Fair Labor Association

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The factual information set forth on the Tracking Charts was submitted to the FLA by each Independent External Monitor and Participating Company and reviewed by FLA staff.  It is being made 
available to the public pursuant to the FLA Charter in order to strengthen the monitoring process. The FLA Charter provides for regular public disclosure of the factual results of independent 
monitoring and the resulting specific actions taken by Participating Companies. 
 
What is a Tracking Chart?  
 
Compliance is a process, not an event. A Tracking Chart outlines the process involved in FLA independent external monitoring and remediation. It is used by the accredited independent external 
monitor, the participating company and the FLA staff to do the following:  
 
 Record Findings: The independent external monitor uses the Tracking Chart to report noncompliance with FLA Code standards. The monitor should also cite the specific Code 
benchmark or national/local law that was used to measure compliance.  
 Report on Remediation: The FLA participating company uses the Tracking Chart to report on the remediation program that was implemented in order to resolve the noncompliance and 
prevent any future violations.  
 Evaluate Progress: The FLA uses the Tracking Chart for purposes of collecting and analyzing information on the compliance situation of a particular factory and for publication on our 
website. This information is updated on an ongoing basis. 
 
What a Tracking Chart is NOT - 
 
 An exhaustive assessment of factory conditions 
 
Working conditions - in any type of workplace - are dynamic. Each Tracking Chart represents a survey of the factory’s conditions on a specific day. Over time, a fuller picture emerges as 
we compile information from various sources to track the compliance progress of a factory. 
  
 A pass or fail evaluation 
 
The Tracking Charts do not certify whether or not factories are in compliance with the FLA Code. Monitoring is a measurement tool. The discovery of noncompliance issues is therefore not 
an indication that the participating company should withdraw from a factory. Instead, the results of monitoring visits are used to prioritize capacity building activities that will lead to 
sustainable improvements in the factory’s working conditions.  
 
• A one-time event  
 
Each monitoring visit is followed by a remediation program, further monitoring and remediation in an ongoing process. The Tracking Charts are updated accordingly. 
 
 
 
 
Note on Language 
Please be advised that because FLA independent external monitors are locally-based and English is generally not their native language, the language presented may at times appear unclear to a 
reader who is a native English speaker. In order to preserve the integrity of the transparency process and the information we receive, our policy is to publish the original text from the monitor and 
participating company. However, the reader will note that we have taken the precaution to remove any identifying information about the factory that was monitored or the workers interviewed.  
 
For example, in cases where monitors and/or participating companies have cited the actual number of workers in reference to a noncompliance issue, in order to protect the workers’ identities, we 
have replaced the numbers with generic wording in brackets (i.e. “[some]”, “[worker interviews revealed that]”,etc.).   
 
We do not disclose the name of the factory that was monitored in order to ensure that the FLA’s efforts to encourage and reward transparency do not have detrimental consequences for the 
factory and the workers.  
 
