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MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

AIRWAIR INTERNATIONAL’S OUR ORGANISATION WHAT IS ‘MODERN SLAVERY’?


STANCE ON MODERN SLAVERY
AirWair International Ltd. is a The Ethical Trade Initiative refers
At Dr. Martens, we do not accept footwear brand that was established to modern slavery as an umbrella
modern slavery. We state in our in Wollaston, UK in 1960, and has term that includes: forced labour,
code of conduct that employment had a manufacturing unit there ever bonded labour, human trafficking
must be freely chosen without since. This year we opened our new and slavery. The term “modern”
any form of forced labour, prison global head office, and home to the is used to distinguish the
labour, or bonded labour. We are brand, in Camden, London. complexity of today’s slavery
committed to taking all necessary from historical slavery associated
steps to identify, investigate, AirWair International Ltd is part with the legal possession of one
engage and remediate any of the Dr. Martens Airwair Group person by another.
issues uncovered. Ltd group of companies which has
subsidiaries in the US, Hong Kong, Our business and our supply chain,
This statement is made pursuant to Japan, Korea, France, Belgium and like many others in our industry,
Section 54 of the Modern the Netherlands, as well as a wholly has multiple tiers reaching across
Slavery Act 2015 and California owned foreign enterprise in China. continents and countries. Modern
Transparency in Supply Chains Act slavery is a global issue within these
of 2010 (SB 657) and is to set out Dr. Martens’ footwear, clothing and complex business models and supply
the actions we have undertaken to accessories products are sold in chains.
understand the potential modern more than 70 owned stores or via
slavery risks related to our business, wholesale and online both in the UK >>>
the steps and measures we have put and internationally.
in place to mitigate against modern
slavery in our own business and our OUR EMPLOYEES
supply chains, as well as some of
As of 2017 we have around 1200
the additional work that we plan to
employees globally, the majority of
do. This statement covers the
which are in offices and stores, with
activities between October 2016
some working in warehouses.
and October 2017.
We recruit and select all of our own
employees and determine the terms
and conditions of their employment.
2017 HIGHLIGHTS Our employees are free to decide
whether they work for us and if they
MODERN SLAVERY TRAINING TO accept the terms and conditions.
KEY EMPLOYEES AND HEAD OF As part of our recruitment process
DEPARTMENTS IN HR, SOURCING we undertake checks locally on all
employees to verify their identity, age
AND PRODUCTION
and eligibility to work in that country.

EXTENDED CSR AUDITS TO In certain areas of our business we


NON-FOOTWEAR SUPPLIERS sometimes use temporary labour to
help manage seasonal peaks in work-
INCLUDED THE GLOBAL AND load (for example in our distribution
centres in the UK and US). We occa-
REGIONAL SERVICE CONTRACTORS
sionally use carefully selected third
IN THE SCOPE OF OUR WORK party recruitment agencies to provide
this labour under pre-agreed terms.

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MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

OUR SUPPLY CHAIN In addition to environmental + Working conditions are safe


topics in the nominated tanneries, and hygienic
WHERE WE PRODUCE AND this year we undertook a detailed
+ Child labour shall not be used
SOURCE OUR PRODUCTS survey to better understand our
(1ST TIER SUPPLIERS) non-nominated second tier material + Living wages are paid
and component suppliers. We are
now expanding our CSR program to + Working hours are not excessive
We are a manufacturing brand which
owns and operates a footwear facto- include the second tier factories’ + No discrimination is practised
ry in the UK. We also source finished social standards.
+ Regular employment is provided
footwear, clothing and accessories
from factories in China, Thailand, SERVICE CONTRACTORS + No harsh or inhumane treatment
Vietnam, Lao, Philippines, Portugal is allowed
and the UK. We purchase services, consumables,
marketing materials from various To provide further guidance to our
Our key strategy in sourcing our contractors. We are in the process of suppliers we have added some
products is to establish long-term mapping and assessing the risk of additional information to our Code of
relationships with our partners in the supply chain of our operations Conduct on what constitutes modern
these countries, in many cases we in our headquarters and regions. slavery/forced labour.
have built up a relationship over While we continue mapping, we have
many years. More than 75% of our introduced a Modern Slavery clause All of our policies are issued to our
sourcing spend comes from factories in our new contract agreements. first tier footwear suppliers on an
we have worked with for more than annual basis for them to review,
10 years. This allows us to have a OUR COMMITMENTS acknowledge and confirm
deeper understanding of the issues compliance. In 2017 we extended
our suppliers face and creates an AND POLICIES these policies to non-footwear
environment of trust, transparency suppliers.
and collaboration in improving the + Supplier Code of Conduct
workplace standards. + Anti-slavery and human ANTI-SLAVERY AND HUMAN
trafficking policy TRAFFICKING POLICY
COMPONENT SUPPLY CHAIN
(2ND TIER SUPPLIERS) + Subcontracting and To ensure that our own employees
homeworking policy are aware of the risks of modern
We also work directly with a large slavery and their obligations under
number of our second tier material SUPPLIER CODE OF CONDUCT the Modern Slavery Act, we have
and component suppliers, such us developed an Anti-Slavery and
leather and textiles, across Asia, Our suppliers must adhere to and Human Trafficking Policy. In 2016
Europe and South America. Where are audited upon our supplier and 2017 we provided training to
possible these are nominated by us Code of Conduct which has been in our key employees on the details of
so we can have better control of the place since 2006 and has been this policy. Alongside this work we
materials used in our products. updated over the years to reflect will also be ensuring that all of our
We are members of the Leather best practices. Our CSR Code of employees have received a copy of
Working Group (LWG) whose aim is Conduct is based on the Ethical our whistleblowing policy that can
to raise environmental standards Trading Initiative Base Code be used as a mechanism to raise any
throughout the industry and to and covers the following areas: concerns in relation to suspected
develop best practices. The majority breaches of our policy.
of our upper leather was sourced + Employment is freely chosen
from nominated LWG medal status + Freedom of association and
tanneries where we can monitor the the right to collective bargaining
environmental standards. are respected

