Fair Labor Association (FLA) Workplace Code of Conduct

Principle 1: EMPLOYERS SHALL ADOPT AND ADHERE TO RULES AND CONDITIONS OF EMPLOYMENT THAT RESPECT WORKERS AND, AT A MINIMUM, SAFEGUARD THEIR RIGHTS UNDER NATIONAL AND INTERNATIONAL LABOR AND SOCIAL SECURITY LAWS AND REGULATIONS. Compliance Benchmarks include: written employment relationships including written terms of employment in language the worker understands; legally binding contracts; protection against arbitrary termination; legally compliant social security + worker insurance / health coverage; respect for the principle that the employment relationship gives rise to obligations independent of any subcontract or other arrangement; the employer is the principal employer for all workers regardless of contract form (regular + part-time + seasonal + casual + temporary + agency-supplied + apprentice + worker classified as 'independent contractor' where in substance the relationship is e

• Written employment contracts in worker's language
• Worker-classification audit identifying mis-classified independent contractors
• Social-security + worker-insurance enrolment evidence
• Termination policy + records demonstrating non-arbitrary process

• Workers without written employment contracts
• Mis-classified independent contractors substantively performing as employees
• Social-security enrolment gaps
• Arbitrary terminations without documented cause + process

Principle 2: NO PERSON SHALL BE SUBJECT TO ANY DISCRIMINATION IN EMPLOYMENT, INCLUDING HIRING, COMPENSATION, ADVANCEMENT, DISCIPLINE, TERMINATION OR RETIREMENT, ON THE BASIS OF GENDER, RACE, RELIGION, AGE, DISABILITY, SEXUAL ORIENTATION, NATIONALITY, POLITICAL OPINION, SOCIAL GROUP OR ETHNIC ORIGIN. Compliance Benchmarks include: equal opportunity policy + practice; equal remuneration for work of equal value (ILO C100); non-discrimination in occupation (ILO C111); pregnancy-related employment protection including no compulsory pregnancy testing + no termination for pregnancy + maternity leave + reinstatement; harassment-free workplace; disability accommodation; non-discrimination training for managers + workers + worker representatives.

• Equal-opportunity policy + non-discrimination training records
• Equal remuneration audit for work of equal value
• Pregnancy-test-free hiring + no termination for pregnancy evidence
• Disability accommodation records

• Compulsory pregnancy testing
• Termination for pregnancy + no reinstatement after maternity leave
• Equal-remuneration audit not performed + gender wage gap unexplained
• Disability accommodation gaps

Principle 3: EVERY EMPLOYEE SHALL BE TREATED WITH RESPECT AND DIGNITY. NO EMPLOYEE SHALL BE SUBJECT TO ANY PHYSICAL, SEXUAL, PSYCHOLOGICAL OR VERBAL HARASSMENT OR ABUSE. Compliance Benchmarks include: written policy prohibiting harassment + abuse; reporting + investigation procedures (the grievance mechanism); disciplinary procedures for offenders; protection for complainants against retaliation; training for managers + workers + worker representatives + security personnel; specific protections against sexual harassment + gender-based violence including for migrant + young + female workers; no use of corporal punishment or any threat thereof.

• Anti-harassment policy + procedure
• Investigation records + remediation evidence
• Anti-retaliation policy + monitoring evidence
• Sexual-harassment + gender-based-violence prevention programme

• Anti-harassment policy lacks reporting procedure
• Investigations not independent or fail to remediate
• Retaliation reported but not addressed
• Sexual harassment investigations limited to female-on-female + ignoring power-imbalance + male-on-female cases

Principle 4: THERE SHALL BE NO USE OF FORCED LABOR, INCLUDING PRISON LABOR, INDENTURED LABOR, BONDED LABOR OR OTHER FORMS. Compliance Benchmarks include: prohibition of any form of forced + bonded + trafficked labor; recruitment-fee-free hiring (NO RECRUITMENT FEES OR DEPOSITS PAID BY WORKERS); freedom of movement + no withholding of original identity documents (passport + visa + work permit) by employer; ability to terminate employment with reasonable notice; ability to leave the workplace + dormitory at any time; no excessive contract penalty payments; no demand for collateral; employer covers all costs of legal + ethical recruitment per the Employer Pays Principle. The Employer Pays Principle is the foundational anti-trafficking standard adopted by IOM + ILO + Responsible Business Alliance + the Consumer Goods Forum.

