POLICY · AUSTRALIA, NEW ZEALAND AND THE UNITED STATES

Modern Slavery Policy & Supplier Code of Conduct

OCC Apparel does not tolerate modern slavery in any form, in our own business or in our supply chain. Our Modern Slavery Policy and Supplier Code of Conduct sets out that commitment and the minimum standards we expect from everyone who makes, decorates or supplies goods and services for us.

The policy applies to Outdoor Clothing Concepts Pty Ltd (trading as OCC Apparel) and its related entities in Australia, New Zealand and the United States, to all our directors, employees, contractors and remote team members, and to all our Suppliers: garment and product manufacturers, fabric and yarn suppliers, decorators, freight and logistics providers, agents and their subcontractors.

Effective 1 July 2025 · Policy owner: Nick Barclay, Managing Director and CEO · Signed 9 November 2026

Download the signed policy (PDF)

What we prohibit

OCC Apparel prohibits our workers, agents and Suppliers from engaging in, or benefiting from:

Forced or compulsory labour, including prison labour, bonded or indentured labour, and work done under threat of penalty
Human trafficking
Debt bondage and servitude, including recruitment fees charged to workers and the withholding of wages, identity documents or travel documents
Child labour and the worst forms of child labour

We will not knowingly do business with any person or organisation involved in these practices.

Our Supplier Code of Conduct

Every Supplier must meet our Code of Conduct, which is based on the International Labour Organization (ILO) core conventions, and make sure its subcontractors meet it too. The Code covers:

Legal compliance
No child labour, with a minimum working age of 15 (or higher where local law requires) and no hazardous work, night work or overtime for workers under 18
No forced labour, no withheld documents or wages, and no recruitment fees charged to workers
No discrimination, and no harsh or inhumane treatment
Freedom of association and collective bargaining
Fair wages, reasonable working hours and safe, healthy workplaces
A legal employment relationship, written work agreements and right-to-work checks
No subcontracting of OCC work without our written approval, and access for inspections and audits
Cotton origin: no cotton, yarn, fabric or finished goods from the Xinjiang Uyghur Autonomous Region or Turkmenistan, or from any region or producer named by a government as using state-imposed forced labour, and traceable fibre origin on request
Supplier policies and a modern slavery risk assessment before onboarding and at least once a year

How we manage risk

We map who makes and decorates our products, assess new Suppliers before onboarding, prefer independently certified supply, require a signed commitment to this Code, ask for current certificates and audit reports at least once a year, and complete independent modern slavery risk assessments. We review our risk assessments, Supplier ratings and improvement actions every year.

All OCC staff, including remote team members, complete modern slavery awareness training when they join and every year after that.

Supplier ethics documents

Our core blank brands publish their own independent social reports, audits and certificates. We make them available here so clients and auditors can see how the supply chain behind our products is checked. Each document is published by the supplier or its certifier and is reproduced unchanged.

Earth Positive® (Continental Clothing Co.)

Continental Clothing has been a Fair Wear member brand since October 2006. Fair Wear’s Brand Performance Check for 2024 placed it in the Leader category, with a benchmarking score of 86. Its 2026 Social Report describes a living wage programme, running for nine years, that pays wage premiums to workers at its primary supplier in Tirupur, India.

Stanley/Stella

Stanley/Stella has been a Fair Wear member since December 2011. Fair Wear’s Brand Performance Check for 2024 placed it in the Leader category, with a benchmarking score of 84.

AS Colour

AS Colour publishes an annual Modern Slavery Statement under Australia’s Modern Slavery Act 2018 (Cth), approved by its Board. Its FY25 statement covers 1 April 2024 to 31 March 2025 and describes its partnerships with amfori (supplier auditing), Better Cotton and Baptist World Aid, and the steps it takes to address cotton risks linked to the Xinjiang region.

Modern Slavery Statement FY25 (PDF)

Gildan

Gildan has been a member of the Fair Labor Association (FLA) since 2003, and its social compliance programme is FLA-accredited. Gildan owns and operates most of its manufacturing.

Modern Slavery Report (2025 reporting year, published 2026) (PDF)

Certificates are valid for the dates shown on each document. We replace them as suppliers issue renewals. For the latest certificates for a specific product, email us.

Raise a concern

Anyone, including OCC staff, Supplier workers, clients and members of the public, can report a concern about modern slavery in OCC Apparel’s business or supply chain. Write to our Managing Director at nick@occapparel.com.au. Reports can be made anonymously, are handled confidentially, and we will not tolerate retaliation against anyone who raises a concern in good faith.

If a breach is found, we put the affected workers’ safety and wellbeing first, agree a written corrective action plan with the Supplier, check that it is completed, and end the relationship if the Supplier refuses to act, fails to improve, or the breach is severe.

Suppliers and clients

Suppliers sign the acknowledgement at the end of the policy as part of every supply arrangement. Clients can download our signed policy above and our suppliers’ documents in the Supplier ethics documents section, or email us for a copy.

This page summarises the policy. The signed PDF is the full and binding version. The policy is reviewed at least once a year.