Code of Conduct
RUNNING RESPONSIBLY PHILOSOPHY
RUNNING RESPONSIBLY FOCUS
STANDARDS OF BUSINESS ETHICS
CODE OF CONDUCT
SOURCING STRATEGY
SUPPLIER MONITORING AND REMEDIATION
SUPPLIER TRAINING
COMMUNITY ENGAGEMENT
GREEN ROOM
INITIATIVES / PARTNERSHIPS
PRODUCT SAFETY
PROGRESS AND FOCUS AREAS
FREQUENTLY ASKED QUESTIONS
RUNNING RESPONSIBLY PHILOSOPHY 
We believe that over time, a brand will reflect the values of the people who are its stewards. Brooks’ purpose is to inspire people to run and be active. We strive to approach this purpose with authenticity, passion, focus, and energy. We know - always acting with integrity, respect, and excellence will be required to deliver on this purpose. We apply these principles to our relationships with customers, consumers, and environments in which we run - and run our business.
At Brooks we care about more than whether you buy our product. We hope you do and we’re confident you’ll enjoy our products, but our interests run deeper than that.
We care about people and the world we all share. We care about healthy bodies and healthy minds. We care about our role in fostering an environment where life can thrive for the long run. We are committed to building great running gear with minimal impact on humanity and the earth.
So what does this mean? For Brooks, it’s a way of doing business–a way of life. It’s about being aware of our environmental footprint and respectful of the people who make and use our gear. It’s an inherent, proactive choice to be agents of change. It’s about community support and a socially responsible code of conduct. And it’s about environmental stewardship and doing our part to find acceptable alternatives to non-renewable and toxic materials, energy sources, and manufacturing practices.
Protecting humanity and the earth is a lifelong race. And we’re running it..
RUNNING RESPONSIBLY FOCUS
Brooks is committed to conducting its business in accordance with the highest standards of business ethics and respect for the environment and human rights. In short, we care about people and the world we all share. We care about our role in fostering an environment where life can thrive for the long run. Brooks takes an active role in social issues and, above all, the safety and fair treatment of all personnel involved in making and marketing our products.
STANDARDS OF BUSINESS ETHICS
A business run without a conscience will not flourish, inspire, or succeed. Beyond what is required from us by law, Brooks supports and adheres to the ethical business standards set by our parent company, and these guiding words from Berkshire Hathaway Inc.’s CEO Warren Buffett:
“…I want employees to ask themselves whether they are willing to have any contemplated act appear the next day on the front page of their local paper – to be read to their spouses, children and friends – with the reporting done by an informed and critical reporter.”
CODE OF CONDUCT
Brooks Sports, Inc. (“the Company”) is committed to conducting its business in accordance with the highest standard of business ethics and respect for human rights, and in compliance with all applicable laws. We require our suppliers, licensees, distributors, and other business partners to work toward and meet these standards.
While the Company recognizes that different cultural, legal, and ethical systems exist in the countries in which merchandise may be manufactured, this Code of Conduct sets forth certain basic requirements that all facilities domestic and foreign - whether owned by the Company or our contractors, licensees, or other business partners - must satisfy.
Compliance with Law: The Company requires all manufacturing facilities to operate in conformance with the requirements of applicable law.
Safety and Health: Conditions throughout the facilities must be safe, clean and meet or exceed requirements of all applicable laws and regulations regarding safety and health. Workers must be trained and equipped to perform their jobs safely.
Child Labor: No person shall be employed at an age younger than the age for completing compulsory schooling in the country of manufacture, or the age consistent with International Labor Organization guidelines, whichever is greater. All Company authorized facilities must observe all legal requirements for work of all employees, particularly those pertaining to hours of work and working conditions.
Forced Labor: The use of forced or compulsory, indentured, or bonded labor is prohibited.
Harassment or Abuse: Corporal punishment or other forms of harassment, abuse or coercion, whether mental or physical, are strictly forbidden.
Discrimination: Discrimination in hiring, pay, promotions, discipline, termination, or other terms and conditions of employment based on personal characteristics, beliefs, or other legally protected criteria, is prohibited.
Working Hours: Except in extraordinary business circumstances, employees shall (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 and
(ii) be entitled to at least one day off in every seven day period.
Wages and Benefits: The Company requires that employees be fairly compensated by providing wages, including overtime pay, and benefits that meet or exceed all applicable laws and regulations.
