hummel uses several methods to ensure compliance with our code of conduct. Below methods are used to identify potential and actual violations of our code of conduct.

• Our Danish CSR team visits our manufacturers in person at regular intervals.

1. During our visits the CSR team will go through the factory floors along with the head of compliance. The CSR team will ask questions related to the implementation of our Code of Conduct, hereunder wages, working hours, unions and other violations often associated with the sector.
2. During our visits the CSR team will furthermore engage with the factories’ management team to share and seek their input in our risk assessment, research, NGO reports, audit results and observations related to CSR, along with hummel´s future expectations concerning the development of preventive measures and corrective action plans where necessary. 

• Our local staff from our offices in China, Pakistan, Bangladesh and Turkey visit the factories frequently. Both in their capacity as quality controllers and as our eyes and ears on the ground regarding the working conditions at the various factories.
• Our suppliers are going through third party audits on an ongoing basis, preferably from one of the following bodies: BSCI, SMETA, WRAP and SA8000.
• As part of our code of conduct, which is presented in both English and local languages, we require the manufacturers to establish complaint mechanisms that go directly to hummel. Most factories already have an internal anonymous complaint mechanism, so this is an additional precaution. Besides our own complaint mechanism, we also use the complaint mechanism of The International Accord, which operates in Bangladesh and Pakistan.
• Most factories also have their own internal anonymous complaint mechanism and workers committee which is used to address complaints.
• And finally, we conduct our own open-source risk assessment mainly based on NGO reports, Indexes, News, Government reports etc.

Based on our identified actual and potential risks of violations we prioritize the most significant risks and work towards preventing, mitigating, and providing remedy to the victims in the event we discover human rights violations in our value chain. Some of the countries hummel operates in can be considered risk countries. Hummel´s efforts will especially be centered around preventing and mitigating risk in those countries.

Some less human rights violation prone countries can have areas or political developments that require an increase in monitoring, such as Poland due to the influx of refugees from Ukraine and Italy due to migrant exploitation in certain areas. 

Image shows hummel´s contractual suppliers