Licensee Profile and Self-Assessment (LPSA)
ONLINE SELF-ASSESSMENT FOR FLA'S UNIVERSITY LICENSEES
This online self-assessment is designed for the FLA’s university licensees, particularly, Category C licensees participating in the Enhanced Licensee Program. The FLA organizes its licensees into three groups depending on different levels of annual revenues. For more information about this program and the FLA’s Licensee Programs including the different categories), please visit the FLA website at www.fairlabor.org.
GENERAL OBJECTIVE
Companies enrolled in the FLA's Enhanced Licensee Program, particularly Category C Licensees, often have limited resources to ensure compliance with the FLA code of conduct. Furthermore, their universities' relationships with their suppliers varies tremendously, ranging from universities directly owning a factory to them being indirectly linked to the production facilities through a third-party.
The Licensee Profile and Self-Assessment (LPSA) takes these differences into account and aims to provide an accurate indication of the company’s compliance program at the moment the LPSA is taken. It is also an instrument that helps develop a capacity building plan, which will allow the company to improve its compliance level. While the tools will be available for all licensees eventually, it is initially focused on Category C Licensees; this group has not previously been deeply involved in the FLA capacity building system and it is our goal to further integrate them at this point. THe FLA will next tailor the LPSA to the Category D licensees.
The information gathered through this tool will be made available to the licensee, the FLA, the licensee's participating university licensors, and licensing agents to assess the licensee's compliance level and outline the required next steps.
To cover a range of different business models, there are seven different versions available of the LPSA available covering the range of the situations relevant for licensors and licensees. The results of all tools look similar and are easily comparable.
LICENSEE PROFILE AND SELF-ASSESSMENT (LPSA) OF COMPLIANCE CAPACITY
Each LPSA has two parts:
1. A very general profile (“PROFILE”) of the company’s size and business model and sourcing practices.
2. The Self-Assessment, refers to the obligations the Licensee has committed to fulfill by joining the FLA, and assesses the level of compliance with these obligations. The Self-Assessment measures the licensee’s existing fulfillment of following company obligations identified as the priorities for Category C licensees:
- Adopt and Communicate the FLA Workplace Code of Conduct
- Train internal staff on compliance.
- Conduct internal monitoring.
- Collect and manage compliance information.
- Remediate in a timely manner.
Each of these obligations is measured through five sets of questions, which will generate results on a scale from one to five for each section, with five being the most desirable scenario, and one indicating much work needs to be done.
INITIATING CAPACITY BUILDING
The results of the LPSA are the baseline for a capacity building process that will strengthen the participant's ability to fulfill the obligations set out by the FLA. The automated LPSA results email proposes tools and trainings that can help the licensee improve its compliance based specifically on its results from the assessment. The licensee Toolkit and Resources Center,in-person orientations and more focused trainings on specific company obligations or code of conduct elements are examples of possible next steps after the assessment.
Ideally, the licensee will repeat the self-assessment on a regular basis (e.g. annually), which allows the licensee, the FLA, and the licensee's universities and agents to observe the development of the company’s compliance program and its implementation at the company and supplier levels.
FLA VERIFICATION & DUE DILIGENCE
Although the LPSA is a self-assessment tool, the FLA still performs due diligence for these affiliates. For example, companies that indicates that they discuss working conditions in their contracts with factories will be asked to submit a copy of their contract so that the FLA can verify the information, or report to the universities in cases where the companies give inaccurate information on their compliance level. Category C Licensees are randomly selected for such verification on a periodic basis and visits to US company headquarters and facilities began in the fall of 2008 and will continue. In addition, the FLA began including a sample of Category C licensees in the FLA's Independent External Monitoring (IEM) Program in 2009.
To access the LPSA questionnaire please click here.