Freedom of Association: The Company recognizes and respects the rights of employees to freedom of association and collective bargaining.
Environmental Compliance: The Company requires compliance with all local laws protecting the environment. In addition, business should be conducted in a manner that minimizes all waste and maximizes recycling, and which results in proper storage and disposal of hazardous substances.
Customs Compliance: The Company will comply with all applicable customs laws and establish and maintain programs to safeguard against the illegal transshipment of products.
Security: The Company will maintain security procedures to guard against the introduction of non-manifested cargo (drugs and other contraband) into shipments of our products.
Notice and Record Keeping: This Code of Conduct must be posted in a location accessible to all employees and visitors (in the appropriate language).
Enforcement: The Company employs internal, as well as third-party auditors to ensure compliance with this code at all locations conducting business for the Company. The Company maintains detailed records of all facilities to determine compliance with this policy.
Violations: To report suspected violations of this Code of Conduct, contact the Company at
P.O. Box 90015,
Bowling Green, KY 42102-9015
or call the Human Resources department at (270) 781-6400.
SOURCING STRATEGY
“Nice to meet you, let’s shake on it!” doesn’t cut it for Brooks. In our efforts to establish solid, long-term, and mutually beneficial relationships with business partners, we are very careful when selecting our manufacturers. We make certain each one meets our social compliance standards prior to establishing a business relationship. We visit the factory, observe its facilities, and conduct a third-party social compliance audit to approve the manufacturer prior to production of one Brooks shoe or technical garment in that facility. Our commitment to quality leads us to pursue business partners with the best facilities and working conditions.
SUPPLIER MONITORING AND REMEDIATION
How do we make sure our business partners maintain a good working environment? We monitor our factories through regular visits and reports on general conditions received from our internal quality control inspectors onsite. Additionally, all factories are reviewed at partnership onset and then annually by an independent third-party auditor that assesses safety and labor conditions. These audits are unannounced and include a physical inspection of the factory, review of documents and procedures, and employee interviews. After each audit, a follow-up inspection is conducted within 60 to 90 days to check for continued compliance and remediation of any reported concerns.
SUPPLIER TRAINING
No one likes to be handed a book of rules. Instead, we prefer to take a more integrated approach to CSR training. We sit alongside our partners to educate them on social and environmental principles, working together to identify and address root cause compliance issues in order to achieve sustained improvements. Suppliers learn about labor code requirements of the country of manufacture, environmental responsibility, supply chain security, and the fundamentals of CSR project management. The onsite training content is customizable; it’s driven by answers to a questionnaire filled out by suppliers on what they would like to learn. We offer it for free to all active partners and provide it in the local language of the attendees. We even throw in all meals!
COMMUNITY ENGAGEMENT
Brooks’ purpose of inspiring people to run and be active extends to our corporate giving program, Run B’cause. The program lends support in the form of in-kind product donations to organizations, individuals, and events that share our passion for sport and a healthy lifestyle. Employees also receive paid time off each year to participate in community group projects benefitting various causes in Brooks’ backyard. We are only as strong as our communities, and we recognize our ability - and our responsibility - to do what we can to make a positive impact on the planet and the people we share it with.
GREEN ROOM
Beyond proper gear, running requires little more than energy and desire. No membership dues, no travel expenses, no lift tickets, or greens fees. The only other necessities to enjoy a good run are a safe running surface, clean air, and fresh water..
That means we at Brooks are intrinsically linked to nature. Linked in how our materials are sourced, and how our gear is manufactured. Linked in how our products are used and what happens to them at the end of their life cycles.
A spirit of authenticity and truth pervades all we do. We realize that simply by creating product, we’re also creating a byproduct of environmental impact. We are conscious of this fact and work tirelessly to adapt our efforts to support the needs of our changing planet.
Visit our Green Room to learn more how we’re trying to meet the responsibility we have to preserve our environment.
INITIATIVES / PARTNERSHIPS
Brooks works actively with reputable outdoor industry and environmental organizations to share ideas and analyze our current business practices and their impact on people and the earth. For example:
We are an active member of the Outdoor Industry Association (OIA) Eco Working Group. Consisting of more than 60 outdoor businesses, the Eco Working Group (EWG) was formed by OIA in 2007 to explore the issues of environmental sustainability as related to the outdoor industry. In addition to general group convenings and activities, Brooks employees are members of the EWG’s Materials and Consumer Packaging subgroups.
