California Transparency Act & UK Modern Slavery Act Statement
TAPESTRY, INC.’S DISCLOSURE REQUIREMENTS UNDER THE UK MODERN SLAVERY ACT 2015 AND CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT 2010 FOR THE FISCAL YEAR 2018
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.
Tapestry, Inc. (“Tapestry”) is a global house of brands powered by optimism, innovation and inclusivity. In October 2017, Coach, Inc. became Tapestry, Inc. to reflect our new position as a global house of brands. Tapestry brands include Coach, kate spade new york (“Kate Spade”) and Stuart Weitzman. 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, Tapestry acquired Stuart Weitzman, a global leader in designer footwear, sold in more than 70 countries and through its website at www.stuartweitzman.com. In July 2017, Tapestry acquired kate spade new york, an exuberant brand focused on inspiring women to live more interesting lives through encouraging personal style with a dash of incandescent charm. Kate Spade is a global brand and is sold in store and online at www.katespade.com. Information about Tapestry, Inc. can be found at www.tapestry.com. Tapestry is traded on the New York Stock Exchange under ticker symbol “TPR”.
TAPESTRY, INC. DISCLOSURE
Tapestry products and major supplier relationships are governed by the Tapestry 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 2 July 2017 to 30 June 2018. This disclosure does not cover any entities acquired by Tapestry after 30 June 2018. This information may also apply to past endeavors undertaken by Tapestry.
Tapestry 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/).
Tapestry 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.
Tapestry assesses its risk of slavery and human trafficking as low for the following reasons:
1. Verification of Product Supply Chain:Tapestry 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 Tapestry’s Global Business Integrity Program. We ensure we know the exact sites where our brands’ products are manufactured, and subcontracting is forbidden without express permission; subcontractors are assessed before being approved by Tapestry. 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:Tapestry 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 Tapestry brands’ products are manufactured and provide Tapestry 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:Tapestry requires that all direct suppliers provide an annual certification of their compliance with Tapestry’s standards for employment – including a certification on the part of 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.
4. Maintains internal accountability standards:Tapestry has developed a 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. 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), which allows employees, suppliers and consumers can report issues with and deviations from Tapestry’s principles and policies.
5. Conducts Training:Tapestry conducts internal trainings of Tapestry 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. Tapestry also conducts supplier trainings to ensure that our suppliers understand our Supplier Code of Conduct and the company’s expectations. Tapestry’s last supplier training took place in October 2017.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We utilize the following metrics to measure how effective we have been to ensure that slavery and human trafficking is not taking place in part of our business or supply chains:
- completion of audits within our suppliers’ facilities by Tapestry personnel or a designated third party – 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
- 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 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 8 August 2018 as applicable to Tapestry, Inc. and its subsidiaries during fiscal year 2018.
Chief Executive Officer