• Anti-forced-labor policy + Employer Pays Principle declaration
• Recruitment-fee audit + reimbursement evidence
• Original-documents-held-by-worker policy + verification
• Freedom-of-movement evidence + worker testimony
• Migrant-worker recruitment due diligence + agency vetting

• Workers paying recruitment fees
• Original identity documents retained by employer or recruitment agency
• Restricted freedom of movement (dormitory lockdown + restricted leave)
• Excessive contract penalties + collateral demands
• Recruitment agency vetting absent + opaque recruitment chain

Principle 5: NO PERSON SHALL BE EMPLOYED UNDER THE AGE OF 15 OR UNDER THE AGE FOR COMPLETION OF COMPULSORY EDUCATION, WHICHEVER IS HIGHER. Compliance Benchmarks include: age verification at hiring through reliable documents; no hazardous work for workers under 18 (ILO C138 minimum age + ILO C182 worst forms of child labour); restricted hours + tasks + workplace + supervision for young workers (15-18) per national law + Programme of Action; access to education for young workers; remediation pathway when child labor is discovered (return to school + family income replacement + monitoring + age-appropriate alternative); rest periods + medical examinations + occupational health for young workers; protection from worst forms of child labour including child trafficking + slavery + bonded labour + commercial sexual exploitation + use in illicit activities.

• Age-verification documents at hiring
• Hazardous-work risk assessment + 18+ enforcement
• Young-worker programme + restricted hours / tasks
• Child-labor discovery + remediation procedure
• Worst-forms-of-child-labour prevention programme

• Age verification limited to self-declaration
• Workers under 18 in hazardous tasks
• Young workers in night shifts or beyond protected hours
• No child-labor remediation procedure (discovery without family income replacement + return-to-school pathway)
• Worst-forms-of-child-labour risk in cocoa + cotton + brick + mining suppliers not addressed

Principle 6: EMPLOYERS SHALL RECOGNIZE AND RESPECT THE RIGHT OF EMPLOYEES TO FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING. Compliance Benchmarks include: legal recognition of workers' right to form + join (or refrain from joining) labour unions of their own choice; right to collective bargaining; non-interference + non-discrimination against worker representatives + union members; in countries where the right is restricted (China, Vietnam, Saudi Arabia, etc.) the employer must NOT obstruct PARALLEL means of independent + free association + bargaining (worker committees + grievance mechanisms + worker representatives chosen freely + access to workplace by recognised representatives); protection of union representatives from disadvantageous treatment; access to information necessary for meaningful bargaining; written collective agreements where collective bargaining has occurred + thei

• FoA + CB policy + procedure
• Worker-representative election + selection evidence + non-interference
• Parallel-means mechanism documentation for restricted-jurisdiction operations
• Written collective agreements + implementation tracking

• Worker representative dismissed or disadvantaged + retaliation
• Parallel means absent in restricted jurisdiction (e.g. PRC operations without worker committees or grievance mechanisms)
• Collective agreement signed but not implemented
• Yellow-union or company-controlled union substituted for genuine worker representation

Principle 7: EMPLOYERS SHALL PROVIDE A SAFE AND HEALTHY WORKPLACE SETTING TO PREVENT ACCIDENTS AND INJURY TO HEALTH ARISING OUT OF, LINKED WITH, OR OCCURRING IN THE COURSE OF WORK OR AS A RESULT OF THE OPERATION OF EMPLOYER'S FACILITIES. EMPLOYERS SHALL ADOPT RESPONSIBLE MEASURES TO MITIGATE NEGATIVE IMPACTS THAT THE WORKPLACE HAS ON THE ENVIRONMENT. Compliance Benchmarks include: occupational health + safety management system (ISO 45001 or equivalent); risk assessment + hazard identification (HIRA); incident investigation + reporting; PPE provision + training + maintenance; chemical management + safety data sheets (SDS) in worker language; ergonomic risk management; fire safety + emergency preparedness + evacuation drills + fire-suppression equipment (criticality elevated after the 2012 Tazreen + 2013 Rana Plaza tragedies); building safety + structural integrity; dormitory + canteen sta

• ISO 45001 (or equivalent) OH&S management system
• HIRA + incident investigation records + PPE + training
• Fire-safety + building-safety audit + emergency drills
• Dormitory + canteen audit
• ISO 14001 (or equivalent) environmental management system

