our suppliers and subcontractors to do business in a manner that aligns with our core values: Love Athletes, Celebrate the Wins, Stand for Equality, Act Sustainably, and Fight on Together. This means that each of our suppliers and subcontractors must treat their employees with dignity and respect and provide safe workplace and dormitory conditions.

STRUCTURE, OPERATIONS AND SUPPLY CHAIN

Our principal business activities are developing, marketing, and distributing branded performance apparel, footwear, and accessories for men, women, and youth. Our products are engineered in many designs and styles for use in nearly every climate and are worn worldwide by athletes at all levels, from youth to professional, on various playing fields around the globe and by consumers with active lifestyles.

Incorporated as a Maryland corporation in 1996, we have registered trademarks around the globe, including UNDER ARMOUR®, HEATGEAR®, COLDGEAR®, HOVR™ and the Under Armour Logo. Substantially all our products are manufactured by unaffiliated third-party manufacturers who work directly with us as business partners, or indirectly, through UA licensees or an agent. Together with these business partners and those who work for them, we strive to work together as a single global team.

We publish a supplier list of strategic and specialty vendors. This list was last updated in June 2021 and reflects over 90 percent of our business. It includes our direct Tier 1 (“T1”) suppliers globally by location and is disclosed in alignment to the Transparency Pledge, as it includes the country, address, company name, number of workers, and product type of each factory in a searchable spreadsheet format.

UA ENTITIES IN THE UNITED KINGDOM AND AUSTRALIA

Entity Name UA Australia PTY LTD Under Armour UK Limited UA UK Retail Limited
Employee Count 250+ 40+ 210+
Operations Summary UA Australia Pty Ltd (“UA Australia”) is an indirect, wholly owned subsidiary of Under Armour, Inc. UA Australia provides sales and marketing support of the UA brand in Australia. UA Australia also sells UA products, including apparel, footwear, and accessories, in UA branded Factory and Brand House stores in Australia. Under Armour UK Limited (“Under Armour UK”) is an indirect, wholly owned subsidiary of Under Armour, Inc. Under Armour UK Limited assists with marketing efforts in the United Kingdom and identifies, facilitates the pursuit of, and provides ongoing support for local third-party distribution partners. UA UK Retail Limited (“UA UK Retail”) is an indirect, wholly owned subsidiary of Under Armour, Inc. UA UK Retail is responsible for the retail distribution of UA products, including apparel, footwear, and accessories, in UA branded Factory and Brand House stores in the United Kingdom.

 

2021 STATS

2021 Stat Chart
(AS OF 12/31/2021)

BEYOND COVID-19

In 2020 and 2021, many of our workstreams were impacted by the immediate and longer-term effects of COVID-19, particularly those in relation to our suppliers and workers. During this time, we prioritized the health and safety of not only our employees, but also the employees of our suppliers, but requiring our suppliers to take appropriate and advisable steps to protect their employees’ health and safety, including complying with local legal obligations related to COVID-19.

The UA sustainability team developed and deployed electronically the Worker Protection & Infection Control Self-Assessment & Management Plan (“WPICSA”), which aimed to assist our suppliers to develop systems to protect workers and potentially reduce COVID-19 infections and provided guidance related to COVID-19, including local government directives and recommendations from expert organizations. We sent the WPICSA to all our T1 vendors and suppliers and required them to take steps to safeguard the health and safety of their workers and to maintain related documentation of such work.

As a result of new COVID-19 waves posing challenges in some manufacturing locations, in the summer of 2021, the UA sustainability team led another engagement with our suppliers. Though this engagement, we asked our suppliers for their commitment to protect the health and safety of their workers by taking all steps required by applicable law or government regulations, and to consider the WPICSA expert recommendations. 

Given the complexity and global nature of our industry, we are committed to ongoing dialogue with other stakeholders including brands, multi-stakeholders, and industry organizations on these issues and are exploring additional means to support workers. We endorsed the International Labour Organization’s (“ILO”) Call to Action, COVID- 19: Action in the Global Garment Industry. Additionally, we serve on the ILO’s Working Group and International Financial Institution Engagement Task Force where we work with like-minded parties to mobilize funds to support business continuity for manufacturers in the apparel and footwear sectors and focus on protecting workers and employers in countries with the weakest health and social protection systems. This is a multi-stakeholder initiative and features the International Employers Association, global trade unions, brands, and suppliers. As COVID-19 related pressures evolve, we continue to assess how we can support workers in our supply chain.

