Human Rights & Labor Practices

We adopt the UN Guiding Principles on Business and Human Rights, the International Labour Organization (ILO) conventions, and relevant national regulations as the foundational baseline for our human rights and labor practices program. These are not minimum standards we seek to meet—they are the floor from which we build our commitment. We recognize that international human rights standards represent the collective wisdom of decades of struggle for dignity and justice, and we honor that struggle by making these standards central to how we operate. We understand that human rights are universal, indivisible, and inalienable, and we commit to respecting and promoting them wherever we operate, regardless of local laws or practices that might fall short of these standards.

Every supplier must sign and commit to our comprehensive Supplier Code of Conduct, which explicitly prohibits forced labor, child labor, discrimination, harassment, unsafe working conditions, excessive working hours, and wage theft. This code is not a suggestion—it is a requirement for doing business with LAC. We recognize that supply chains are complex, and that ensuring compliance requires more than a signature, but the code serves as our clear statement of expectations and our foundation for accountability. We work with suppliers to understand and implement the code, providing training, resources, and support, but we also make clear that violations are not acceptable and will result in consequences, including suspension or termination of the business relationship.

We require that all workers in our supply chain have fundamental rights: freedom of association and the right to collective bargaining, access to effective grievance mechanisms, fair compensation that meets or exceeds legal minimums and provides a living wage, safe and healthy working conditions, reasonable working hours with adequate rest, and protection from discrimination and harassment. These are not aspirational goals—they are non-negotiable requirements. We recognize that in some contexts, these rights are not fully protected by law, and we commit to going beyond legal minimums to ensure that workers are treated with dignity and respect. We understand that respecting human rights sometimes requires us to do more than what is legally required, and we embrace that responsibility.

We extend our human rights commitment beyond labor rights to include the rights of communities affected by our operations and supply chains. We respect the rights of indigenous peoples, local communities, and other stakeholders who may be impacted by our activities. We commit to free, prior, and informed consent where appropriate, to respecting land rights, to protecting cultural heritage, and to ensuring that our operations do not harm the communities in which we operate. We recognize that business operations can have profound impacts on communities, and we commit to ensuring that those impacts are positive, not negative.

We recognize that human rights and labor rights are interconnected with other rights, including the right to health, the right to education, and the right to a clean and healthy environment. We work to ensure that our operations and supply chains support these broader rights, understanding that true respect for human dignity requires attention to the full spectrum of human rights. We understand that workers cannot exercise their labor rights effectively if they lack access to healthcare, education, or a healthy environment, and we work to address these interconnected challenges.

Human rights due diligence is not a one-time exercise—it is an ongoing process that requires continuous attention, assessment, and action. We conduct comprehensive risk assessments that prioritize high-risk geographies, product categories, and manufacturing processes, recognizing that not all parts of our supply chain pose the same level of risk. These assessments are based on credible data, expert analysis, and stakeholder input, and they guide our audit frequency, monitoring intensity, and resource allocation. We understand that effective due diligence requires understanding where risks are highest and focusing our efforts accordingly, while never ignoring lower-risk areas entirely.

We partner with independent, credible auditors and NGOs to conduct thorough onsite assessments, recognizing that external verification is essential to credibility and effectiveness. These assessments include comprehensive worker interviews conducted in safe, confidential settings, detailed document reviews, facility inspections, and engagement with local stakeholders including workers, unions, community organizations, and government officials. We recognize that effective assessments require trust, and we work with partners who have earned that trust in the communities where we operate. We understand that audits alone are not sufficient—they must be part of a broader strategy that includes prevention, remediation, and continuous improvement.

When violations are identified, we respond with urgency and seriousness. Corrective action plans are developed in collaboration with suppliers, workers, and other stakeholders, and they include clear timelines, measurable milestones, and accountable owners. These plans address not just the immediate violation, but the root causes that led to the violation, recognizing that sustainable improvement requires systemic change. We provide support and resources to help suppliers implement corrective actions, but we also make clear that persistent violations or failure to implement corrective actions will result in suspension or termination of the business relationship. We understand that our leverage as a buyer is a powerful tool for protecting human rights, and we use that leverage responsibly and effectively.

We recognize that some human rights violations are so severe that they require immediate action, including potential termination of business relationships. Forced labor, child labor, and other egregious violations are not subject to corrective action plans—they require immediate remediation and, in many cases, termination of the relationship. We understand that continuing to do business with suppliers who engage in egregious violations would make us complicit in those violations, and we refuse to be complicit. We recognize that this may sometimes require difficult business decisions, but we are committed to making those decisions based on human rights, not just business considerations.

We continuously improve our due diligence and monitoring processes, learning from experience, best practices, and stakeholder feedback. We invest in training for our procurement teams, auditors, and other staff who are involved in human rights due diligence, ensuring that they have the knowledge, skills, and resources necessary to effectively identify and address human rights risks. We participate in industry initiatives, multi-stakeholder partnerships, and other collaborative efforts that advance human rights due diligence, recognizing that addressing complex human rights challenges requires collective action. We understand that human rights due diligence is an evolving field, and we commit to staying current with best practices and continuously improving our approach.

When human rights violations occur, our primary focus is on remediation that supports and empowers affected workers. We prioritize back pay for workers who have been underpaid, medical care for workers who have been injured or made ill, safer working conditions for workers who have been exposed to hazards, and other forms of remediation that directly address the harm that has been done. We recognize that remediation is not just about correcting violations—it is about restoring dignity, providing justice, and ensuring that workers are made whole. We work with suppliers, workers, unions, and other stakeholders to develop remediation plans that are meaningful, effective, and sustainable.

Worker voice is essential to effective human rights protection, and we create multiple channels for workers to raise concerns, report violations, and provide feedback. Anonymous reporting channels are available to employees, contractors, and supplier workers, ensuring that workers can report concerns without fear of retaliation. These channels are well-publicized, easily accessible, and available in multiple languages. Reports are evaluated by our Human Rights Committee within five business days, and serious allegations receive immediate attention. We recognize that workers are often the best source of information about violations, and we create systems that encourage and protect worker reporting.

We collaborate extensively with partners to deliver comprehensive training on worker rights, occupational health and safety, and safe management practices. This training is not a one-time event—it is an ongoing program that builds capacity, changes behavior, and creates cultures of respect and safety. We work with unions, worker organizations, NGOs, and other partners who have expertise and credibility in worker education, recognizing that effective training requires trust and cultural competency. We understand that training alone is not sufficient, but it is an essential component of building supply chains that respect human rights.

We support worker organizing and collective bargaining, recognizing that workers who can organize and bargain collectively are better able to protect their rights and improve their conditions. We do not interfere with worker organizing efforts, and we work with suppliers to ensure that workers' rights to freedom of association and collective bargaining are respected. We understand that strong, independent worker organizations are essential to sustainable improvements in working conditions, and we support their development and effectiveness.

We measure and report on our human rights performance transparently, recognizing that accountability requires measurement and disclosure. We track key metrics including audit results, corrective action plan completion rates, worker grievance resolution, and other indicators of human rights performance. We report on these metrics in our annual sustainability report and other public disclosures, providing transparency about both our successes and our challenges. We understand that perfect human rights performance is not achievable, but transparent progress is essential, and we commit to that transparency. We recognize that stakeholders deserve to know how we are performing on human rights, and we provide that information honestly and comprehensively.