California Privacy Rights
If you are a California resident and a customer of DICK'S Sporting Goods, Inc. or its Family of Businesses, including Golf Galaxy, LLC (collectively, "DICK'S"), you have the right to request information from DICK'S regarding the manner in which DICK'S shares certain categories of your personal information with third parties, for the third parties' direct marketing purposes. California law provides that you have the right to submit a request to DICK'S at its designated address and receive the following information:
- The categories of personal information DICK'S disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year;
- The names and addresses of third parties that received such information; and
- If the nature of a third party's business cannot be reasonably determined from the third party's name, examples of the products or services marketed.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. DICK'S designated email address for such a request is email@example.com.
California Proposition 65
The Safe Drinking Water and Toxic Enforcement Act of 1986, also referred to as Proposition 65, is a California initiative to address concerns regarding exposure to toxic chemicals. Proposition 65 requires warning labels on products that contains certain levels of the 600+ elements that the California Air Resources Board considers a carcinogen or a reproductive toxicant. These elements include lead, brass, PVC and a multitude of other everyday elements.
The general Proposition 65 notice is:
WARNING: You have purchased an item that contains a chemical known to the state of California to cause cancer, birth defects or other reproductive harm.
California Transparency in Supply Chains Act
As required under the California Transparency Supply Chain Act, we are disclosing our efforts to mitigate the risk of slavery and human trafficking in our supply chain.
DICK'S Sporting Goods, Inc. is committed to fair labor practices throughout the supply chain. New and existing private brand contracted factories are regularly assessed against our Workplace Standards and Code of Conduct (below) which are based on International Labour Organization standards. Assessments are initiated based on geographic location, workplace history or previous audit record and other policy requirements. These audits are performed by DICK'S Compliance Team members and also by third party verifiers. Results are reviewed by Compliance Managers, who assist factories in remediating issues identified during audits, share key performance data with internal business partners as appropriate, and also engage with industry and NGO stakeholders to identify strategic opportunities to improve working conditions. DICK'S is a Better Work Buyer Partner (www.betterwork.org) and leverages the Better Work program to engage with key factories in countries where Better Work operates.
Each year DICK'S audits a significant percentage of our private brand contract factories to determine if they are in compliance with our standards, which in addition to requiring compliance with local laws on working hours, wages and health and safety concerns, also prohibit forced, slave or child labor. Audits are performed by DICK'S compliance personnel or third party verifiers and are semi-unannounced within a negotiated time frame. Annual and follow-up audit frequency is determined in accordance with our policy and is based in part on the level of risk and non-compliance determined by previous audit results.
As part of the supplier onboarding process, all vendors are required to certify that they conduct business in accordance with all applicable laws and regulations which include any existing laws on slavery and human trafficking in the country of manufacture. DICK'S certifies private brand factories into various risk levels and active status categories. Detailed Corrective Action Plans are required within 14 days for any non-compliance with local law or our Code. Factories must exhibit continuous improvement, transparency, and management cooperation to ensure continued certification and business eligibility. Additional follow up audits are required until high risk issues are resolved. Lack of continuous improvement may result in termination of the business relationship. Factories that demonstrate low risk and strong management systems have opportunities to reduce the frequency of audits.
The Director of Global Ethics & Compliance, who reports to the Chief Compliance Officer, is responsible for overseeing the compliance and factory monitoring programs. The Director works with the DICK'S compliance team to ensure that the Factory Compliance Policy is followed and with Product Development and Sourcing teams to integrate key performance data into the sourcing business process and to address high risk factories. In addition to requiring corrective actions and remediation of identified non-compliances, DICK'S actively encourages factories to take ownership of compliance management and implement root cause/management systems based approaches to facilitate sustainable improvement. In addition to working with factory management, DICK'S strategically communicates responsible sourcing guidelines to internal business partners and vendors and also provides "hotline" channels for workers that we engage during factory visits.
DICK'S provides annual training to relevant associates and business units on our Workplace Standards, Code of Conduct and program requirements. Training is conducted with management level associates in roles related to sourcing, product development, quality assurance and who interact with or travel to factories and may be in the best position to identify issues. Training on responsible sourcing guidelines and program expectations is also conducted in annual meetings with vendors and factories.
DICK'S Workplace Standards and Code of Conduct for Vendors
Business partners must comply fully with all legal requirements relevant to the conduct of their businesses.
Business partners must not use forced labor, whether in the form of prison labour, indentured labour, trafficked labour, bonded labour or otherwise. No employee may be compelled to work through force or intimidation of any form, or as a means of political coercion or as punishment for holding or expressing political views.
Business partners must not employ children who are less than 15 years old, or less than the age for completing compulsory education in the country of manufacture where such age is higher than 15.
Business partners must not discriminate in recruitment and employment practices. Decisions about hiring, salary, benefits, training opportunities, work assignments, advancement, discipline and termination must be based solely on ability to perform the job, rather than on the basis of personal characteristics or beliefs, such as race, national origin, gender, religion, age, disability, marital status, parental status, association membership, sexual orientation or political opinion. Additionally, business partners must implement effective measures to protect migrant employees against any form of discrimination and to provide appropriate support services that reflect their special status.
Wages & Benefits
Wages must equal or exceed the minimum wage required by law and legally mandated benefits must be provided. In addition to compensation for regular working hours, employees must be compensated for overtime hours at the rate legally required in the country of manufacture or, in those countries where such laws do not exist, at a rate exceeding the regular hourly compensation rate.
Employees must not be required, except in extraordinary circumstances, to work more than 60 hours per week including overtime or the local legal requirement, whichever is less. Employees must be allowed at least 24 consecutive hours rest within every seven-day period, and must receive paid annual leave.
Freedom of Association & Collective Bargaining
Business partners must recognize and respect the right of employees to join and organize associations of their own choosing and to bargain collectively. Business partners must develop and fully implement mechanisms for resolving industrial disputes, including employee grievances, and ensure effective communication with employees and their representatives.
Employees must be treated with respect and dignity. No employee may be subjected to any physical, sexual, psychological or verbal harassment or abuse or to fines or penalties as a disciplinary measure. Business partners must publicize and enforce a non-retaliation policy that permits factory employees to express their concerns about workplace conditions directly to factory management or to us without fear of retribution or losing their jobs.
Health & Safety
A safe and hygienic working environment must be provided, and occupational health and safety practices which prevent accidents and injury must be promoted. This includes protection from fire, accidents and toxic substances. Lighting, heating and ventilation systems must be adequate. Employees must have access at all times to sanitary facilities which should be adequate and clean. Business partners must have health and safety policies which are clearly communicated to employees. Where residential facilities are provided to employees, the same standards apply.
Business partners must ensure they are compliant with local and national laws regarding the environment, including regulatory agency requirements designed to limit consumer exposure to harmful chemicals.