WRC Update: Implementation of Forced Labor Guidance

To:WRC Affiliate Universities and Colleges
From:Scott Nova
Date:December 21, 2020
Re:WRC Update: Implementation of Forced Labor Guidance

I write to update you concerning the implementation of the WRC’s recent guidance to university licensees on compliance with university codes of conduct during the forced labor crisis in the Uyghur region of China (also known as the Xinjiang Uyghur Autonomous Region or “XUAR”).

The WRC’s guidance advises licensees not to source collegiate goods from companies that have been implicated in forced labor in the Uyghur Region. Our guidance lists six of these companies: Esquel Group, Huafu Fashion, Lu Thai Textile, Jinsheng Group, Youngor Group, and Shandong Ruyi Technology Group. The guidance applies to all factories owned and operated by these companies.

Recently, the WRC and licensing agents engaged with a number of licensees concerning this issue:

  • In October, Exemplar Associates contacted licensee Cutter & Buck concerning the latter’s use of a factory in Myanmar called Lu Thai (Myanmar) Co. The factory is owned by Lu Thai Textile. Although Lu Thai Textile recently changed the factory’s name to Vanguard Apparel, Exemplar made clear to Cutter & Buck that, consistent with the WRC’s guidance, because the factory is still owned by Lu Thai Textile, it should not be used for the production of collegiate goods. On December 3, Cutter & Buck informed Exemplar that by the end of this month it will cease doing business with this factory. We appreciate Exemplar’s engagement and the licensee’s decision to stop doing collegiate business with Lu Thai Textile.
  • This month, CLC contacted licensee Peter Millar concerning its use of another Lu Thai Textile-owned factory to make collegiate products. That factory is in China. Peter Millar responded to CLC by reporting that it has shifted production to a factory in Vietnam that is also owned by Lu Thai Textile, named Lu An Garment Co. According to Peter Millar, Lu Thai Textile says it is using cotton from the US and Australia at this facility. Last week, the WRC wrote to Peter Millar advising the licensee that it should not be sourcing collegiate goods from any factory owned by a company implicated in forced labor, including Lu Thai Textile, regardless of where the raw material for its goods originates. We have asked for Peter Millar’s prompt response, and we will update schools when it is received.

The WRC is also pursuing inquiries with other licensees whose recent supplier disclosure data indicate that they may be using companies implicated in forced labor for production of collegiate goods, and we will provide further updates when available.

As always, let us know if you have any questions about this information.