Code of Conduct for Georgetown University Licensees

I. Introduction
II. Notice
III. Remediation
IV. Compensation Policy
V. Standards
VI. Compliance and Disclosure
VII. Verification

I. Introduction

Georgetown University is committed to conducting its business affairs in a socially responsible manner consistent with its Jesuit tradition and educational mission. Georgetown University expects the same social responsibility of its licensees. Therefore, Georgetown University licensees will be expected to conduct their business in a manner consistent with, and follow workplace standards that adhere to, the following Code of Conduct.

II. Notice

The following Code of Conduct shall apply to all licensees of Georgetown University. Throughout this Code, the term “licensee” shall include all persons or entities who have entered a written license agreement with the Collegiate Licensing Company (CLC) to manufacture products bearing the name, trademarks, and/or images of Georgetown University. Additionally, this code shall apply to all of the licensee’s contractors. Throughout this Code of Conduct, the term “contractor” shall include each contractor, subcontractor, vendor, or manufacturer that engages in 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 and/or sell licensed products bearing the name, trademarks, and/or images of Georgetown University, each licensee must comply with this Code and ensure that its contractors comply with this Code. This Code constitutes a requirement for licensees pursuant to Paragraph 24 of the License Agreement. Accordingly, all licensees and contractors are required to adhere to this Code within six months.

III. 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. Georgetown University reserves the right to terminate its relationship with any licensee that continues to conduct its business in violation of this Code.

IV. Compensation 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, clothing, education, health care, transportation, and child care 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 products. Georgetown University reserves the right in the future to require licensees to pay a living wage to employees involved in the production of its licensed products if and when sufficient production facilities that meet this standard become available with an independent system to monitor compliance.

V. Standards

A. Legal Compliance

Georgetown University licensees must comply with all applicable legal requirements in conducting business related to, or involving the production or sale of products or materials bearing the name, trademarks, and/or images of Georgetown University. 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 to 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. Licensees shall report annually on their efforts to achieve a living wage standard for employees, including contracted or subcontracted workers engaged in the production of licensed products, in accordance with Section IV (“Compensation Policy”).
  2. Working Hours: Except in extraordinary 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 7-day period.
  3. Overtime Compensation: In addition to their compensation for regular hours of work, employees shall be compensated for overtime hours at such a premium rate as is legally required in that country, but not less than at a rate equal to their regular hourly compensation rate.
  4. Child Labor: No person shall be employed at an age younger than 15, (or 14, where consistent with International Labor Organization practices for developing countries, the law of the country of manufacture allows such exception). Where the age for completing compulsory education is higher than the standard for the minimum age of employment stated above, the higher age for completing compulsory education shall apply to this section. Licensees agree to work with governmental, human rights, and non-governmental organizations to minimize the negative impact on any child released from employment as 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 occuring 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 diginity and respect. No employee shall be subjected 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.
  10. Legal System: Products and materials bearing the name, trademarks, and/or images of Georgetown University shall not be manufactured or produced in any country where the local legal system would prevent Georgetown University in its sole discretion, from adequately protecting its name, trademarks, and/or images, or other interests, or from implementing any provision of this Code.
  11. Political, Economic, Social, and Human Rights Environment: Products and materials bearing the name, trademarks, and/or images of Georgetown University shall not be manufactured or produced in any country where the 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.

VI. Compliance and Disclosure

Sixty (60) days prior to the date of the annual license renewal, licensees shall disclose the following to Georgetown University:

the company names, owners and/or officers, addresses, phone numbers, e-mail addresses and nature of the business association for all the licensees’ contractors and manufacturing plants which are involved in the manufacturing process of items bearing the name, trademarks, and/or images of Georgetown University.
written assurances that it and its contractors are in compliance with this Code, and
a summary of the steps taken, and/or difficulties encountered, during the preceding year in implementing and enforcing this Code.

Note: Licensees shall immediately report to Georgetown University when changes occur that materially affect the application of these standards, such as the selection of a new factory.

VII. Verification

Internal and External Monitoring

It is recognized that clearly defined methods of internal monitoring, training, and independent external monitoring have not yet been determined by Georgetown University and its licensees. Georgetown University and its licensees agree to undertake efforts to determine and clearly define the obligations associated with the development of adequate training and monitoring methods. Georgetown University seeks to participate in the methods developed and agreed to by the White House Apparel Industry Partnership, or other selected group, provided that, among other things, there is a demonstrated commitment to independent external monitoring. In this process, Georgetown University and licensee are committed to the principles of:

  1. establishing clear evaluation guidelines and criteria,
  2. creating a database of records and information required to determine compliance with this Code,
  3. creating an informal workforce, including communicating this Code to workers in their own languages, both orally and by posting the Code in a prominent place at the factories,
  4. access on a confidential basis to the manufacturing facilities and information required to determine compliance with this Code by independent external monitors selected by Georgetown University and agreed to by the licensee,
  5. conducting periodic announced and unannounced visits on a confidential basis, of an appropriate sampling of company factories and facilities of contractors to survey compliance with this Code,
  6. opportunity for employees to report noncompliance with this Code in a manner that ensures they will not suffer retaliation for doing so,
  7. establishing relationships with labor, human rights, religious, or other local institutions,
  8. publicizing to consumers the content of this Code and the compliance by site (excluding proprietary information) with this Code by licensees, and
  9. applying and enforcing the principles set forth in the Code in a reasonable and consistent manner.