At ZELO (Taiwan Lilu Commercial Co., Ltd.), we believe the value of sports and equipment is built upon every participant—including workers in the supply chain, partners, and the community using our products together with us.
We commit to respecting and promoting internationally recognized human rights and labor rights within our own operations and supply chain, and to continuously identifying, preventing, mitigating, and remedying potential adverse impacts in a reasonable and feasible manner. This commitment applies to ZELO and our suppliers, contractors, and business partners, regardless of their location.
International Principles and Standards We Refer To
Our human rights and supply chain management approach refers to (but is not limited to) the following frameworks and principles:
- Core Conventions of the International Labour Organization (ILO) and related labor standards
- United Nations Guiding Principles on Business and Human Rights (UNGPs)
- Applicable laws and reasonable industry practices in the locations of the supply chain
🏛️ Governance and Responsibilities
We establish responsibility attribution and decision-making processes through corporate governance to ensure commitments can be implemented and tracked.
Board of Directors / Senior Oversight
- Ultimate oversight responsibility: The corporate governance level (board of directors/senior management) holds final oversight responsibility for policies and major risks related to human rights and labor standards.
- Regular review: Review human rights issues and improvement directions at least once a year (or adjust frequency according to operational needs).
Daily Management (Person in charge: Chen Meng Kuan)
- Daily duties: Chen Meng Kuan coordinates ZELO’s human rights and supply chain risk management operations and reports major risks and handling progress to management.
Cross-department Governance (Self-established mechanism)
- Mechanism name: ZELO “Human Rights and Supply Chain Risk Working Group”
- Members: Product, procurement/supply chain, operations, customer service, legal/compliance (adjusted according to company structure)
- Meeting frequency: Convene at least every six months to review risks, complaint/report trends, partner management, and improvement matters.
Layered Reporting and Decision-making (Escalation)
When a significant or suspected significant human rights risk is identified, we will handle it according to the following path:
- Procurement/supply chain contact first collects information and provides a preliminary assessment
- Report to the working group to discuss handling plans and schedules
- Depending on risk level, report to management, and if necessary, to governance level
- Confirm responsible persons, improvement requirements, and tracking methods until case closure
🔍 How We Identify and Classify Human Rights Risks (Without “Audits”)
We adopt a risk-based approach, prioritizing issues that may cause serious harm or are highly likely to occur.
Sources of Information for Risk Identification
- Country/region-level information: Public data and reports on human rights, labor rights, migrant workers, forced labor, etc.
- Pre- and during cooperation information: Supplier basic data, contract terms, shipment/delivery abnormal signals, complaints or report information
- Public information and stakeholder feedback: Media, government announcements, NGO public reports, etc. (if related to our supply chain)
Classification Principles (Concept)
We judge priorities based on the following aspects:
- Severity: Scale, scope, irreversibility of impact
- Likelihood: Probability of occurrence, whether there are already signs
- Remediability: Whether it can be quickly remedied, resources and cooperation needed
Current situation explanation: ZELO currently has not established a regular third-party supplier audit system; we will use contract requirements, document verification, risk signal tracking, and incident handling as the main management methods at this stage and gradually strengthen them.
🌍 Scope and Transparency of Our Supply Chain
ZELO’s products may include categories such as clothing and accessories (subject to actual items sold). We cooperate with supply chain partners to complete design, material sourcing, manufacturing, packaging, and distribution.
Supply Chain Levels (General Definition)
- Tier 1: Suppliers related to finished product manufacturing/assembly
- Tier 2: Material and key raw material suppliers (e.g., fabric, dyeing, accessories, etc.)
Supply Chain Information Disclosure Policy
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Supplier list: Not disclosed.
Due to business confidentiality, contracts, and supply chain security considerations, ZELO currently does not disclose the supplier list; however, we will still promote supply chain human rights risk management and improvement within a reasonable scope.
🤝 Union Rights, Freedom of Association, and Collective Bargaining
We respect workers’ lawful rights, including freedom of association and collective bargaining. In regions where laws or environments make it difficult to fully exercise these rights, we will encourage suppliers to establish alternative, effective, and trusted worker voice mechanisms (such as complaint channels, representative systems, regular labor-management meetings, etc.) to help workers safely express opinions and receive responses.
Our Conservative Goals (Achievable Versions)
- By 2027/12/31: Complete document-level confirmation of whether major Tier 1 suppliers (judged mainly by purchase amount or cooperation volume) have worker complaint/voice mechanisms (e.g., policies, procedures, or contact information).
- By 2029/12/31: Among major Tier 1 suppliers, achieve **at least 70%** having operational worker complaint/voice mechanisms (reasonably confirmed by documents and incident response records, etc.).
⚠️ Significant Human Rights Risks and ZELO’s Responses
The following issues are common risks in sportswear and accessory supply chains; ZELO will adjust priorities based on its own supply chain risk assessment results.
| Risk Issue | Possible Occurrence Stage | ZELO’s Approach (Current Stage) |
|---|---|---|
| Excessive working hours and insufficient rest | Finished product manufacturing peak season rush | Require compliance through cooperation terms and communication; request explanation and improvement plans when abnormal signals are found |
| Occupational health and safety (including chemicals) | Material production, processing, and dyeing | Pay extra attention to high-risk stages; require suppliers to provide basic management information and improvement commitments when necessary |
| Forced labor, human trafficking, and improper recruitment fees | Migrant worker employment, outsourcing/agency chains | Clearly reject forced labor and improper fees; if clues arise, require suppliers to explain, remedy, and revise systems |
| Discrimination, harassment, and inhumane treatment | Workplaces at all levels | Require respect for dignity and basic rights; initiate investigation and corrective demands if reports are received |
| Child labor and protection of underage workers | Upstream raw materials, outsourcing | Require compliance with legal minimum age and protection of underage workers; request evidence and improvements if doubts arise |
| Insufficient complaint channels / risk of retaliation | Management systems and culture | Encourage establishment of confidential complaint channels and no-retaliation principles; treat major incidents as high priority for handling |
🛠️ Remedy and Correction (What to Do When Problems Are Found)
When adverse human rights impacts are found or reasonably suspected in the supply chain, ZELO will take the following measures as appropriate (which may be concurrent):
- Collect facts and require suppliers to submit a Corrective Action Plan (CAP) and schedule
- Require remedies depending on the severity of the incident (e.g., refund improper fees, improve safety measures, etc.)
- Track improvement results; if refusal to improve or risks cannot be controlled, evaluate suspension or termination of cooperation
📣 Feedback, Complaints, and Contact
If you have concerns, clues, or suggestions regarding possible human rights or labor rights issues in ZELO’s operations or supply chain, please contact:
- Contact email: zelo@zelosportivo.com
- Company: Taiwan Lilu Commercial Co., Ltd. (ZELO)
- Address: 12th Floor, No. 221, Section 4, Zhongxiao East Road, Da’an District, Taipei City
We will respond within a reasonable period and protect whistleblower information and privacy within necessary scope.
✅ Document Approval and Release
This commitment is reviewed and approved by Chen Meng Kuan.
Release date: 2026/01/01
Review frequency: at least once a year