Teammates & Suppliers' Workers

Our Responsible Sourcing Policy supports our commitment, as an FLA-accredited company, to the FLA’s Principles of Fair Labor and Responsible Sourcing. Our policy, which was last revised in 2020, encompasses the scope and complexities of our supply chain, financial and contractual terms, balanced planning, accountability, training, communication and review.

Responsible Sourcing Training for Teammates

We provide ongoing training programs on responsible sourcing for our global product supply and sustainability teams. For instance, our sustainability team has conducted Responsible Sourcing Policy training for supply chain leaders and teammates in the Asia-Pacific and Latin America regions. 

In addition, the sustainability team regularly participates in industry and NGO-led training on a range of topics, including responsible sourcing and purchasing practices, living wages, modern slavery, forced labor, integrating the UN Sustainable Development Goals into supply chains, responsible recruitment and COVID-19’s impact on sourcing practices.

Supplier Responsibility 

We require our suppliers to comply with our Supplier Code of Conduct, which details our expectations for respecting the human rights of and protecting the suppliers’ workers in our supply chain, aligns with FLA guidelines, and reflects the core ILO Conventions. It includes provisions on forced labor, compensation, hours of work, freedom of association and collective bargaining, nondiscrimination, harassment or abuse, nonretaliation, reporting potential misconduct and sustainable business practices. Along with the Under Armour Modern Slavery Statement, our Supplier Code of Conduct makes clear we will not tolerate any findings associated with slavery, servitude, forced or compulsory labor, human trafficking or other forms of modern slavery in our supply chain.

We engage third parties to conduct regular audits as part of our efforts to measure and safeguard the well-being, and respect the human rights, of our suppliers’ workers who make our products, while aiming to reduce negative social and environmental impacts from the manufacturing of our products. 

Our auditing process begins with our supplier onboarding. If we are sourcing from a new country, our sustainability team conducts a country-level human rights due diligence analysis. Every new Tier 1 supplier must complete our Global Ethics and Compliance Questionnaire and undergo a social compliance audit. The audit evaluates the potential supplier’s practices and workplace conditions against our Supplier Code of Conduct, the FLA Workplace Code of Conduct and Compliance Benchmarks, and applicable laws, as well as other applicable UA policies, standards and commitments they agree to comply with when they sign our manufacturing agreement. Our product licensees and their suppliers also agree to comply with these requirements and their Tier 1 suppliers undergo such audits.

We aim to have all UA onboarded and active Tier 1 suppliers audited annually.

Our Audit Approach

Under Armour Sustainable Assessment Tool and Report (UASATR)

We continue to use the UASATR as a core audit tool to evaluate supplier performance against our Supplier Code of Conduct and compliance with other codes, laws and standards. The UASATR aligns with the FLA’s Sustainable Compliance Initiative methodology, which assesses suppliers’ management systems and working conditions through worker and management interviews, document review, health and safety review, visual inspections and union or worker representative consultations.  

Given the increasing concern around risks of forced labor in certain countries, over the past few years we have expanded the UASATR to include additional questions aimed at enhancing the auditors’ ability to assess and report risks of forced labor, modern slavery, debt bondage and human trafficking. These questions include the ILO Forced Labor Indicators and risks potentially applicable to the recruiting, hiring and employment of migrant workers. We also provided additional teammate and auditor training focused on conducting human rights due diligence and identifying forced labor, modern slavery, and human trafficking risks and indicators and human rights and legal compliance issues.

The UASATR measures our suppliers’ performance in 10 social and environmental categories:

1. Environmental protection

2. Grievance

3. Health and safety

4. Hours of work

5. Industrial relations

6. Migratory workers

7. Recruiting, hiring, and personal development

8. Terminations

9. Wages and benefits

10. Workplace conduct and discipline 

Remediation & Collaboration

Our suppliers are valued business partners with whom we aim to maintain long-term relationships. We work closely to support them as they remediate issues. However, if necessary, we may terminate a supplier relationship depending on the specific facts and circumstances, including if a supplier or subcontractor fails to adequately remedy noncompliance up to our satisfaction and standards.

Evolution in Auditing

There are many inefficiencies when suppliers are asked to undergo similar audits by different brands. Because of this, the apparel and footwear industry is shifting toward greater audit alignment which will allow brands to leverage shared auditing tools. As a result, in 2021, we started to incorporate SLCP /FSLM verification and the ILO Better Work assessment into our auditing process. By using common industry assessment frameworks, our suppliers are more willing to share data with other buyers which in turn will enhance our beyond compliance program. For example, in 2022 we completed a total of 168 SLCP verification in lieu of our UASATR assessment.

