California Transparency Act & UK Modern Slavery Act Statement
DISCLOSURE REQUIREMENTS UNDER THE UK MODERN SLAVERY ACT 2015 AND CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT 2010 FOR THE FISCAL YEAR 2017
UK MODERN SLAVERY ACT 2015 (“UK ACT”)
Under the UK Act, companies providing goods and services with a turnover of £36m or more are obliged to publish an annual Slavery and Human Trafficking Statement setting out the steps the company has taken to ensure slavery and human trafficking is not taking place in its supply chain or its own business.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT 2010 (SB-657) (“CALIFORNIA ACT”)
Under the California Act, companies of a certain size doing business in the State of California are obliged to disclose their efforts to eradicate slavery and human trafficking from their direct product supply chains for the goods that they offer for sale.
Coach, Inc. (to be Tapestry, Inc. effective October 31, 2017) (the “Company”) is a New York-based house of modern luxury lifestyle brands. The Coach brand was established in New York City in 1941, and has a rich heritage of pairing exceptional leathers and materials with innovative design. Coach is sold worldwide through Coach stores, select department stores and specialty stores, and through Coach’s website at www.coach.com. In 2015, the company acquired Stuart Weitzman, a global leader in designer footwear, sold in more than 70 countries and through its website at www.stuartweitzman.com. The Company’s common stock is traded on the New York Stock Exchange under the symbol COH and its Hong Kong Depositary Receipts are traded on The Stock Exchange of Hong Kong Limited under the symbol 6388.
Company products and major supplier relationships are governed by the Supplier Code of Conduct (“Supplier Code of Conduct”) which includes the absolute prohibition of forced or bonded labor. In this disclosure we explain in detail how we apply our Supplier Code of Conduct in practice through good governance practices.
In compliance with the UK Act, this document covers the reporting period of 3 July 2016 to 1 July 2017. This disclosure does not cover any entities acquired by the Company after 1 July 2017. This information may also apply to past endeavors undertaken by the Company.
The Company has adopted the following broad definition of slavery: “a person who is forced to work, without pay, under threat of violence, who cannot walk away,” as defined by the international non-governmental organization Free the Slaves (see http://www.freetheslaves.net/about-slavery/faqs-glossary/).
The Company has adopted the following broad definition of human trafficking: “any recruitment, harboring, transportation, provision or obtaining of a person for labor services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery” as defined in the Victims of Trafficking and Violence Protections Act of 2000.
The company assesses its risk of slavery and human trafficking as low for the following reasons:
1. Verification of Product Supply Chain:The Company verifies its product supply chain by conducting audits of the service providers and raw material providers with which we do business to ensure compliance with our Supplier Code of Conduct and guidelines, including our Global Business Integrity Program. We ensure we know the exact sites where Company products are manufactured, and subcontracting is forbidden without express permission; subcontractors are assessed before being approved by the Company. Both human trafficking and slavery fall within our Code’s definition of “forced labor” and, as such, are strictly prohibited, and penalized, at all stages of the product supply chain.
2. Conducts Audits of Suppliers:The Company conducts two types of supplier audits: Audit by employee and independent third party audits. Third party auditors routinely undertake unannounced visits to the locations where Company products are manufactured and provide the Company with full reports on the living and working conditions of the people retained to work at those locations. Each location receives at least one unannounced audit visit in a year.
3. Requirement for suppliers to certify compliance:The Company requires that all direct suppliers provide an annual certification of their compliance with our standards for employment – including a certification on the part of the supplier that all materials sourced for and incorporated into our products comply with slavery and trafficking laws of the country or countries where the supplier is doing business.
4. Maintains internal accountability standards:The Company has developed a code of conduct for all parties working with the Company – as embodied in the Global Business Integrity Program. In the case of non-compliance, the Company reserves the right to examine the specific situation and develop a strategy for resolution. If non-compliance is not resolved within a designated time frame, the Company may terminate a business relationship. Additionally, the Company operates an ethics and compliance reporting system (1-800-396-1807 or www.coachinc.ethicspoint.com), which allows employees, suppliers and consumers can report issues with and deviations from the Company’s principles and policies.
5. Conducts Training:The Company conducts internal trainings of employees to ensure that participants in the supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including human trafficking and slavery, with a particular focus on mitigating risks. The Company also conducts supplier trainings to ensure that our suppliers understand our Supplier Code of Conduct and the company’s expectations. The Company’s last supplier training took place in May 2017.
The Company will continue to assess its business and supply chains to identify potential risks and then target those areas with policies, procedures and training to ensure it maintains appropriate safeguards against the mistreatment of persons within its own business and supply chains.
Approved by the Board on 10 August 2017 as applicable to the Company and its subsidiaries during fiscal year 2017.
Chief Executive Officer