NOTABLE POLICIES

Our sustainability strategy encompasses three strategic pillars (Products, Team, and Home Field) within our Sustainability Business Integration model, which has been endorsed by our Executive Leadership team and shared with the Corporate Governance and Sustainability Committee of our Board of Directors. Our social compliance and human rights due diligence work falls under the Team pillar and is part of our effort to protect the people who make, use, and wear our products, their components, and materials, as well as to add value to communities. Our goals related to this workstream include being reaccredited by the Fair Labor Association (“FLA”), developing social compliance and human rights standards and initiatives for our strategic suppliers, and implementing an evolving corporate-wide human rights program pursuant to the Under Armour Human Rights Commitment (“UA HRC”).

The UA Supplier Code of Conduct  (“UA Code”) reflects ILO’s Conventions and Recommendations and includes provisions on Forced Labor, Compensation, Hours of Work, Freedom of Association and Collective Bargaining, Nondiscrimination, Harassment or Abuse, Non-Retaliation, Reporting Potential Misconduct, and Sustainable Business Practices. The UA Code sets forth expectations for the protection of workers and seeks to mitigate risks, including those related to modern slavery. We recently developed and published the Under Armour, Inc. Global Human Rights Commitment which outlines our dedication to promoting and respecting the rights of those throughout our value chain. (See Box 1.)

Box 1. Under Armour Human Rights Commitment: 

The Under Armour, Inc. Global Human Rights Commitment (“UA HRC”)  outlines our dedication to promoting and respecting the rights of the people who create, make, wear, use, promote, and connect to our products. After extensive work in partnership with third-party experts to understand our human rights risks across our supply chain, we published the UA HRC to formalize our commitments to adhere to international human rights frameworks; to respect human rights throughout our operations, our value chain, our digital products, our communities, and our environment; and to provide a remedy to those impacted by our operations. The UA HRC was approved by our Sustainability Leadership Council, our Executive Leadership team and the Corporate Governance and Sustainability Committee of our Board of Directors.

As part of our responsible sourcing strategy and commitment to operational excellence, we formalized and deployed our Responsible Sourcing Policy (“RSP”) in 2018. Our RSP supports our commitment as an FLA Accredited Company to the FLA Principles of Fair Labor and Responsible Sourcing. Our RSP’s elements reflect the complexities of our supply chain, and place an emphasis on financial and contractual terms, balanced planning, accountability, training, communication, and review. Our ongoing work related to our RSP is described in Box 2.

Based on engagements with vendors and facilities employing migrant workers, and engagements and learnings cultivated from extensive work with migrant labor experts around the world, we have built on the pre-existing requirement that suppliers comply with the Institute for Human Rights and Business’ Dhaka Principles for Migration with Dignity (the “IHRB Dhaka Principles”). At the center of this work is the development and deployment of our Migrant Worker Policy & Standards (“MWPS”) that requires our suppliers to practice responsible recruitment, including ensuring that migrant workers obtain work free of coercion, deception, fees, and debt. (Box 2)

Box 2. Responsible Sourcing and Recruitment:

Updated Responsible Sourcing Policy: Since launching our RSP in 2018, we have engaged in several initiatives to assess our performance within responsible sourcing and to apply principles of responsible sourcing to address supply chain conditions amidst the COVID-19 pandemic. One of these initiatives, through the Better Buying Institute, which we refer to as “Supplier Voice,” allows our suppliers to identify areas where we can improve confidentially and anonymously. Additionally, we continue to update and enhance our RSP policy to incorporate lessons learned from assessments and engagements with peers and stakeholders, improve stakeholder reports and expand analyses on responsible sourcing.

