The CoC not only applies to the ECCO Group and its employees, but also to all external suppliers. ECCO requires its suppliers as a minimum to comply with ECCO’s Code of Conduct and all national laws of their country of origin. Non-compliance is considered a material breach and may cause termination of the contract. In this way, ECCO seeks to pro- mote the respect for labour and human rights in its supply chain. The responsibility to monitor the implementation of ECCO’s human rights policies lies in ECCO’s Group Corporate Responsibility (GCR) depart- ment. This department further tracks new relevant standards, best prac- tises, and new legal requirements to ensure ECCO continuously improves its human rights performance and mitigates potential risks. ECCO fur- ther has a Group Corporate Responsibility Steering Committee where employees at management level and internal experts discuss ECCO’s performance and related projects, and monitor potential risks. The Management of ECCO’s business units is responsible for implement- ing the Group policies and procedures at local level. To ensure proper implementation, relevant departments, such as EHS, QA, HR, and Supply Chain at the units have close collaboration with ECCO’s GCR depart- ment. This process and collaboration ensures that all group policies and procedures are addressed and implemented at relevant ECCO business units, and that support is available at a group level. To learn more about ECCO policies relating to modern slavery and other areas of its CoC, please visit: https://group.ecco.com/en/responsibility. DUE DILIGENCE PROCESSES IN RELATION TO MODERN SLAVERY AND HUMAN TRAFFICKING Human rights due diligence is important to help ECCO identify, prevent, mitigate, and account for how ECCO addresses its human rights risks. ECCO believes that enterprises are responsible for respecting human rights wherever they operate, and that this responsibility exists in addition to compliance with national laws and regulations. A fundamental component of ECCO’s human rights due diligence is its compliance system, where CoC audits of suppliers are conducted systematically by ECCO’s internal CoC auditors or external auditors from Bureau Veritas. Most audits are announced audits and focus on the con- tinuous improvement of ECCO’s suppliers. After each audit, an action plan for improvements is made for the supplier and followed up by an ECCO’s auditor. In 2021, ECCO conducted 183 onsite CoC supplier audits, up from 123 in 2020. The COVID-19 pandemic still posed a lot of challenges to ECCO’s CoC audit system in 2021, but ECCO is satisfied that it managed to carry out a significant amount of the onsite audits planned for the year. ECCO’s CoC audit system also includes pre-screenings of potential new suppliers to ensure compliance with ECCO’s human rights and other CoC related areas before a collaboration may start. Pre-screenings are currently conducted of potential new suppliers to ECCO’s shoe production and finished leather goods. In 2021, ECCO conducted 33 pre-screenings that included a full CoC audit. As part of ECCO’s internal audit programme, Bureau Veritas in 2021 conducted audits at five ECCO production units. The audit scope was OPERATES IN 89 COUNTRIES 2,280 ECCO SHOPS 6 SHOE FACTORIES 4 TANNERIES
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