• OH&S system without management commitment + worker participation
• Fire safety inadequate (locked exits + flammable storage + no drills)
• Building safety not certified for occupancy + age
• Environmental management focused only on regulatory minimum + not preventive

Principle 8: EMPLOYERS SHALL NOT REQUIRE WORKERS TO WORK MORE THAN THE REGULAR AND OVERTIME HOURS ALLOWED BY THE LAW OF THE COUNTRY WHERE THE WORKERS ARE EMPLOYED. THE REGULAR WORK WEEK SHALL NOT EXCEED 48 HOURS. EMPLOYERS SHALL ALLOW WORKERS AT LEAST 24 CONSECUTIVE HOURS OF REST IN EVERY SEVEN DAY PERIOD. ALL OVERTIME WORK SHALL BE CONSENSUAL. EMPLOYERS SHALL NOT REQUEST OVERTIME ON A REGULAR BASIS AND SHALL COMPENSATE ALL OVERTIME WORK AT A PREMIUM RATE. OTHER THAN IN EXCEPTIONAL CIRCUMSTANCES, THE SUM OF REGULAR AND OVERTIME HOURS IN A WEEK SHALL NOT EXCEED 60 HOURS. Compliance Benchmarks include: 48-hour regular workweek + 60-hour cap (regular + overtime) except in exceptional circumstances; 24-hour weekly rest period; voluntary overtime (worker consent + no penalty for refusal); overtime premium (typically 125-150% of regular rate per national law); accurate time-recording for all w

• Time-recording system covering all workers + all hours
• Overtime-voluntariness policy + worker-consent documentation
• 60-hour-cap monitoring + exceptional-circumstance documentation
• Overtime-premium calculation evidence + payroll cross-check

• Double-bookkeeping (audit-time-records vs payroll-time-records divergent)
• Forced overtime in production peaks
• 60-hour cap routinely exceeded + 'exceptional circumstances' invoked as routine
• Overtime premium underpaid or paid as base

Principle 9: EVERY WORKER HAS A RIGHT TO COMPENSATION FOR A REGULAR WORK WEEK THAT IS SUFFICIENT TO MEET THE WORKER'S BASIC NEEDS AND PROVIDE SOME DISCRETIONARY INCOME. EMPLOYERS SHALL PAY AT LEAST THE MINIMUM WAGE OR THE APPROPRIATE PREVAILING WAGE, WHICHEVER IS HIGHER, COMPLY WITH ALL LEGAL REQUIREMENTS ON WAGES, AND PROVIDE ANY FRINGE BENEFITS REQUIRED BY LAW OR CONTRACT. WHERE COMPENSATION DOES NOT MEET WORKERS' BASIC NEEDS AND PROVIDE SOME DISCRETIONARY INCOME, EACH EMPLOYER SHALL WORK WITH THE FLA TO TAKE APPROPRIATE ACTIONS THAT SEEK TO PROGRESSIVELY REALIZE A LEVEL OF COMPENSATION THAT DOES. Compliance Benchmarks include: payment at or above legal minimum + prevailing wage; full payment of fringe benefits + social-security contributions; timely + transparent wage payment (worker-language payslip); no illegal wage deductions; the FAIR COMPENSATION PATHWAY (FCP) - the FLA's signatu

• Wage-payment records + comparison against legal minimum + prevailing wage
• FCP benchmarking + living-wage gap analysis (Anker / WageIndicator / GLWC)
• Purchasing-practice alignment with living-wage pricing
• Gender pay gap audit + remediation

• Wages below legal minimum or prevailing wage
• FCP not adopted or living-wage gap analysis absent
• Purchasing practices (low prices + tight delivery windows) systematically incompatible with fair compensation
• Gender pay gap unexplained or unaddressed

FLA Accreditation is the multi-year assurance mechanism by which FLA Member Companies + Supplier Companies + Universities + Civil Society Organisations demonstrate sustained implementation of the Workplace Code of Conduct. Components: (a) FLA membership application + initial assessment; (b) Independent External Monitoring (IEM) - on-site factory audits conducted by FLA-accredited monitors; (c) Sustainable Compliance Initiative (SCI) - systems-level audit covering company operational policies + supplier management + worker grievance + remediation effectiveness; (d) Public Tracking Chart - public-facing summary of factory-level audit findings + remediation; (e) Public Reports - annual member company reports on FLA-conducted assessments; (f) Accreditation Decision - FLA Board approval following demonstrated compliance + remediation effectiveness; (g) Ongoing Monitoring - sustained assessmen