Migrant Worker Policy & Standards: In January 2021, we published our MWPS, which was reviewed by external third-party experts, including VeritéThe Mekong  Cluband Impactt. Our MWPS addresses topics including the ILO’s forced labor indicators, the “Employer Pays” Principle and requirements that employers and suppliers ensure the protection and equitable treatment of migrant workers across the worker employment life cycle. This includes outlining responsible recruitment, ensuring migrant workers retain control of their personal identification document, and prohibiting free and reduced labor cost programs.

AREAS OF RISK AND DUE DILIGENCE

We remain committed to improving the systems we have in place to identify and address human rights-related risks, including those related to modern slavery. We periodically update these systems based on findings from third-party assessments and engagements with suppliers, external stakeholders, and third-party experts. Updates are also based on information from organizations like the FLA, knowledgeable stakeholders, and organizations, and are based upon the results from risk mapping exercises that focus on salient human rights risks, the presence of vulnerable groups, and/or sourcing location risks. See Box 3 for a high-level summary of our systematic approach.

Box 3. Human Rights Supply Chain Risk Management Model

Supporting Continuous Improvement

AREAS OF RISK AND DUE DILIGENCE CHART

 

 

Generally, in conducting our due diligence, risks can include: payment of recruitment fees, below standard dormitory/living conditions, low oversight of recruitment agencies’ recruitment practices, passport retention, contract substitution, employment contract in languages not spoken/understood by workers and low awareness in wage and benefits calculation. Our human rights due diligence process includes a country-level risk model for new sourcing countries. This tool scores countries against factors including perceived general governance capacity, protection of fundamental human rights as outlined in the International Bill of Rights, and with respect to the ILO's Eight Core Conventions. We use this assessment tool when considering sourcing from a new country to help foster greater internal awareness of country-level risks and trends. It has also been used to enhance the company’s ability to engage with suppliers about related potential risks. Higher-risk countries where we have previously conducted further focused due diligence assessments include Egypt, Jordan, and Malaysia. (See remediation case study and Box 4 for an example in Malaysia.)

We identified a list of risks by conducting a materiality assesment informed by the Global Reporting Initiative (“GRI”) and other industry leading standards for apparel, footwear, and digital/IT business sectors. This list that is used for reporting includes Forced or Compulsory Labor; Child Labor; Freedom of Association and Collective Bargaining; Occupational Health and Safety; Fair Compensation (including Working Hours); and Non-Discrimination, Diversity and Equal Opportunity.

Our questionnaire-based assessment tool is based on the FLA Code and Benchmarks and the FLA’s Sustainable Compliance Initiative (SCI) tool helps us identify and manage risks that are salient to the apparel and footwear industry. Within the area of Forced and Compulsory Labor, the tool has questions related to the IHRB Dhaka Principles and the FLA/AAFA Principles of Responsible Recruitment, including around the recruitment and employment of migrant workers, possession and control of workers’ personal identification documents, wage payment, recruitment fees, deductions from pay, and other expenses.

We have previously consulted, and continue to work with, third-party human rights experts, such as Verité, Impactt, and Article One to ensure our assessments and global systems are comprehensive and identify salient human rights risks, including modern slavery. Following Impactt’s review of our assessment tool and assessment methodologies, we enhanced our assessment tool and methodologies to focus more on ILO’s core Forced Labor Indicators. In 2021, we provided third-party assessors the new tool and methodologies, which have been used to assess factories in sourcing countries, including those where migrant workers are employed. 

When needed, third-party audit firms review the question of whether suppliers work with recruitment agencies, employment brokers, and intermediaries. If the use of these entities is found, our assessment firms are directed to report on the nature and type of recruitment fees. All violations, including violations of the UA Code and the FLA Codes and Benchmarks and applicable laws, are documented so that we can directly address them with suppliers for improvement and remediation of systems, processes, and conditions, as needed over time.

