Based on an analysis of apparel companies’ disclosure practices, it became clear that without minimum standards, companies’ efforts toward supply chain disclosures suffered from a range of deficiencies:
- A lack of a common understanding of what constituted the first tier of a brand’s supply chain. For example, not disclosing any information about authorized subcontractors like external printers, embroiderers, and laundries that are essential to producing a finished product, without which it cannot be sold.
- Publishing only a part of all cut-make-trim supplier factories, without specifying what was included.
- Omitting factories’ street addresses, making it impossible to know where in a given country or city a factory was located.
- Excluding names and addresses of factories used by licensees or agents.
- Not specifying if supplier factory information was published for all or only some brands owned by the apparel company.
- Not specifying whether the disclosure was for all or only some types of products.
- Not describing what was being excluded from the disclosure.
- Not stating what percentage of their total sourcing volume and supplier factories was published, the date the information was last updated, and how frequently such updates were made public.
- Not publishing this data in downloadable and searchable formats.