• FLA membership agreement + annual reporting
• IEM + SCI audit reports + remediation evidence
• Public Tracking Chart entries + Public Report
• Triennial re-accreditation cycle

• Member company without IEM coverage of representative supplier sample
• Audit findings not remediated (re-occurring findings across audit cycles)
• Public Tracking Chart incomplete or stale

The FLA Workplace Code of Conduct is the principal multi-stakeholder voluntary labor-standards code in the apparel + footwear + agriculture + electronics + university-licensee sectors. The 10 principles + 100+ Compliance Benchmarks operationalise the ILO Declaration on Fundamental Principles and Rights at Work + the UN Guiding Principles on Business and Human Rights + the OECD Guidelines for Multinational Enterprises in the workplace context. The Code is reviewed periodically (last substantive revision: 2017; ongoing review 2024-2025 to align with EU CSDDD + the FLA Fair Compensation Pathway + worker-voice strengthening + climate + biodiversity considerations). The FLA Workplace Code is intentionally HARMONIZED with related multi-stakeholder codes (SAC Higg + amfori BSCI + WRAP + SA8000) + leverages CONVERGENCE CODE collaboration (joint cross-recognition of audits between FLA + ETI + amf

• FLA member subscription for full Compliance Benchmarks
• Tracking of the 2024-2025 FLA Code revision pipeline
• Cross-reference to related multi-stakeholder codes (SAC Higg + amfori BSCI + WRAP + SA8000)

• Treating this corpus node as the substantive source (it is a sector-application view; the full Compliance Benchmarks are FLA-member-gated)
• No tracking of the 2024-2025 Code revision pipeline

Worker grievance + remediation + worker voice are cross-cutting requirements applying across all 10 principles. Compliance Benchmarks include: ANONYMOUS + multiple-channel grievance mechanisms (worker hotlines + grievance committees + worker-representative-led mechanisms + third-party operated mechanisms + digital grievance platforms); accessible + culturally appropriate + language-appropriate; tracked + investigated + outcome-communicated; protection against retaliation; remediation including monetary compensation + restoration of employment + improved process + apology + non-recurrence prevention; alignment with UNGP Pillar III access to remedy + OECD National Contact Point mechanism. The 2024 FLA Code revision strengthened worker-voice requirements aligning with the EU CSDDD (Corporate Sustainability Due Diligence Directive, Directive (EU) 2024/1760) + UNGP-29 operational-level grieva

• Multi-channel + anonymous grievance mechanism + investigation evidence
• Remediation case file + outcome-communication evidence
• Worker-voice survey + representation evidence
• Anti-retaliation policy + monitoring

• Grievance mechanism single-channel or accessible only via direct supervisor
• Investigation not independent + outcome not communicated to complainant
• Remediation limited to apology + no monetary or process improvement
• Anti-retaliation policy without monitoring or detection

Principle 10 (variant designations include 'Subcontracting' or 'Code Communication and Awareness' or 'Supply Chain Responsibility' in different FLA Code editions): EMPLOYERS SHALL BE RESPONSIBLE FOR THEIR SUPPLY CHAIN INCLUDING SUBCONTRACTORS AND HOMEWORKERS, ENSURING THAT THE WORKPLACE STANDARDS OF THE FLA CODE FLOW DOWN THROUGH ALL TIERS OF THE SUPPLY CHAIN AND HOMEWORK ARRANGEMENTS. Compliance Benchmarks include: subcontracting + homeworking inventory (mapping the tier 2 + tier 3 + homeworker network); written subcontracting agreements aligned with the FLA Code; subcontractor + homeworker monitoring + capacity building; transparency in disclosure of subcontractors to the FLA + member companies; flow-down of all Workplace Code principles to subcontractors + homeworkers; protection against unauthorised subcontracting + safety risks in subcontracted operations + homeworking (where produc

• Subcontractor + homeworker inventory + map
• Written subcontractor agreements with FLA Code flow-down clauses
• Tier 2 / tier 3 + homeworker monitoring records
• Supply-chain transparency disclosure

• Subcontracting + homeworking opaque
• Tier 2 / 3 unmapped + uncovered by monitoring
• Unauthorised subcontracting (e.g. PRC factory finds work overflows go to unauthorised + un-audited tier 2)
• Supply-chain disclosure limited to tier 1