CODES OF CONDUCT

At UA, we use the FLA’s Sustainable Compliance Initiative (SCI) methodology in our sustainability program as part of our efforts to advance workers’ rights through a continuous improvement model that applies to employment practices and working conditions. We expect our product supply chain business partners, including manufacturers, licensees and agents and their subcontractors, to comply with our UA Code, the FLA Workplace Code of Conduct and Compliance Benchmarks (the “FLA Code”), the IHRB Dhaka Principles and the AAFA/FLA Apparel and Footwear Industry Commitment to Responsible Recruitment that we signed in 2018. The UA Code is included in our manufacturing agreements that our suppliers must acknowledge and sign. Any violation of the Code may be construed as a breach of the Manufacturing Agreement and could lead to the termination of the business relationship between UA and the supplier. The UA Code’s Forced Labor provision states the following:

“Under Armour suppliers and their subcontractors shall not use forced labor, whether in the form of prison labor, indentured labor or bonded labor, or other forms of forced labor to make or perform work on Under Armour products or their components or materials or permit their suppliers to do so.”

The FLA Code and Benchmarks, the UA Code, and the FLA Code must be posted and communicated with factory employees in all facilities that make UA products. Our auditing program verifies that our suppliers comply with this requirement.

AUDITING

We have a supplier assessment program in place that evaluates the management, assessment, and remediation of supply chain social and labor issues. The program spans the entire “worker life cycle,” encompassing everything from how workers are hired to it, how, and when their employment with the supplier ends. The program reviews how employers perform their core management and employment functions, including whether effective policies and procedures are in place, and whether training, implementation and process responsibilities and updates are assigned. 

Factories manufacturing UA products are enrolled in this program and expected to be assessed annually for UA Code and FLA Code compliance, policy, standards, commitments, and legal compliance. We use the Under Armour Sustainability Assessment Tool and Report (“UASATR”) to evaluate active T1 suppliers and onboard suppliers prior to them being authorized to make our products. Every year we develop an assessment strategy and schedule and work primarily with FLA-accredited monitoring organizations and lead assessors to conduct these UASATR assessments. Generally, assessments are semi-announced with a two-week window and include evaluations of both a facility and related external facilities, such as dormitories.

In addition to UASATR assessments, the FLA conducts Independent External Assessments for some of our factories that fall within our FLA affiliation obligations, and publishes associated reports with the corresponding action plan on their website.

Starting in 2018, we also introduced focused migrant worker assessments of suppliers in high-risk sourcing locations. These focused assessments include an analysis of the recruiting and hiring practices of suppliers and intermediaries. In 2020 and throughout 2021, Impactt conducted some of these assessments with a focus on gathering information on potential forced labor issues in countries with migrant workers. These assessments, engagements, and related recommendations by Impactt and others, have yielded learnings for us about areas and/or indicators to focus on during these assessments, and are being addressed, as noted elsewhere herein, if, and as, issues are surfaced during them. These areas include assessing sub-contractors and sister factories, as well as improving communication and grievance system effectiveness.

In 2021, our supplier assessments also included Social and Labor Convergence Program (“SLCP”)’s assessments and verification and ILO’s Better Work Program assessments (where applicable). Under the SLCP, vendors, and their facilities complete self-assessments, and undergo third party verifications, annually. In the Better Work Program, facilities undergo Better Work assessment cycles and remediation/training programs.

ASSESSMENT REMEDIATION

We expect our suppliers’ factories to work to remediate issues raised during assessments or verifications and submit timelines and plans for how they propose to improve continuously conditions and work toward achieving sustainable compliance. For example, to ensure this occurs with respect to UASATR audits, auditors generate a Management Action Plan (“MAP”) for factory management that is discussed along with assessment findings as a part of a closing meeting. Utilizing MAPs, we engage with suppliers through a cloud-based platform to track recommendations for improvement and related progress. Once findings and recommendations are uploaded into the platform, UA’s sustainability team reaches out to management to support remediation.

The findings report may include country-specific requirements based upon human rights due diligence work, as well as requests for actions aimed at building UA Code and FLA Code awareness. Such actions may include requiring management to conduct periodic training sessions on both UA Code and FLA Code standards and benchmarks for workers, supervisors, and other employees in managerial positions. Once the suppliers receive the notification that the findings are available in the platform, they are responsible for addressing all the findings by reporting on short-term and long-term actions they have taken and uploading supporting documentation. Management responses and supporting documentation are then reviewed by the UA sustainability team. Throughout the remediation process, the UA sustainability team is in communication with the suppliers, and provides the suppliers with additional guidance, including MAP Response Guidance, MAP response Standard Operating Procedures, and Frequently Asked Questions.