Instructions for Printing 
The information contained in the Tracking Charts is organized by columns and rows in a table format. Due to the number and width of the columns, the charts have been formatted for legal size 
(8.5 x 14in.) paper. To print the charts, please make sure to select “legal” size paper from Print properties. 
FLA Audit Profile
Country
Factory name
IEM
Date of audit
Days in the facility
PC(s)
Number of workers
Product(s)
Production processes
FLA Code/ Compliance issue Legal 
Reference
FLA Benchmark Monitor's Findings Documentation PC remediation plan PC follow up
1. Code Awareness
Code posting/information Establish and articulate clear, written workplace 
standards.  Formally convey those standards to 
Company factories as well as to licensees, contractors 
and suppliers. (POM)
Participating company has not 
delivered a COC to the 
factory.    No COC was posted 
in the factory.               
Visual 
inspection
Eddie Bauer will provide the factory with the Eddie Bauer 
Factory Workplace Code of Conduct poster in English, Spanish 
and Chinese. Factory should ensure that the Code is posted in 
a prominent place.   
The Eddie Bauer Code is posted in two 
different areas of the factory in English, 
Spanish and Chinese. (follow-up visit, Feb 7, 
2005)
Worker/management 
awareness of Code
Ensure that all Company factories as well as contractors 
and suppliers inform their employees about the 
workplace standards orally and through the posting of 
standards in a prominent place (in the local languages 
spoken by employees and managers) and undertake 
other efforts to educate employees about the standards 
on a regular basis. (POM)
Workers are not aware of 
Code of Conduct elements.
Workers  
interviews 
see above. The Code is posted, and factory management 
was instructed on the elements of the Code 
and Eddie Bauer's expectations. The factory 
informs workers of their rights orally and 
through an induction manual during 
orientation.  (follow-up visit, Feb 7, 2005)
Confidential non-compliance 
reporting channel
Develop a secure communications channel, in a manner 
appropriate to the culture and situation, to enable 
Company employees and employees of contractors and 
suppliers to report to the Company on noncompliance 
with the workplace standards, with security that they shall 
not be punished or prejudiced for doing so. (POM)
Manager was not aware of any 
confidential communication 
channel to EDDIE BAUER 
Management 
interview
The 2005 version of Eddie Bauer's Factory Workplace Code of 
Conduct poster includes local Eddie Bauer contact information. 
While Eddie Bauer encourages factories to develop and utilize 
internal procedures for resolving workplace disputes, this 
communication channel is provided as an additional resource 
for workers to confidentially report non-compliance issues 
directly to Eddie Bauer.
The Code posters include Eddie Bauer contact 
information and a notice to workers that they 
are encouraged to report any instances of non-
compliance to Eddie Bauer.  (follow-up visit, 
Feb 7, 2005)
3. Child Labor
There will not be any use of forced labor, whether in the form of prison labor, indentured labor, 
bonded labor or otherwise
02008258C
2.Forced Labor 
Findings
USA
EDDIE BAUER
SWIM WEAR
Remediation
COTECNA
NOVEMBER 29, 2004
ONE
164
CUTTING, SEWING, FINISHING AND SHIPPING
1
FLA Code/ Compliance issue Legal 
Reference
FLA Benchmark Monitor's Findings Documentation PC remediation plan PC follow up
Findings Remediation
4. Harassment or Abuse
5. Nondiscrimination
6. Health and Safety
Evacuation Procedure All applicable legally required or recommended elements 
of safe evacuation (such as posting of evacuation plans, 
unblocked aisles/exits, employee education, evacuation 
procedures, etc.) shall be complied with and workers 
shall be trained in proper safety, first aid, and evacuation 
procedures
No training has been provided 
to workers in evacuation 
procedures.
Workers  
interviews and 
records review
Develop and implement fire safety policies and procedures, and 
train workers in the procedures. Fire drills should be conducted 
on at least an annual basis.  
A fire drill was conducted on Feb. 2 and 
workers were instructed in evacuation 
procedures and the use of fire extinguishers. 
Factory is planning an unannounced fire drill 
later in the year. (follow-up visit, Feb 7, 2005)
Safety Equipment All safety and medical equipment (such as fire fighting 
equipment, first aid kits, etc.) shall be in place, 
maintained as prescribed and accessible to the 
employees
No fire alarm is functioning in
this factory.
Visual 
inspection and 
management 
interiew
Factory should maintain working fire alarms in the factory. There is one fire alarm located in a deserted 
section of the factory. Factory has agreed to 
install new fire alarms in the factory's main 
production areas. Eddie Bauer will continue to 
monitor this issue to verity completion. (follow-
up visit, Feb 7, 2005)
Worker Participation Workers should be involved in planning for safety, 
including through worker safety committees
There is not a fire brigade in
this factory.
workers and 
manager 
interviews 
Factory should promote worker participation in the health and 
safety management of the factory, such as through organizing 
fire brigades.
A factory-wide fire drill was conducted on Feb. 
2 and supervisors were designated to direct 
their teams and take attendance. (follow-up 
visit, Feb 7, 2005)
8. Wages and Benefits
9. Hours of Work
No person will be employed at an age younger than 15 (or 14 where the law of the country of 
manufacture allows) or younger than the age for completing compulsory education in the country of 
manufacture where such age is higher than 15.
Employers will provide a safe and healthy working environment 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 facilities
Employers will recognize and respect the right of employees to freedom of association and collective 
bargaining
Employers recognize that wages are essential to meeting employees’ basic needs. Employers will 
pay employees, as a base, at least the minimum wage required by local law or the prevailing 
industry wage, whichever is higher, and will provide legally mandated benefits
7. Freedom of Association and Collective Bargaining
Every employee will be treated with respect and dignity.  No employee will be subject to any 
physical, sexual, psychological or verbal harassment of abuse.
No person will be subject to any discrimination in employment, including hiring, salary, benefits, 
advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, 
disability, sexual orientation, nationality, political opinion, or social or ethnic origin.
2
FLA Code/ Compliance issue Legal 
Reference
FLA Benchmark Monitor's Findings Documentation PC remediation plan PC follow up
Findings Remediation
10. Overtime 
Compensation
Miscellaneous
Illegal subcontracting
Possible homework
In addition to their compensation for regular hours of work, employees will be compensated for 
overtime hours at such premium rate as is legally required in the country of manufacture or, in those 
countries where such laws will not exist, at a rate at least equal to their regular hourly compensation 
rate.
Except in extraordinary business circumstances, employees will (i) not be required to work more 
than the lesser of (a) 48 hours per week and 12 hours overtime or (b) the limits on regular and 
overtime hours allowed by the law of the country of manufacture or, where the laws of such country 
will not limit the hours of work, the regular work week in such country plus 12 hours overtime; and (ii) 
be entitled to at least one day off in every seven day period
3


Tracking Chart 2004 Eddie Bauer, USA 02008258C

https://digitalcommons.ilr.cornell.edu/cgi/viewcontent.cgi?article=3038&amp;context=globaldocs

Tracking Chart 2004 Eddie Bauer, USA 02008258C

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