MODERN SLAVERY POLICY 1. INTRODUCTION 1.1 Background ECCO is aware that the issue of forced labour and human trafficking, in particular where work is conducted by migrant workers or other vulnerable workers, occurs across the world. Such abusive working conditions are unacceptable and ECCO welcomes the growing body of legislation that focuses on preventing modern slavery from occurring in the business and supply chains of companies. 1.2 Purpose This policy supports commitment 6 in the ECCO Code of Conduct: “ECCO wishes to provide employees with a workplace free of harassment or abuse and condemns any form of enforced labour.” The purpose of this policy is to encourage ownership, commitment and adherence to all levels of the business and to provide framework for establishing and reviewing modern slavery objectives. 1.3 Scope This Policy applies to all ECCO Group entities. 2. POLICY STATEMENT 2.1 Modern Slavery Policy ECCO is aware that the issue of forced labour and human trafficking, in particular where work is conducted by migrant or otherwise vulnerable workers, occurs across the world. These abusive working conditions are unacceptable and ECCO welcomes the growing body of legislation that focuses on preventing modern slavery from occurring in the business and supply chains of companies. ECCO’s Code of Conduct affirms ECCO’s commitment to respect internationally recognised human rights. The Code of Conduct makes it clear that ECCO must provide employees with a workplace free of harassment or abuse, and it condemns any form of forced labour. The Code of Conduct not only applies to all ECCO employees and business units, but also to all external suppliers and other business partners. ECCO regularly provides training for its Code of Conduct auditors to improve their skills in identifying and addressing modern slavery. ECCO also seeks to work with its suppliers to help them understand the implications of modern slavery and related risks. A key forum is the ECCO Code of Conduct Supplier Summit, which gathers over 90 of its global suppliers, and creates the opportunity to share best practices and lessons learned amongst the participants. Human rights due diligence is important to help ECCO identify, prevent, mitigate, and account for how ECCO addresses potential adverse human rights impacts. ECCO’s approach is based on the UN Guiding Principles on Business and Human Rights. ECCO seeks to prevent and mitigate potential impacts on human rights. To achieve this, ECCO is working to assess its actual and potential human rights risks, and tackle any issues that are identified. One way this is done is by conducting pre-screening on all new suppliers to assess compliance with this element of the Code of Conduct. Audits of suppliers are conducted by ECCO’s internal Code of Conduct audit team, and findings are supplemented with audits from external auditors. The process is structured to target suppliers most 40
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