To ensure completion of SLCP verifications, we have a conversion tool that is mapped against our UA code and FLA code. Following the generation of conversion reports, we engage with audit firms to generate a MAP for us to work with factories on corrective action items, and we follow the same approach as the above remediation process for the UASATR assessments.

WORKER VOICE

At UA, we are committed to ensuring that workers’ rights to freedom of association and collective bargaining are respected. As part of the assessment process, third-party assessors are required to consult with worker representatives, unions, and federations, if available, to gain an understanding of factory conditions even before the on-site assessment begins. Once on site, assessors not only evaluate whether grievance mechanisms are present, but that they are also accessible and effective. Assessors collect information by interviewing workers, reviewing on-site documentation on grievance procedures, submitting grievances and their resolution, and may also physically inspect grievance systems. We require factories to identify the person who is responsible and accountable for developing and implementing written grievance policies and procedures, as measured against the FLA Benchmarks. These systems must enable workers to report confidentially grievances to factories’ top management or its human resources teams – without supervisors' knowledge, reprisal, or retaliation.

We have sometimes served as an intermediary between workers and management when they are in conflict. In other cases, we have engaged a third-party expert to mediate and resolve issues. We also work with other brands that share our suppliers to identify issues and seek to implement jointly near-term corrective actions, in addition to building more sustainable systems for the future.

When we receive grievances via our hotline/email, we investigate them and take action, including asking suppliers to remedy issues. To strengthen our work around remediation and the effectiveness of grievance systems and their management, we have engaged with Ulula and Labor Solutions since 2021 to pilot a Worker Voice Program at 10 T1 factories in China, Indonesia, Jordan, Philippines, and Vietnam. In the program, mobile applications were deployed that enable workers to anonymously report grievances. Data related to reporting is aggregated and presented for action through third-party dashboards. By the end 2021, employers resolved over 98 percent of the cases captured by the grievance lines and developed grievance escalation guidance for cases that need to be escalated to our sustainability team. The program will be scaled up in the high-risk migrant countries with the service providers to monitor salient supply chain social and labor risks including forced labor risks. We will continue to enrich the program through collaboration with other brand partners as well as harmonization with Supplier Assessment Program to an extent that we make use of the data to advise applicable interventions and support remediation and capacity building. We will continue to engage with third parties to support factories in resolving cases and conduct investigations when necessary.

Because we are an FLA-accredited company, workers and their advocates also have access to the FLA third-party complaint procedure. This is an additional safeguard tool that supplements other grievance channels. The FLA reports on all complaints received. The FLA’s reports are available publicly, and we collaborate fully with the process.

VERIFICATION CERTIFICATION

We expect our suppliers to have human rights due diligence processes in place with respect to their own suppliers and contractors. Our manufacturing agreement requires our direct suppliers to certify that materials and components incorporated into our products comply with applicable laws and standards regarding modern slavery and human trafficking in the country or countries in which they are doing business, and where our products are made, sold, and distributed. The language in our manufacturing agreements is subject to periodic review and revision and was revised most recently in 2021 to ensure sections related to forced labor reflected current areas of highest risk.

Our supplier assessment approach has also created a significant data set that the UA sustainability team periodically analyzes to identify and address trends for particular issues, regions, countries, and types of suppliers, as well as to inform the sustainability score within our vendor scorecard. This analysis enables us to enhance and adapt our approach to the issues we have seen over time. We are currently using this data to improve our social compliance program and human rights due diligence including the ability to enhance remediation in, strengthen systems of, and develop clearer standards for, our suppliers and to guide updates to our policies and procedures.

We are deeply concerned by credible reports of forced labor and other abuses associated with the production of cotton. As the reported and specific circumstances may preclude the effective use of third-party audits to assess whether such abuses are occurring, we are employing measures to mitigate the risk of such abuses occurring in, or being linked to, our supply chain.  We have undertaken measures to trace the provenance of cotton fiber throughout our directly managed supply chain, across all jurisdictions where production occurs.

