California Transparency Act & UK Modern Slavery Act Statement
Tapestry, Inc.’s Disclosures Under The UK Modern Slavery Act and California Transparency in Supply Chains Act for the Fiscal Year 2021
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 annually publish a Slavery and Human Trafficking Statement setting out the steps the company has taken to ensure slavery and human trafficking are not taking place in its supply chain or its own business. Tapestry, and the following group companies are required to publish a statement pursuant to the UK Act: Coach, kate spade new york and Stuart Weitzman. In compliance with the UK Act, this Statement covers the reporting period of 28 June 2020 to 3 July 2021. This Statement addresses some endeavors undertaken by Tapestry prior to the reporting period.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT 2010 (“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.
TAPESTRY, INC. DESCRIPTION AND DEFINITIONS
Our global house of brands unites the magic of Coach, kate spade new york and Stuart Weitzman. Each of our brands is unique and independent, while sharing a commitment to innovation and authenticity defined by distinctive products and differentiated customer experiences across channels and geographies. We use our collective strengths to move our customers and empower our communities, to make the fashion industry more sustainable, and to build a company that’s equitable, inclusive, and diverse. Individually, our brands are iconic. Together, we can stretch what’s possible. To learn more about Tapestry, please visit www.tapestry.com. The Company’s common stock is traded on the New York Stock Exchange under the symbol TPR.
Although our brands are unique and independent, we have instituted common policies and procedures across our business to address modern slavery. We use the definition of slavery or forced labor as defined by the International Labour Organization, which is “all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.”
We also have adopted the definition of human trafficking in the Victims of Trafficking and Violence Protections Act of 2000: “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.”
We also follow the definitions of slavery and human trafficking applicable in the jurisdictions where we do business.
TAPESTRY, INC. DISCLOSURE
We believe the risk of modern slavery in our own business is low due to our culture and the strength of our internal labor policies and procedures. Tapestry takes the following actions to mitigate the risk of slavery and human trafficking in its supply chains.
Policies:Tapestry has a Supplier Code of Conduct (“Supplier Code of Conduct”), as part of a larger Global Business Integrity Program that applies to all of Tapestry’s direct supplier relationships, as well as other supplier relationships that are involved in producing our products. This policy includes an absolute prohibition on slavery, forced, bonded and child labor.
Verification of Product Supply Chains:Tapestry verifies its product supply chain by conducting audits of the service providers and key raw material providers with which we do business to ensure compliance with our Supplier Code of Conduct and other corporate guidelines, including the policies under Tapestry’s Global Business Integrity Program.
Audits of Suppliers:Tapestry conducts audits of direct service providers and key raw material providers with which we do business to ensure compliance with our Supplier Code of Conduct and other corporate guidelines, including policies under Tapestry’s Global Business Integrity Program. Tapestry conducts supplier audits using independent third parties; however, from time to time Tapestry employees may also conduct audits. Third party auditors routinely undertake unannounced visits to the locations where Tapestry brands’ products are manufactured and provide Tapestry with reports on the living and working conditions of the workers at those locations. Suppliers are subject to semi-announced audits every 12 months, as circumstances allow. In addition, in accordance with the Sustainable Apparel Coalition (“SAC”) requirements, in FY2022 Tapestry will begin having suppliers self-report information, which will be subject to certain verification procedures administered by the SAC and audited by Tapestry. In FY2021, the Company’s internal auditing team and external auditors performed 159 audits of the facilities that produce Tapestry brand products. This number was moderately lower than the audits performed in FY2020 due to logistical challenges resulting from the Covid-19 pandemic. Additional information on our social auditing program is in our FY2020 Corporate Responsibility Report.
Supplier Certification:Tapestry receives certifications from direct suppliers regarding their compliance with Tapestry’s standards for employment – including a certification from the supplier that all materials sourced for and incorporated into Tapestry products comply with slavery and trafficking laws of the country or countries where the supplier is doing business.
Internal Accountability Standards:Tapestry has developed a Supplier Code of Conduct for all parties working with Tapestry or its brands – as embodied in the Global Business Integrity Program. In the case of non-compliance, Tapestry reserves the right to examine the specific situation and develop a strategy for resolution. Depending on the seriousness of the situation or if non-compliance is not resolved within a designated time frame, Tapestry may terminate a business relationship. Additionally, the Company operates an ethics and compliance reporting system (1-800-396-1807 or www.tapestry.ethicspoint.com), where employees, suppliers, consumers and other interested parties can report (anonymously, if desired) issues with and deviations from Tapestry’s principles and policies.
Training:Tapestry conducts internal trainings with its supply chain management personnel to ensure they are knowledgeable and aware of supply chain issues and concerns, including relating to human trafficking and slavery. A particular focus on the training is risk mitigation. Tapestry also conducts supplier trainings on our Supplier Code of Conduct and the Company’s expectations. New suppliers are provided with onboarding training that covers forced labor and human trafficking. Tapestry’s most recent supplier training took place in June 2021.
Participation in Multi-stakeholder Initiatives:Modern slavery is beyond the capacity of any single company to solve. Therefore, in addition to the actions outlined above, Tapestry participates in multi-stakeholder initiatives to address the risk of forced and involuntary labor in our industry and supply chains, including:
- Tapestry is a participant of the United Nations Global Compact (“UNGC”). We have aligned our strategies and operations to the UNGC’s Ten Principles on human rights, labor, the environment and anticorruption. Through the UNGC, Tapestry reports on our progress in relation to the Ten Principles annually.
- Tapestry is a member of the United Nation’s International Labour Organization’s Better Work Programme which works to improve working conditions in the garment industry.
- Tapestry recently joined BSR’s HERproject, a collaborative initiative that strives to empower low-income women working in global supply chains by driving impact for women and business via workplace-based interventions on health, financial inclusion, and gender equality.
- Tapestry joined the Sustainable Apparel Coalition (“SAC”) and is planning that certain suppliers complete the SAC’s Higg Facility Social Labor Module to increase transparency. This will require certain service providers and strategic raw material providers to disclose their approach to various social topics, including working hours, wages and benefits, employee treatment and health and safety.
MEASURING OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
Tapestry’s Environmental, Social and Governance (“ESG”) Task Force meets monthly to set and drive company-wide ESG strategy, including our social and labor related approach. The ESG Task Force includes members of Tapestry’s Executive Committee, including our General Counsel and the Chief Operations Officer, and representation from cross-functional membership from major business functions at Tapestry. Our Board of Directors approves long-term ESG goals, strategic moves, or major plans of action and receives updates at least annually.
We use the following metrics to measure our effectiveness in mitigating the risk of slavery and human trafficking in our business and supply chains:
- the number of completed audits of our suppliers’ facilities by Tapestry personnel or a designated third party, and the findings of those audits; supplier audits are reported on annually in our Corporate Responsibility Report;
- use of labor monitoring and payroll systems to check eligibility of employees in our owned and leased UK operations; and
- the number of suppliers trained annually on our corporate policies and expectations, with special emphasis on human trafficking and modern slavery.
Tapestry will continue to assess its business and supply chains to identify potential modern slavery risks and target those areas with policies, procedures and trainings to ensure it maintains appropriate safeguards to mitigate those risks.
Approved by the Board of Directors of Tapestry, Inc. on 11 August 2021.
Chair of the Board