Effective grievance mechanisms give suppliers’ workers access to remedy under the UNGP. When suppliers’ workers have effective avenues to express their grievances and concerns, their rights are respected, and they are consequently more valued, engaged and productive. In addition, their feedback can foster improvements in the workplace. We are committed to ensuring that our suppliers’ workers have a voice and that suppliers’ workers’ rights to freedom of association and collective bargaining are respected.

Our suppliers are required to maintain systems that enable their workers to effectively and confidentially report their grievances to top management and human resources teams. As part of our supplier auditing process, we evaluate not only whether grievance mechanisms are present, but also whether they are accessible and effective. Our third-party auditors provide factory personnel with their contact information so grievances and information may be shared, and consult with worker representatives, unions and federations, if available, to understand factory conditions when possible.

Additional Grievance Mechanisms

While we require our suppliers to maintain their own worker grievance systems, our suppliers’ workers—and employees of their subcontractors, if any—can also report suspected violations of our Supplier Code of Conduct to our hotline. The hotline is monitored 24 hours a day, seven days a week. It allows for anonymous reporting, depending on location.

When a concern is reported, we investigate and, where appropriate, act, including requiring suppliers to remedy issues. Our supplier hotline is another channel where we can continually monitor compliance with our Supplier Code of Conduct and help safeguard the people who make our products. These mechanisms are listed in the Reporting Misconduct provision of our Supplier Code of Conduct, which has been translated into over 35 languages. This information is required to be posted prominently in suppliers’ facilities and to be addressed in documented facility training on our Supplier Code of Conduct.

In 2020, we developed a Worker Voice Program in partnership with Ulula and Labor Solutions, organizations that are focused on the rights and well-being of migrant workers in our strategic suppliers’ facilities.

The Worker Voice Program connects factories with third-party hotlines and surveys providers to handle grievances. It also collects anonymous survey data about workplace conditions directly and confidentially from suppliers’ workers. The output from the hotlines and surveys becomes part of the suppliers’ due diligence processes and human resource management systems. We also have visibility into these anonymous grievances through a dashboard that allows us to spot trends at the factory level and further help our suppliers make improvements.

We recognize that fair compensation is a fundamental human right, and we remain steadfast in our commitment to ensure that suppliers take the appropriate actions to progressively realize a fair compensation level for their workers. This commitment is reflected in our Supplier Code of Conduct, our Fair Compensation Commitment Statement and our FLA membership.

We have set a goal to implement a fair compensation strategy across our supply chain by 2025, with pilot initiatives implemented in strategic supplier sites by 2023. 

Of course, fair compensation exists within a complex environment of considerations and challenges due to the dynamic roles that national and local governments play in setting wages. We recognize that fair compensation will require progressive action over time, and that this is an effort we cannot undertake alone. 

We are enhancing our understanding of these issues through activities including:

• Collaboration and stakeholder engagement. 

• Compensation data collection and analysis.

• Supplier feedback. 

Informed by a comprehensive assessment of human rights risks across our global operations and supply chain, we published the Under Armour Inc. Global Human Rights Commitment. We work with third parties and engage stakeholders to identify human rights risks relevant to our role as an employer, operator, purchaser, designer, innovator and connector. We prioritize managing our human rights risks by categorizing them into five focus areas—operations, supply chain, digital products, communities and the environment. In parallel, we regularly consult with external stakeholders, including civil society organizations, to determine where and how to continue improving.  

Migrant Workers 

Our Migrant Worker Policy & Standards comprehensively addresses the additional risks migrant workers face and reflects the continued evolution of our sustainability program to address these risks. We developed the policy to communicate our requirements with respect to our suppliers’ employment of migrant workers. These requirements were designed to ensure that migrant workers’ rights are respected, protected and treated equitably throughout our supply chain and across their employment life cycle. 

We also require our suppliers to practice responsible recruitment to ensure migrant workers obtain work free of coercion, deception, fees and debt. In addition, we are developing a self-assessment tool for our suppliers to compare their operations against the standards outlined in our policy and identify any gaps for improvement.

From Our Migrant Worker Policy and Standards

Migrant workers must: 

• Not pay for their job.

• Retain control of their personal identity documents.

• Have freedom of movement. 

• Be informed of the basic terms of their employment before leaving home.

• Live in well-maintained housing (if provided, secured, referred to, or arranged for, directly or indirectly, by the supplier).

• Have access to the equivalent clean, safe and healthy living and working conditions afforded to local residents, including in the event of natural, manmade or global health crisis.

• Enjoy demonstrably effective and anonymous grievance systems, without retribution and with demonstrated responsive actions by their employers.

• Have access to remedy for any issues faced. 

• Be repatriated fairly, rapidly and at the employer’s expense.