Since 2019, we have sent multiple communications to vendors reinforcing their responsibility to comply with applicable laws and the Forced Labor provision of the UA Code and FLA Code and benchmarks throughout their supply chain and to ensure no forced labor has been used in the production of UA products, their components or raw materials including cotton.

ADDRESSING GRIEVANCES

We remain committed to addressing grievances from individuals, workers, and communities. In its 2019 Accreditation Report, the FLA highlighted our grievance procedures and demonstrated engagement with civil society and unions in key sourcing regions as strengths of our social compliance approach. We recognize the importance of tailoring our remediation responses to reflect specific facts, local and other circumstances, and considering the safety of those potentially impacted, and engaging third parties for support and expertise, if needed.  While we work for continuous improvement, and expect the same from its business partners, we reserve the right to take necessary actions, including terminating business relationships.

Workers in our supply chain continue to have access to multiple grievance mechanisms, including a hotline and email option, specifically referred to in the Reporting Potential Misconduct provision of the UA Code. Workers who participate in the interview process during assessments and investigations are regularly provided with contact information for the UA sustainability team to enable them to voice issues or concerns including about matters that were not referenced during the audit or issues arising from the interviews during or after the assessments or investigations. Under the UA Code, UA suppliers and subcontractors also have a responsibility to implement effective non-retaliation policies, should a worker express a grievance. When issues are reported, we work with suppliers to support their corrective actions for identified issues, ensure the supplier is committed to continuous improvement over time and direct them to engage in related capacity building, as applicable.

The hotline mechanism featured in the UA Code is monitored 24 hours a day, seven days a week, and available to our teammates and external stakeholders and provides an option to report anonymously and in local language depending on the location. Product supply chain business partners, including manufacturers, licensees, and their subcontractors are required to post, in prominent areas, the UA Code in the language understood or spoken by workers at the facility. Additionally, we have a strict non-retaliation policy prohibiting retaliation against any teammate for raising an ethical concern, question, or complaint in good faith. Should the identity of the teammate making the complaint be known, we will monitor any disciplinary action against the teammate to determine if it is retaliatory.

All allegations are taken seriously and investigated, whether they come in through the hotline, email, assessors, or other stakeholders. In 2021, we received five complaints related to supply chain social compliance through our worker grievance channels (which are separate from our supplier grievance mechanisms). Of these complaints, one related to discrimination, one related to production incentives, two related to wages and severance packages, and one related to hours of work. We have closed four out of the five complaints received to date, two of which involved follow-up investigations and remediation plans, and we are actively working to remediate the remaining case with the facility and vendor.

Current Remediated Case Tracker

Data represents grievances lodged by year, not solely those related to modern slavery issues.

   2018   2019   2020   2021 
Annual Grievances Received 8 5 7 5
Open Cases 0 1 0 1
ClosedCases 8 4 7 4

REMEDIATION CASE STUDY UPDATE

Collaborating on Remediation Related to Migrant Labor in Malaysia

In our last Modern Slavery Statement, we provided information about a remediation case study involving migrant labor in Malaysia. Since 2019, we and other brands have continued partnering with the facility in Malaysia to address areas of noncompliance found initially in an assessment by Verité. This was followed by a verification visit by Impactt in 2019, and a follow-up visit in 2020 by a FLA-accredited assessment firm. In June 2021, an FLA-accredited assessment firm visited the facility and confirmed that all outstanding and previously identified recruitment fees have been reimbursed to migrant workers, and that it had successfully addressed other issues identified, which included worker training on harassment or abuse, wage calculation, and sustained improvements in fire safety competencies. The facility has continued implementing management systems to ensure worker rights are respected, and additional due diligence is conducted when hiring new foreign migrant workers. We will continue monitoring workplace conditions at this facility.

An updated summary and simplified timeline of key actions taken by the supplier since we first identified potential violations of the UA Code, the FLA Benchmarks, and the IHRB Dhaka Principles is provided in Box 4 as an example of how we work with our partners to ensure both immediate corrective actions and longer-term improvements based on best practices. With all our suppliers, we aim for a sustained improvement effort over time.