Brooks recently partnered with The Bainbridge Graduate Institute to benchmark our company's sustainable business practices. After providing an initial evaluation of Brooks' social and environmental impact, the Institute counseled us on how to make additional improvements beyond programs currently in place. As a result, we've already made advancements in areas such as office operations, footwear design and development procedures, marketing and communication, carbon footprint evaluation, and more.
Brooks Sports is also a member of Business for Social Responsibility (BSR), a nonprofit business association that provides socially responsible business solutions to many of the world's leading corporations. Through advisory services, convenings, and research, BSR works with corporations and concerned stakeholders of all types to create a more just and sustainable global economy. Brooks is a member of BSR’s Ethical Sourcing Working Group, which meets semiannually to discuss social responsibility and environmental trends, partnership opportunities to improve health education and working conditions in the global supply chain, and share best practices amongst brands.
We recognize sustainability is a process and will continue to develop supporting efforts on an ongoing basis. We currently work with sustainability advisors from OASIS Environmental and Sustainable Business Consulting to further our progress.
In addition to the affiliations listed above, Brooks also works with the following industry organizations:
BioEnvironmental Polymer Society
Society of Plastics Engineers’ Environmental Plastics Technical Division
American Society for Testing and Materials’ Environmental Plastics Technical Committee
Conservation Alliance
PRODUCT SAFETY
Brooks Sports hereby certifies that our products are in compliance with all rules, bans, standards, and regulations applicable under the Consumer Product Safety Improvement Act (CPSIA) of 2008. General Conformity Certificates are available to retailers and U.S. Customs by emailing us at CPSIA@brooksrunning.com or contacting Brooks’ Customer Service team at 877-427-5296. Additionally, Brooks currently tracks more than 140 chemicals that are restricted from use in our products, and we’re in the process of building out a chemical responsibility validation program to further this effort. We also continue to monitor changes in global restricted substance legislation (e.g. REACH) that might impact our products. We are making changes to our policies, manufacturing, and sourcing processes as needed.
PROGRESS AND FOCUS AREAS
Protecting humanity and the earth is a lifelong race. We’ve enacted significant positive advancements in areas such as factory remediation, supplier training, materials sourcing, product design and development, and packaging and collateral. But at the same time, we know our effect on people and the environment isn’t all roses and rainbows. We recognize our current challenges and shortcomings, and we’re focusing efforts toward finding solutions to lessen our impact in those areas. For example:
We continue to work on supply chain issues with respect to working hours. We partner with great factories, but a few still tend to work more hours than allowed. Problems often stem from a lack of adequate policies and procedures at the factory level, but also from root causes such as delays of orders or material deliveries. We’re currently developing a management system to address the root causes, and we’re increasing training with factory partners on other issues that heavily affect hours of work, such as production planning and risk management (e.g. last-minute orders).
On the environmental side, we continue to seek eco-friendly materials that are cost efficient and stand up to the rigors of running - the performance demands of our technical products. Materials boasting both solid environmental and performance attributes are becoming more accessible, but the price of these materials still remains high. Industry surveys say our consumers are willing to pay a bit more for more eco-friendly products, but there’s a pricing threshold they won’t cross. Through our Design for Environment approach, we have found ways to offset some of these higher material costs, such as using fewer parts and finding more efficient manufacturing processes.
Our ability to monitor and affect upstream supply chain compliance and practices is also a work in progress. Our list of direct production factories is relatively short, and we have effective programs in place to ensure compliance. But it’s harder to monitor the material suppliers and other sub-suppliers upstream. For example, while we actively track 140 restricted substances, it’s a challenge to chase accurate information the further upstream you go. While we are working toward more effective and responsible partnerships with these upstream suppliers, this area continues to require focus and attention from us.
FREQUENTLY ASKED QUESTIONS
Where does Brooks manufacture its products?
While we design, engineer, and specify every component and stitch of our high performance running gear in the U.S., we manufacture in factories around the world. Countries of manufacture include China, Malaysia, Vietnam, Taiwan, Korea, Turkey, Greece, Israel, the Philippines, Thailand, and Canada.
How do you choose where your products are made?
