Code of Conduct for Georgetown University Licensees

I. Introduction

II. Notice

III. Standards

IV. Living Wage Policy

V. Disclosure

VI. Monitoring and Investigation

VII. Remediation

VIII. Termination

I. Introduction

Georgetown University is committed to conducting its business affairs in a socially responsible manner consistent with its Catholic and Jesuit tradition and educational mission. Georgetown University expects the same social responsibility of its licensees. Therefore, Georgetown University licensees are required to conduct their business in a manner consistent with, and follow workplace standards that adhere to, this Code of Conduct (“Code”).

II. Notice

This Code shall apply to all licensees of Georgetown University. Throughout this Code, the term “licensee” shall include all persons or entities who have entered into a written license agreement with Georgetown University or its designated trademark licensing agent to manufacture products bearing the name, trademarks, or images of Georgetown University (“licensed articles”). Additionally, this Code shall apply to all of the licensee’s contractors. Throughout this Code, the term “contractor” shall include each contractor, subcontractor, vendor, or manufacturer that engages in a manufacturing process that results in a finished product for the consumer. “Manufacturing process” shall include assembly and packaging.

As a condition of being permitted to produce or sell licensed articles, each licensee must comply with this Code and ensure that its contractors comply with this Code.

III. Standards

A. Legal Compliance

Licensees must comply with all applicable legal requirements in conducting business involving the production or sale of licensed articles. Where there are differences or conflicts with this Code and the applicable laws of the country of manufacture, the higher standard shall prevail. Whenever there is uncertainty as to which standard is higher, Georgetown University will consult with the licensee and governmental, human rights, labor, or business organizations and determine which standard will prevail.

B. Environmental Compliance

Licensees will be committed to the protection and preservation of the global environment and the world’s finite resources, and conduct business accordingly.

C. Ethical Principles

Licensees will be committed in the conduct of their business to a set of ethical standards which include, but are by no means limited to honesty, integrity, trustworthiness, and the respect for the unique intrinsic value of each human being.

D. Employment Standards

Georgetown University will only do business with licensees whose workers are present at work voluntarily, not at undue risk of physical harm, fairly compensated, and not exploited in any way. In addition, the following specific guidelines must be followed:

  1. Wages and Benefits: Licensees recognize that wages are essential to meeting employees’ basic needs. Licensees must provide wages and benefits which comply with all applicable laws and regulations, and which match or exceed the local prevailing wages and benefits in the relevant industry.
  2. Working Hours: Licensees shall not require employees to work more than the regular and overtime hours allowed by the law of the country where workers are employed. The regular work week shall not exceed 48 hours. Employees shall be entitled to at least one day off every seven-day period. All overtime hours must be worked voluntarily by employees. Licensees shall not request overtime on a regular basis. Other than exceptional circumstances, the sum of regular and overtime hours in a week shall not exceed 60 hours.
  3. Overtime Compensation: In addition to their compensation for regular hours of work, employees shall be compensated for all overtime hours at such a premium rate as is legally required in the country of manufacture or, in those countries where such laws do not exist, at a premium rate determined by the licensee.
  4. Child Labor: No person shall be employed at an age younger than 16, or the age for completing compulsory education or the country’s legal working age, whichever is higher. Licensees agree to work with governmental, human rights, and non-governmental organizations to minimize the negative impact on any child released from employment as a result of the enforcement of this Code.
  5. Forced Labor: There shall not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor, or otherwise.
  6. Health and Safety: Licensees shall provide a safe and healthy working environment to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of licensee facilities.
  7. Nondiscrimination: No person shall be subject to any discrimination in employment, including hiring, salary, benefits, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin.
  8. Harassment or Abuse: Every employee shall be treated with dignity and respect. No employee shall be subject to any physical, sexual, psychological, or verbal harassment or abuse. Licensees will not use or tolerate any form of corporal punishment.
  9. Freedom of Association and Collective Bargaining: Licensees shall recognize and respect the right of employees to freedom of association and collective bargaining. No employee shall be subject to violence, threats, intimidation, retaliation, discrimination, harassment or abuse in their efforts to freely associate or bargain collectively. Licensees shall not interfere with the formation or operation of a union representing employees. Licensees shall recognize the union of the employees’ choice. Where a country’s legal system restricts freedom of association, licensees shall take affirmative measures to achieve the maximum level of respect for freedom of association that is consistent with applicable laws.
  10. Legal, Political, Economic, Social, and Human Rights Environment: Licensed articles shall not be manufactured or produced in any country where the legal, political, social, economic, or human rights environment as determined by Georgetown University, would prevent conducting of business in a manner that is consistent with this Code.
  11. Pregnancy:
    1. Pregnancy tests will not be a condition of employment, nor will they be demanded of employees.
    2. Workers who take maternity leave will not face dismissal, threat of dismissal, loss of seniority, deduction of wages, or other discriminatory treatment and will be able to return to their former employment at the same rate of pay, benefits, and working conditions.
    3. Workers will not be forced or pressured to use contraception.
    4. Licensees shall provide appropriate services and accommodations to workers who are pregnant or have recently given birth.

IV. Living Wage Policy

Georgetown University believes that employees have the right to earn wages that enable them to meet their basic needs, which is known as a living wage. Basic needs include the cost of housing, energy, nutrition, safe drinking water, sanitation facilities, clothing, education, health care, transportation, child care, and some discretionary income for an employee and two dependents. When making licensing decisions, Georgetown University will give preference to current or prospective licensees that pay a living wage at one or more factories involved in the production of its licensed articles. Georgetown University reserves the right to require licensees to pay a living wage to employees involved in the production of its licensed articles if and when sufficient production facilities that meet this standard become available with an independent system to monitor compliance

Licensees shall report annually on their efforts to achieve a living wage standard for employees and contracted or subcontracted employees engaged in the production of licensed articles.

V. Disclosure

On not less than a quarterly basis, licensees will disclose to Georgetown University or its designated trademark licensing agent information regarding manufacturing facilities involved in the manufacturing process of licensed articles. For each manufacturing facility, licensees will provide information requested by Georgetown University or its agent, which will include but not be limited to the company name, owners or officers, contact person, address, phone number, email address, products produced, and nature of business association with the licensee.

VI. Monitoring and Investigation

Georgetown University has designated the Worker Rights Consortium (“WRC”) as its independent labor rights monitor for the purpose of conducting investigations of factories manufacturing licensed articles. Licensees will use their best efforts, using all available economic leverage including exit, to facilitate access by the WRC’s employees and agents to a factory under investigation, including its facilities and personnel. Licensees will use their best efforts to ensure the WRC has access to physical or electronic records needed to complete its investigation. Licensee will comply with the WRC’s protocols for factory investigations. Licensee will not retaliate against employees for reporting noncompliance with this Code.

VII. Remediation

If Georgetown University determines that any licensee or contractor has failed to comply with this Code, then upon consultation with the licensee, the University may require that the licensee implement a corrective action plan on terms acceptable to Georgetown University. The remedy will, at a minimum, include immediately taking all necessary steps to correct such violations including, and without limitation, paying all applicable back wages, or any portion of them, found due to workers who manufactured the licensed articles. Licensees will use their best efforts, including all available economic leverage including exit, to cause contractors to remediate any violations identified by Georgetown University’s designated labor rights monitor.

VIII. Termination

Georgetown University reserves the right to terminate its license agreement with any licensee that conducts its business in violation of this Code.