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UNITED KINGDOM MODERN SLAVERY ACT OF 2015
Coach, Inc. (“Coach”) is a leading New York design house of modern luxury accessories and lifestyle brands. 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, Coach acquired Stuart Weitzman, a global leader in designer footwear, sold in more than 70 countries and through its website at www.stuartweitzman.com. Coach, Inc.’s common stock is traded on the New York Stock Exchange under the symbol COH and Coach’s Hong Kong Depositary Receipts are traded on The Stock Exchange of Hong Kong Limited under the symbol 6388.
REPORTING PERIOD & DISCLOSURE
In compliance with the Modern Slavery Act 2015, this document covers the reporting period of 28 June 2015 to 2 July 2016. This information may also apply to past endeavours undertaken by Coach, Inc. and its subsidiaries.
COACH’S GLOBAL BUSINESS INTEGRITY PROGRAM
Coach’s objective is to be a good employer and a responsible and socially sensitive corporate citizen in the locations and manner in which we conduct business. In order to accomplish these objectives, Coach has operated a Global Business Integrity Program since the date of its incorporation. This Program sets forth the ethical and legal responsibilities that all Coach employees, contractors and suppliers are expected to uphold.
The Global Business Integrity Program consists of five published documents. These documents are publicly available on Coach’s website www.coach.com.
1. A Code of Conduct that is issued to all employees worldwide and outlines the significant legal and ethical issues that frequently arise in the course of business and describes the key responsibilities all employees, directors and officers are expected to uphold and comply with in conjunction with our values and policies.
2. The Global Operating Principles which sets forth the minimum standards by which strategic partners must operate
3. Supplier Selection Guidelines for parties from whom Coach sources products, including contractors, joint venture partners and suppliers of goods and services
4. The Anti-Corruption Policy describes our commitment to integrity and explains the specific requirements and prohibitions applicable to our operations under anti-corruption laws including, but not limited to, the U.S. Foreign Corrupt Practices Act of 1977.
5. The Coach, Inc. Animal Welfare Policy sets forth our commitment to principles and practices that require animals in our supply chain to be treated with care.
These documents clearly state Coach’s views on the ill treatment of workers, including our refusal to do business with those engaging in child labour, forced labour, discrimination, health and safety violations or the overwork of workers. Coach’s business principles and philosophies are founded on dignity and respect for the individual, a strong commitment to common sense, fairness, diversity, and ethical business practices and policies.
In order to monitor adherence to our Global Business Integrity Program, Coach created the Global Business Standards Committee, comprised of senior executives, which meets quarterly. Coach also has an ethics and compliance reporting system (www.coachinc.ethicspoint.com) on which employees and consumers alike can report issues with and deviations from Coach’s principles and philosophies.
MEETING OUR OBLIGATIONS UNDER THE MODERN SLAVERY ACT OF 2015
Coach is hereby publicly disclosing the efforts that we routinely undertake to identify and address slavery and human trafficking within our supply chain. It is our hope that these efforts will assist our customers and the public alike to make more informed choices regarding their support of companies. Coach has adopted the following broad definition of slavery: “the act of holding the worker against his or her will and controlled physically or psychologically by violence or its threat for the purpose of appropriating their labour” as defined by the international non-governmental organisation Free the Slaves (see www.freetheslaves.net).
Coach has adopted the following broad definition of human trafficking: “any recruitment, harboring, transportation, provision or obtaining of a person for labour 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.
Coach assesses our risk of slavery and human trafficking as low for the following reasons:
1. Verification of Product Supply Chain: Coach verifies its product supply chain by conducting audits of the factories with which we do business to ensure compliance with our code of conduct and guidelines, including Coach’s Global Business Integrity Program. Both human trafficking and slavery fall within our code’s definition of “forced labour” and, as such, are strictly prohibited, and penalised, at all stages of the product supply chain.
2. Conducts Audits of Suppliers: In addition to Coach employees, Coach also hires independent third party auditors who undertake unannounced visits to Coach manufacturing locations and provide Coach with full reports on the living and working conditions of people retained to work at those locations.
3. Requirement for suppliers to certify compliance: Coach requires that all direct suppliers provide a certification of their compliance with Coach’s standards for employment - including a certification on the part of the supplier that all materials sourced for and incorporated into Coach products comply with slavery and trafficking laws of the country or countries where the supplier is doing business.
4. Maintains internal accountability standards: Coach has developed a code of conduct for all parties working with Coach - as embodied in the Global Business Integrity Program. In the case of non-compliance, Coach reserves the right to examine the specific situation and develop a strategy for resolution. If non-compliance is not resolved within a timely manner, Coach may terminate a business relationship.
5. Conducts Training: Coach conducts internal training of Coach 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.