Brooks only makes high performance, technical running gear sold through premium retail channels. We believe our product quality standards are the highest in the industry, and our consumers expect nothing less from us. To maintain these standards, we work with the best partners in the business. While we design, engineer, and specify every component and stitch of our gear in the U.S. - where Brooks is headquartered - we manufacture in factories around the world where the infrastructure, resources, capacity, and reasonable cost of goods for building such product exists.
How do you pick your factories?
In our efforts to establish solid, long-term, and mutually beneficial relationships with business partners, we are very careful when selecting our manufacturers. We make certain each one meets our social compliance standards prior to establishing a business relationship. We visit the factory, observe its facilities, and conduct a third-party social compliance audit to approve the manufacturer prior to production of one Brooks shoe or technical garment in that facility. We also require factories to commit to not using restricted substances in the production of our gear. Our commitment to quality leads us to pursue business partners with the best facilities and working conditions.
How much communication do you have with your factories?
We have continual communication with all factory partners. Our sourcing directors and developers visit our factories regularly and communicate with our factories daily. In addition to our third-party social compliance and security audits, our internal quality control inspectors conduct audits regularly at these facilities.
Does Brooks ever sever relationships with factories that violate the Company’s Code of Conduct?
Yes, we have. Brooks selects partners carefully and commits to educating our suppliers on social and environmental principles so that if any problems arise, we can work together toward continuous improvement in these areas. It is our policy to encourage and help the factory to make necessary changes. If the factory is unwilling to make improvements, we will terminate the relationship.
Which countries supply your more environmentally friendly shoes?
All Brooks shoes are designed in the U.S. and manufactured in Southern China.
Have countries that make Brooks shoes ratified and given effect to the core International Labor Organization (ILO) conventions?
All Brooks products are designed and engineered in the U.S. and manufactured in Southern China. China has ratified four of the fundamental ILO conventions on discrimination (C.100 , C.111) and child labor (C.138, C.182). Since China has not ratified all of ILO’s principals, we require our factories to sign a “Working Conditions Policy and Commitments” document in which they agree to be in compliance with the local labor laws (including age requirements, fair wages); not employ child/forced/slave labor; and provide adequate food, housing, and medical coverage to all employees.
Is there a process by which workers can make complaints if their rights are not being respected your suppliers?
Yes, we have phone number and address through which workers can make complaints if their rights are not being respected by our suppliers. A third-party service is contracted to provide us with the translations for any calls or letters received. The address and phone number is located in our Code of Conduct, which is posted in each of our factories in a location accessible by all employees and in the local language spoken by the workers.
What steps does Brooks take to address complaints when they are brought to the company?
Our Human Resources management team at our parent company, Fruit of the Loom, reviews all calls and letters. If an investigation is required, Fruit of the Loom works with Brooks to explore and rectify, if necessary, any violation(s) claimed by the caller.
What is Brooks’ carbon footprint?
Brooks recently partnered with The Bainbridge Graduate Institute to benchmark our company's sustainable business practices and attempt to wrap our heads around our carbon footprint. While we have a sense of the environmental impact we create through shipping, travel, and operations at our corporate office and distribution center, one of our most significant environmental impacts occurs at the factory level. At this time, we do not have accurate carbon footprint assessments from our factories. The picture muddies as you begin to look up the supply chain toward materials we source and what impact those sourcing partners incur to develop the technologies we use. Given all this, arriving at an accurate and complete carbon footprint figure becomes even more challenging. That won’t change until universally accepted tracking measures are in place. So in lieu of a way to pinpoint our total carbon footprint at this time, we currently focus more on eco-improvements we know we can make and track, such as our Design for Environment approach toward creating product. We currently work with sustainability advisors from OASIS Environmental and Sustainable Business Consulting to further our progress in areas such as carbon footprint.
How do we incorporate sustainability into our business?
Brooks is a company full of employees who are active, enjoy the outdoors, and are vocal about their personal interests to protect the environment. This grassroots passion gives us a firm foundation on which to build sustainability efforts. But running an entire business and making strategic decisions with sustainability as a key pillar is no easy task. It’s an ongoing journey that’s as challenging as it is exciting. At Brooks, eco-efforts are incorporated into our core business values. That means every employee has the power to think and act on the job with the environment in mind. We have a strategic sustainability team tasked with driving the vision and focus for our efforts, and we are creating individual goals company-wide. Sustainability doesn’t rest on the shoulders of one individual or team; we all contribute the problem…and the solution.
