Governance
Our Compliance Steering Committee oversees our approach to ethics and compliance. This executive-level Committee operates under the leadership of our President and Chief Executive Officer and oversees the Company’s global compliance programs in numerous areas, including ethics, environment, labour and human rights, fraud, bribery, and health and safety. The Committee is accountable to the Board of Directors and reports quarterly on important compliance matters to the Corporate Governance & Social Responsibility Committee of the Board.
Five committees within Gildan report to the Compliance Steering Committee
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Ethics and Fraud Compliance
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Financial and Securities Law
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Operational Compliance
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Tax Compliance
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Information Security
Three sub-committees support the Compliance Steering Committee framework
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A disclosure sub-committee under the Financial and Securities law Compliance Committee
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A Product Safety sub-committee under the Operational Compliance Committee
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A Data Privacy sub-committee under the Information Security Committee
The Compliance Steering Committee, in turn, reports to the Corporate Governance and Social Responsibility Committee of the Board of Directors. The Audit and Finance Committee is also notified by our Internal Audit department if there is a complaint that relates to accounting, internal controls, audit matters, or if fraudulent conduct is involved. In such instances, the Audit and Finance Committee determines how the case will be handled.
Our Ethics and Compliance program is administered under the Vice-President, General Counsel and Corporate Secretary.
Our Code of Ethics, adopted by our Board of Directors, is applicable to all Gildan directors, officers, and employees, and serves as a framework in guiding the Company's operations and business practices. The Code of Ethics also guides our employees in making decisions that are consistent with Gildan's core values and guiding principles.
The Code of Ethics addresses matters that include conflicts of interest, integrity and confidentiality of corporate records and information, protection and use of corporate assets, employee relations, protection of human rights, health and safety, anti-corruption laws, insider trading, compliance with laws, and reporting of unethical or illegal behaviour.
All new employees are asked to read, acknowledge, and certify that they will comply with our Code of Ethics when they join Gildan. Employees in supervisory positions or in non-supervisory positions with job functions that require an especially high standard of compliance must complete an annual certification process.
Our Board’s Corporate Governance and Social Responsibility Committee is responsible for monitoring compliance with the Code of Ethics.
The Gildan Code of Conduct encompasses the principles set forth by the International Labour Organization (ILO), the Fair Labor Association (FLA), and various other organizations. It outlines our position on a wide range of labour and business practices and openly communicates our commitment to employees, partners, and stakeholders to always act responsibly and sustainably.
All new employees are asked to read, acknowledge, and certify that they will comply with our Code of Conduct when they join Gildan and are asked to participate in an annual training program.
Our Anti-Corruption Policy and Compliance Program outlines our policy against bribery and all other forms of prohibited payments, including facilitation payments. Anti-Corruption Compliance officers from each of our geographic sites report any instances of solicitations for prohibited payments or non-compliance with our Policy to the Compliance Steering Committee.
Reporting violations and grievances
Gildan’s Global Whistleblowing Policy for Employees and External Stakeholders details our procedures for, and response to, complaints and concerns about improper practices or questionable acts by Gildan or its employees, officers, Board members, consultants, contractors, agents, or suppliers. The Policy provides our employees and external stakeholders with communication channels that allow them to raise concerns in confidence, and anonymously if desired, without fear of reprisal or retaliation. Quarterly reports of the Ethics and Compliance Hotline are presented to the Audit and Finance Committee.
Gildan maintains a strong open-door environment. Anyone, at any time, without discomfort or fear of retaliation, can speak up about real or suspected misconduct, which helps Gildan solve problems at the source and keep issues from escalating or reoccurring. Employees can report concerns to their supervisor, department head, local Human Resources department, or Legal department. Employees can also report concerns to the:
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The Chair of the Ethics and Fraud Compliance Committee at [email protected]
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Chair of the Board of Directors [email protected]
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Chair of the Audit and Finance Committee [email protected]
Reports can be made by calling the Ethics and Compliance Hotline using a local toll-free number or by submitting a report online. The service is available in the local language of each country where we operate. This information will be kept confidential, consistent with local law and the need to conduct a thorough investigation.
Additional communication channels
In addition to the Ethics and Compliance Hotline, workers at most of our manufacturing facilities can report concerns, grievances, or complaints through our digital grievance mechanism, the Open Worker Line (OWL) app. Workers can submit feedback anonymously, as well as any supporting evidence, via their smartphone.
Other mechanisms available to employees include suggestion boxes in our facilities that allow employees to submit anonymous suggestions and/or grievances, and roundtables that allow employees to share their opinions and contribute to the management of workplace issues.
Remediation process
Gildan is committed to remediating, where legitimate concerns are identified, including concerns relating to adverse human rights impacts, and engaging and cooperating with affected stakeholders and/or their representatives in remediation efforts through legitimate processes. Gildan also commits to not obstructing access to other remedies or other state-based judicial or non-judicial mechanisms. We expect our suppliers and contractors to follow the same commitment.
Under our remediation process, Gildan's Social Compliance team works with facility managers to provide advice and recommendations on how to best address any issues, make changes where necessary, and put in place sustainable remediation solutions that are available for review and verification. Facilities shall provide details and evidence of their remediations, which are subject to verification through follow-up audits that can be conducted on-site or through a desktop review. Facilities are expected to implement remediation actions and demonstrate improvements within a prescribed timeframe.
Non-retaliation
Anyone who, in good faith, reports improper practices or questionable acts in accordance with Gildan’s Global Whistleblowing Policy for Employees and External Stakeholders procedures, or any of Gildan’s grievance mechanisms, whether anonymously or not, shall not suffer harassment, retaliation, or adverse employment consequences.