Frequently Asked Questions
What is Transparentem?
We are a non-governmental organization whose mission is to spur transparency and accelerate ethical behavior in important global industries. We work to achieve that mission by identifying and investigating endemic human and environmental abuses upstream in manufacturing supply chains. Currently, we are focused on apparel, footwear, and accessories. A public service initiative, we are not for profit and tax exempt in the United States under Section 501(c)(3) of the Internal Revenue Code.
Where are you based?
We are based in Brooklyn, NY and Washington, DC with a global investigations team.
How is Transparentem funded?
We are entirely philanthropically funded by individuals and foundations, several of which are represented on our board.
Does Transparentem solicit or accept fees or commissions from brands, retailers, or importers?
No.
Do you have a protocol regarding conflicts of interest?
Yes. Our operating procedures ensure our independence from the subjects of our work. Transparentem does not allow its funders to direct or interfere with investigations. Additionally, Transparentem has a formal conflict of interest policy applicable to all employees and directors that requires at a minimum, disclosure of any potential conflicts and recusal where appropriate.
How do you decide what to investigate?
We investigate evidence of endemic problems that affect the health and welfare of a substantial number of workers and communities. Once sufficient evidence is gathered, we strive to inform brands, retailers, and importers, who in our view, could and should accelerate positive impact not only within their own supply groups, but throughout their industries.
Are you focusing only on American and European brands and retailers?
No.
What is a PIN?
A Primary Intelligence Note (PIN) is a richly-detailed distillation of confirmed findings gathered from Transparentem’s analysts and investigators. We adhere to the highest ethical standards of investigative journalism and, to the extent consistent with our model and mission, with the Code of Ethics of the Society of Professional Journalists. We are committed to delivering an intelligence report that is responsible, accurate, specific, valuable, and most importantly, pragmatically actionable.
Who are the recipients of the PINs?
The initial recipients of our PINs are principally major brands and retailers, and include any entity whose purchasing practices and sourcing strategies can rapidly transform markets. Under confidentiality agreements in order to protect sources and methods, we may allow those recipients to view carefully-selected evidence that may not be included in the written PINs. This is to demonstrate the accuracy of our findings, while protecting vulnerable sources.
What are “grace periods”?
We offer PIN recipients time-bound grace periods starting from our first requests for meetings to discuss the PINs. During those grace periods, we agree to temporarily delay further release of the contents of the PINs, and the identities of the companies named in them, while the recipients have the opportunity to develop and implement an initial remedial action plan.
In certain cases, we may suggest that problems would be best resolved through collaboration among PIN recipients with common suppliers and/or common concerns. In such cases, we may offer to connect such brands through double opt-in introductions.
What is a CIR?
Consolidated Intelligence Reports (CIRs) are aggregate, updated PINs that include additional context and findings across all factories investigated. Critically, CIRs also reflect the responses and actions of initial recipients. Following the end of the grace periods, we do not directly disclose CIRs to the general public. However, we deliver CIRs to those who can exercise leverage for positive change. Those secondary recipients include select investors, regulators, advocacy organizations, and journalists.
How do you engage with investigated supply groups?
Investigated supply groups are welcome to provide relevant information.
Are you targeting brands and retailers?
No. Our teams investigate evidence of endemic problems upstream in supply chains and then trace those supply chains downstream. Such problems may be in direct or indirect supplier groups of brands, retailers, or importers that would be, or in our view should be, interested in learning more about our findings. The procurement strategies of brands, retailers, and importers can rapidly transform markets. We share our findings with those recipients who are well positioned to influence remediation or other actions within their supplier groups.
Why don’t you share names of the investigated suppliers before your meetings with brands, retailers, or importers?
Because electronic communications are inherently insecure, we will not disclose sensitive information until we can meet privately and in person. This is primarily to ensure the safety of vulnerable sources, including children, but also to honor the scrupulously accurate and discreet nature of our engagement with all PIN recipients during the first stage of delivery.
What if a brand is not interested in meeting with you?
In cases where a brand is unable or unwilling to meet, our policy is to share hard copies of the PINs with the intended recipient’s CEO and board members simultaneously. Included with these PINs will be copies of any correspondence, except that which we have agreed to keep confidential, with the initial recipients. The written PINs present proof of the documented abuses in fuller context, but leave out the more sensitive, detailed information, including video footage, that we are only able to present during in-person meetings.
What happens after the presentations?
At the presentations, we will deliver printed copies of the PINs to the recipients. These initial PINs may help inform subsequent internal investigations, remediation planning, and action. We ask that recipients not relay specific citations to anyone outside of their own companies. We hope to provide recipients with enough time to research and respond to the current and actionable issues outlined in the reports before they are disclosed more widely.
What do you want PIN recipients to do?
We do not prescribe or prejudge what response would best serve PIN recipients, their suppliers, or other affected parties. We present industry best-practices and case studies on potential responses, and are happy to discuss options. We remind recipients, however, that Transparentem is not the ultimate audience for their responses.
What is disclosure?
Our ultimate service is to the public. That means that regardless of company responses, we will eventually release CIRs to others, including company board members, and select investors, regulators, and journalists.
When do you disclose?
We move forward with CIR disclosure after the ends of the grace periods.
What do you disclose?
We disclose CIRs. These include any relevant new information, including:
1.) Any evidence that either confirms or is at odds with our findings;
2.) Any non-proprietary communication with supplier(s) pertinent to our investigation; and
3.) Any written response or remediation plan to the issues outlined in our investigation.