Forced and Child Labor Policy

Forced and Child Labor Policy

Issued On: August 1, 2024 | Last Updated On: April 26, 2025

This Forced and Child Labor Policy (“Policy”) outlines the standards and member obligations regarding the prevention of forced labor, human trafficking, and child labor within the Global Fashion Directory LLC (“GFD,” “we,” “us,” or “our”) platform and its supply chains. By accessing or using GFD’s services, you (“you,” “your,” or “User”) agree to comply with the terms outlined in this Policy and uphold ethical labor practices consistent with international, federal, and local laws.

This Forced and Child Labor Policy is part of GFD’s Terms of Service and is incorporated by reference into those Terms. By accessing or using any part of the Platform, you agree to be bound by the Terms of Service and this Forced and Child Labor Policy.

1. Scope and Applicability

The Global Fashion Directory (GFD) is committed to promoting ethical labor practices across the fashion industry and maintaining full compliance with international, federal, and local laws prohibiting forced and child labor. This policy applies to all GFD members, their operations, and supply chains, and is designed to align with the requirements of U.S. federal funding agencies and international standards.

  • The California Transparency in Supply Chains Act.
  • U.S. Federal labor laws, including the Fair Labor Standards Act (FLSA)
  • U.S. Federal Acquisition Regulation (FAR) 52.222-50 (Combating Trafficking in Persons)
  • European Union labor directives
  • International Labour Organization (ILO) Conventions No. 29, 105, 138, and 182

Members also agree to adhere to any future laws, regulations, or ethical requirements GFD may adopt to remain in alignment with emerging industry standards or federal compliance mandates.

2. Prohibition of Forced Labor

Members must ensure that their operations and supply chains are free from forced labor, including but not limited to:

  • Human Trafficking: No worker may be recruited, transported, harbored, or employed through coercion, fraud, or abuse of vulnerability.
  • Debt Bondage: Workers must not be required to work to repay recruitment fees or debts incurred through employment.
  • Coercion: Practices such as withholding passports, wages, or personal documentation to restrict worker freedom are strictly prohibited.

3. Prohibition of Child Labor

  • Minimum Age Standards: Members must adhere to national laws on minimum employment age and, at a minimum, to International Labour Organization (ILO) Convention No. 138.
  • Protection of Young Workers: Workers under the age of 18 must not be engaged in hazardous work, or in roles that interfere with education or development, per International Labour Organization (ILO) Convention No. 182.

4. Member Certification and Accountability

By participating in GFD, members certify their ongoing compliance with this policy and applicable laws. Members further agree to:

  • Submit accurate information regarding their labor practices
  • Promptly notify GFD if any risks or violations are identified in their supply chain
  • Cooperate with audits, documentation requests, or other verification processes initiated by GFD

5. Monitoring, Verification, and Risk-Based Due Diligence

GFD may verify member compliance through:

  • Annual Verification: Members must reconfirm their compliance as part of GFD’s annual platform review.
  • Triggered Audits: GFD reserves the right to request documentation or initiate a review in response to credible reports, risk assessments, or changes in business operations.
  • Corrective Action Plans (CAP): Where violations are identified, members may be asked to implement corrective actions within a defined timeframe.

GFD encourages members to conduct internal audits and adopt third-party verification tools to proactively monitor supply chain risks.

(See full Terms of Service and Subscription Agreement for details on annual verification.)

6. Reporting and Investigations

  • Confidential Reporting: Members or third parties may report potential violations to GFD at info@globalfashiondirectory.com . All reports are treated confidentially.
  • Investigation Procedures: GFD will investigate reports promptly, and may request evidence, supplier documentation, or audit results. Non-cooperation may result in temporary account suspension.

(See full Dispute Resolution Policy for detailed procedures.)

7. Consequences of Non-Compliance

Violations of this Policy may result in:

  • Immediate suspension or termination of membership
  • Public disclosure of verified violations only in accordance with applicable law and GFD’s terms of use.
  • Reporting to federal or international authorities, if required under applicable law (e.g., FAR 52.222-50)

GFD reserves the right to take any necessary action to protect the integrity of the platform and meet legal or ethical obligations.

8. Policy Updates This Policy will be reviewed annually and may be updated to reflect legal developments, evolving best practices, or new requirements set by U.S. or international regulatory bodies. Members will be notified of any material changes and are expected to comply with the updated Policy upon notice.