BOX 4. Malaysia Migrant Labor Remediation Case Study Timeline

Malaysia migrant labor remediation case study timeline

 

 

MEASURING EFFECTIVENESS

Our teammates, factories, suppliers, business partners, and manufacturers are all expected to meet company standards and procedures regarding and prohibiting modern slavery – including those in the UA Code, the FLA Code and our MWPS – and may be held accountable for failing to comply with such standards and procedures.

Effectiveness in meeting these standards and procedures is measured primarily through our previously described assessment process. Follow-up data analysis and remediation engagements between partner facility management and the UA sustainability and/or sourcing teams are also critical for ensuring continuous progress and improvement.

ACCOUNTABILITY

The UA sustainability team, led by our Chief Sustainability Officer, is primarily responsible for creating, implementing, operationalizing, and enhancing policies, standards, procedures, and structures including those related to modern slavery, human rights (including the ILO Core Labor Standards) and transparency. The team reports to our Chief Operating Officer, a reporting structure that bolsters the team’s ability to operationalize, integrate and implement our sustainability goals throughout our business units.

Our sustainability and sourcing teams collaborate closely, seeking to work with manufacturing business partners who strive to perform better on key labor and other human rights performance indicators. With respect to embedding human rights throughout the supply chain, we believe that close collaboration between the UA sustainability, product supply and sourcing teams is critical.

This collaboration allows the UA sustainability team to receive and provide up-to-date information about suppliers’ social and environmental compliance to corresponding sourcing personnel and to work with them as part of an integrated, cross-functional effort to avoid purchasing practices that increase the risk of human trafficking and forced labor in the supply chain (e.g., short-term contracts, excessive downward pressure on pricing, sudden changes of workload, rushed factory on-boarding).

Our RSP is an example of collaboration between our sustainability and supply chain teams, designed to support ongoing improvements of workplace conditions for workers in our global supply chain. These two teams have also worked closely together to embed sustainability into our vendor scorecard. This integrated approach provides an opportunity for improved tracking of supplier performance on key labor, modern slavery, and human rights-related indicators, and promotes greater cross-functional communication and alignment on sourcing decisions.

We also see engaging in public dialogue related to modern slavery as an additional way we can hold ourselves accountable for our commitments. These engagements and our participation in related membership initiatives, such as the FLA, the Better Buying Institute and The Mekong Club, further allow us to learn from other key stakeholders and collaborate with other actors who share our values in relation to combating modern slavery and advancing responsible sourcing. See Box 5 for some specific examples of some of these key partnerships.

Box 5. 2021 Stakeholder Engagement Highlights

Partnerships and Collaborations: UA is an accredited participating company affiliate of the FLA. We also became a member of The Mekong Club in October 2019, which has allowed us to receive up-to-date information and expert trainings on issues pertinent to modern slavery and exchange practices with other members on industry-specific challenges. In 2021, we attended The Mekong Club Working Group sessions to receive updates on the proposed legislation changes particularly in the UK law and the Canadian Modern Slavery Act, as well as information about emerging issues on modern slavery amid Covid-19 and the new tools such as human rights resources, living wage resources and an anti-slavery scorecard developed by The Mekong Club. In 2021, we also became a Better Work member to further support our commitment to advance ethical practices in our supply chain. Through this partnership, we strive to improve continuously the working conditions for the people who make our products and to deepen our engagement with suppliers and industry partners.

LEADERSHIP PARTICIPATION

Our sustainability program has workstreams that occurs across our organization, and involve the participation of leaders from sourcing, management supply chain, supply planning, materials innovation, digital, licensing, category, legal, communications and investor relations. We have a Sustainability Leadership Council (“SLC”), consisting of our Chief Operating Officer; Chief Product Officer; Executive Vice-President, General Counsel and Corporate Secretary; and Chief Sustainability Officer, which meets periodically to support our sustainability program. The SLC strives to incorporate the results of our sustainability program and related due diligence efforts into business processes and help drive operational improvements. The SLC is also charged with periodic reviews of issues, risks, findings, and trends related to assessments of manufacturers for compliance with laws and labor-related codes and benchmarks.

