Workers & Factories

Product Sourcing Policy

We commit to the advancement of social and environmental responsibility. When producing products we select factories that work to be role models of responsible business and labor practices and we believe that supporting good practices at a factory level is part of a broader human rights solution.

Guiding Principles

• We will follow sourcing practices that ensure our products are manufactured in safe and healthy workplaces where human and civil rights are respected.
• We have adopted a Fair Labor Code of Conduct (FLCC).
• We will ensure implementation of the FLCC in our supply chain.
• We will work with our suppliers who do not comply with our FLCC and help them to improve their work practices. If corrective action is not achieved, we reserve the right to cease business with the supplier in question.

Monitoring & Assesment

Lumos’ approach to labor conditions in our contract factories is evolving.

We have adopted a Fair Labor Code of Conduct (FLCC). We will ensure all our suppliers know that we expect them to comply with our FLCC.

We have three levels of monitoring. We analyze the risk factors of a particular manufacturing partner and determine which type of compliance evaluation to utilize.

• Basic Monitoring (SE) — the audit can be completed by the manufacturing partner, providing details of their operation as they pertain to the FLCC. We often use this monitoring process with trusted partners that can document completion independent third party auditing with other customers.
• In-depth (ISE) — this is a series of steps that our QA staff can follow to actively verify compliance with the FLCC. The audit covers all health and safety aspects of the Code, but does not involve a review of wage and hourly documentation or worker interviews.
• Full Audit (3P) — A full audit of all elements of the FLCC carried out by an independent third part audit firm. The 3P audit includes all elements of the ISE audit, as well as review of wage and hour documentation and worker interviews.
   

Country of Origin

Lumos brand products sold in North America are manufactured in several factories in two countries. The country of origin of all our products is clearly marked on the box and on the product. When we print the country of origin on our products this means the components where manufactured and assembled there. We do not engage in the deceptive practice of making the components of our products in one place and shipping these to another location for assembly. This misleading process can be employed to make the components in a country where labor costs are low, and to then ship these components to a another country for assembly. This process allows the manufacturer to label their products "Made in the U.S.A.", for example, without actually making any of the components in the U.S.A. While completely legal this practice is misleading.

At Lumos we pledge transparency in reporting country of origin. When we write "Made in" we mean manufactured and assembled in.