compliance to local legislation on environment, health & safety, and employment relations. ECCO’s internal audit programme is further sup- plemented by audits or assessments conducted by business partners, as ECCO’s shoe factories and tanneries do not only produce for ECCO – they also produce leather and shoes for external brands and wholesale customers. These customers frequently conduct strict audits at ECCO, which also include human rights related topics. To learn more about the history and content of the audit programme, please visit: http://group.ecco.com/en/responsibility . ECCO is aware of the importance of complementing audits with oth- er measures and processes in the area of modern slavery and human trafficking. ECCO therefore has EHS officers at all its factories to assist workers in voicing their concerns related to working conditions. Local HR departments further ensure a solid introduction to ECCO’s CoC and ethical standards as part of the onboarding for new employees. ECCO has established a ‘Whistleblower System’ to promote employees’ and stakeholders’ ability to notify ECCO if they encounter violations of ECCO’s CoC or general business ethics. ECCO still encourages employ- ees to go to their immediate manager or colleague if a breach or con- cern occurs, so that ECCO can act appropriately in a timely manner. But realising that some need or prefer to raise their concerns anonymously, the Whistleblower System seeks to ensure all serious concerns can be raised. The system was promoted and communicated in local languag- es through a group campaign in 2021. RISKS IN ECCO’S OPERATIONS AND SUPPLY CHAIN As a global company with employees and suppliers in most parts of the world, ECCO recognises that human rights related risks are present in its operations and supply chain. ECCO’s main forum for risk assessment and risk mitigation related to modern slavery, and human rights in general, is ECCO’s Group Cor- porate Responsibility Steering Committee. Here risks are assessed on a quarterly basis. Based on research, ECCO has identified areas of its supply chain where it has the highest risk. This is one of the main reasons behind ECCO’s comprehensive Code of Conduct Audit System, which targets suppliers with the highest identified risks of non-compliance to ECCO’s standards. ECCO continues to focus on strengthening and expanding the audit system to lower its risks even further. ECCO further uses training to lower the risks of human rights abuses in its business and supply chain, which is described further in the following section. TRAINING ECCO regularly provides up-to-date trainings to its CoC auditors and other relevant employees to discuss how to identify and address the risks of modern slavery. To mitigate risks, ECCO in 2021 conducted trainings to its CoC audi - tors focusing on groups more vulnerable to modern slavery and other COC AUDITS PRE-SCREENINGS AT NEW SUPPLIERS EXTERNAL LEGAL AUDITS CONDUCTED AT 5 ECCO PRODUCTION UNITS ALL ECCO TANNERIES RANKED GOLD BY THE LEATHER WORKING GROUP
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