Additionally, the UA Board of Directors has delegated primary oversight of sustainability to the Corporate Governance and Sustainability Committee, which, among other responsibilities, oversees UA’s significant strategies, programs, policies and practices relating to sustainability (including environmental and human rights issues and impacts) and corporate responsibility.

TRAINING

We have previously provided our teammates and management, who have direct responsibility for supply chain management, with training on modern slavery, particularly with respect to mitigating related risks within the direct suppliers of products.  In 2018, we provided in-person trainings on the UA Code and our RSP to approximately 500 supply chain teammates in strategic sourcing units around the globe. In 2020, we expanded the training on the UA Code to include all corporate and distribution house (“DH”) teammates. In 2020, approximately 98 percent of all DH teammates and approximately 89 percent of corporate teammates took this training. In 2021, all corporate and DH teammates that had not received the training in the previous year were asked to complete the training.

In 2021, we partnered with Quizrr to launch a series of digital trainings to two suppliers in Jordan through the Worker Voice Pilot Program with an aim to further build capacity among our suppliers of high migratory labor risks. Specifically, two digital training modules covered topics related to involuntary works and responsible recruitment practices that are adapted based on the International Organization for Migration CREST Migrant Worker Guidelines and Suppliers Guidelines. During the year, over 4,500 factory workers and nearly 400 factory management team members received such trainings.

In 2020, more than 75 percent of the UA sustainability team attended modern slavery trainings conducted by Impactt, a leading modern slavery expert. These sessions included training on the ILO’s Forced Labor Indicators, updates on modern slavery legislation and reporting requirements, nuanced information on the relevant risks and impacts associated with modern slavery and recommended actions to identify and eliminate modern slavery within our supply chain.

Box 6. 2021 Training Spotlight

Forced Labor and Updates on Industry Trends: UA sustainability teammates participated in five third-party trainings related to modern slavery in 2021, including three webinar sessions hosted by The Mekong Club. The first and second training sessions outlined the Australian and UK Modern Slavery Acts and covered topics including work aimed at eliminating forced labor. Experience on how to prepare a Modern Slavery Statement were also shared and discussed broadly over the training. The third training focused on the Slavery and Trafficking Risk Template (STRT), an open-source tool developed by The Mekong Club and Social Responsibility Alliance. This training focused on how the STRT can assist companies with human trafficking and modern slavery legislative compliance and identify opportunities to improve supply chain-related public disclosures.

UA sustainability teammates also attended a session organized by the FLA that addressed challenges faced in conducting due diligence in certain regions, as well as a training delivered by American Apparel & Footwear Association on evaluating forced labor in cotton supply chains where the panellists covered issues including supply chain mapping, due diligence capacity building and assessments, and supplier engagement strategies.

Environmental, Social, and Governance (“ESG”) and Modern Slavery Risks: UA sustainability teammates also attended two trainings that focused on the role of ESG disclosures in addressing modern slavery risks.

LOOKING AHEAD

We plan to continue addressing and mitigating the risks of modern slavery in our supply chain by further embedding into our policies, tools, and sustainability program the important lessons we have learned from collaborating with forced labor and human rights due diligence experts and from working with our suppliers on effective remediation, sustainable capacity building, and responsible recruitment practices.

One of our programmatic goals for the upcoming fiscal year is to engage with our supply chain business partners around conducting due diligence aimed at ensuring that workers do not pay recruitment fees at origin or destination countries and that original travel document and personal IDs are not retained by facilities. In the future, we are also planning to begin piloting the MWPS’ Supplier self-assessment at facilities with migrant workers; expand our Worker Voice program and gender-based supply chain initiatives; and continue to use a diversified auditing methodology by incorporating other audits, such as Better Work, the SLCP, and the Higg FSLM.

 


SIGNATURE

The principle governing body of each of our subsidiaries in the United Kingdom and Australia is the entity’s Board of Directors. This statement has been approved by the Board of Directors of each of UA UK Retail, Under Armour UK and UA Australia, and was signed below by a director of each entity on 27 June

2022. David E. Bergman, Director
of UA UK Retail Limited, Under Armour UK Limited and 
UA Australia Pty Ltd

Dave Bergman Signature

 

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