Due Diligence Procedure

Due Diligence Procedure – GOTS

As part of our ethical and sustainability commitment, KeaBabies conducts a comprehensive Due Diligence Procedure that integrates GOTS principles into our operations and supply chain practices. This procedure covers the GOTS Chemical Input Criteria, Environmental Criteria, Human Rights and Social Criteria, and Governance Criteria. The process is tailored to our operational scale, business model, and risk exposure.

4.1.1 Integration of Due Diligence Framework at KeaBabies

KeaBabies implements the six-step due diligence approach as follows:

  1. Policy & System Integration
     We embed responsible business conduct into our internal policies, supplier onboarding documentation, compliance SOPs, and sourcing strategy. These systems are integrated across departments — including Product Development, Sourcing, Quality Assurance, and Marketing.
  2. Impact Identification
     We actively assess actual and potential adverse impacts in our operations and supply chain — including:
    • Chemical safety and restricted substances
    • Labor risks (e.g., fair wages, safe work environments)
    • Environmental footprint (e.g., water/energy use, emissions)
    • Governance risks in supplier accountability
  3. Prevention & Mitigation
    • Risk mitigation protocols are activated for any flagged supplier.
    • Non-compliant inputs are rejected.
    • Our Procurement Team ensures all cotton and fabrics labeled as organic are backed by valid certifications and clean audit trails.
  4. Tracking & Monitoring
    • Ongoing monitoring of supplier performance and compliance is handled through a quarterly review and document audit process.
    • Corrective Action Reports (CARs) are tracked and updated in our supplier compliance dashboard.
  5. Transparent Communication
    • Any sustainability-related claims are reviewed and cleared by the Compliance Team.
    • We avoid misleading terms (e.g., “GOTS Certified”) unless full certification is held.
    • Our internal teams receive regular updates on compliance topics, including claim wording and logo usage restrictions.
  6. Remediation Enablement
    • KeaBabies has internal escalation processes and supplier corrective action protocols to address any identified issues.
    • We promote supplier development rather than termination, wherever feasible.

4.1.2 Scope and Scalability

While KeaBabies is not a GOTS-certified entity, we apply due diligence proportionate to our structure as a digitally native global baby brand.
Factors such as supplier location, risk exposure, and production volume influence how deeply we audit and engage with partners.

4.1.3 Continuous Improvement

Due diligence is not a one-off task. KeaBabies engages in progressive improvement by:

  • Upgrading compliance tools annually
  • Tracking internal training attendance
  • Requiring updated supplier documentation each cycle

We aim to elevate sustainability benchmarks over time.

4.1.4 Policy on Responsible Business Conduct

KeaBabies has adopted a Policy on Responsible Business Conduct that clearly states our commitment to:

  • Ethical sourcing
  • Legal and fair labor practices
  • Environmentally safe production
    This policy applies both to our internal operations and to all upstream partners in our supply chain.

4.1.5 Strengthening Management Systems

We are strengthening our systems by:

  • Implementing supplier scorecards with GOTS alignment checks
  • Automating certification tracking and renewal reminders
  • Training all product and compliance managers on red-flag indicators

4.1.6 Oversight & Accountability

Oversight for due diligence at KeaBabies is assigned to:

  • The Head of Product & Compliance, with direct reports from QA and Sourcing
  • Board-level oversight is assigned to the CBO, who receives quarterly updates on ethical compliance status

Regular training is provided to managers on GOTS topics, human rights, and environmental compliance.

4.1.7 Resourcing

KeaBabies allocates dedicated resources to ensure effective due diligence:

  • A dedicated Compliance Manager oversees GOTS-aligned procedures
  • Budget is assigned annually for external audits, third-party training, and supplier development support
  • Legal counsel is engaged to review claims and risk disclosures