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MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT
Our staff in key sourcing countries DUE DILIGENCE, The training included:
and headquarters have received
Modern Slavery awareness training AUDITING AND + Introduction to Modern Slavery,
by a third party organisation TRAINING IN PRODUCT including the law and in practice
specialised in improving labour
conditions in global supply chains. SUPPLY CHAIN + The spectrum of Modern Slavery
This training aimed to create
awareness on what constitutes A key part of our supply chain due + Roles and responsibilities of
slavery in today’s world, especially diligence and compliance is carrying employees and staff
in manufacturing and retail business out detailed audits against our CSR
environments. Code of Conduct at all of our first + Worker vulnerabilities
tier footwear suppliers before and
SUBCONTRACTING AND during our relationship. These audits + Key issues for members of
HOMEWORKING POLICY have been in place for a number of commercial teams to spot when
years now and we continue to visiting factories.
One of the main risks in sourcing regularly conduct CSR audits.
from other countries is the use of Most of the countries and regions
subcontracting and homeworking. The audits are carried out by a third we are operating in have been part
We have a policy in place with all of party company which specialises of our supply chain for a number of
our first tier footwear suppliers that in this field and involve talking to years, so we believe we understand
requires them to disclose any workers both on-site and off-site. the risks that are present and we can
potential subcontracting or The audits are conducted by local immediately work with the suppliers
homeworking before going ahead so experts during several days to allow for remediation.
that we can review the proposed site. detailed checks and verifications
through document reviews and When we move to a new country/
As we work closely with our worker and management interviews. region or become aware of any sig-
suppliers and understand their nificant changes to our supply chain,
production processes to a high level Alongside our CSR audit program, we we undertake activities to assess
of detail, and conduct regular CSR have our own Sourcing and Quality potential risks, including:
audits, the risk of any subcontracting team based in Asia, which allows
or homeworking taking place without us to visit all of our first tier and + Preliminary assessment visits
our knowledge is reduced. most of our second tier suppliers in
person on a regular basis. This again + Desk-based research
MIGRANT WORKER POLICY gives us invaluable insight into our
supplier factories practices including + Consultation with relevant third
Modern slavery in supply chains is potential issues relating to modern parties
a growing issue globally and is slavery.
increased by the workforce + Full audit prior to commencing bulk
migration. Migrant workers are In 2016 these teams were trained on production
more vulnerable because they are Modern Slavery, how to detect it in
unlikely to raise grievances with the supply chain context and what + Ongoing monitoring, depending on
their employers or the authorities – steps to take if a potential issue is the outcome of the previous audit
especially if they are undocumented. identified. result.
These are shared issues and require
collective and collaborative action >>>
to be tackled. This year we have also
started to develop a migrant worker
policy to implement international
best practices addressing the issues
that migrant workers may face.

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MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

WHAT’S NEXT
We are committed to keep our focus + We are creating a structure to
on the continuous improvement of enable our regional sales and
our approach to Modern Slavery. stores teams to look at Modern
Next year we will take the following Slavery risks in their own
steps to continue to meet this operations. This includes
important commitment. services, consumables, marketing
+ Footwear is our main product, materials they receive from
however, we also sell leather contractors.
accessories and some clothing + Our ongoing series of Modern
items. We plan to extend our Slavery training will be provided
CSR assessments in all the non- at all our finished product
footwear factories to get a better suppliers and our own regional
understanding of the labor offices’ to ensure they have
standards and working mechanisms to detect potential
conditions. risks and take necessary
+ We are increasing our resources remedial actions.
in Asia to start assessing our + Finally, we are currently
second tier suppliers to developing a migrant worker
understand the conditions in policy that will cover principles
those factories. and requirements to guide our
internal teams and suppliers
towards best practices when
employing migrant workers.

ADDITIONAL INFORMATION

Additional information can be found
on the social responsibility section
of our website.

This statement was approved by the
Board of Directors of Dr. Martens
AirWair Group Limited.

Paul Mason
Chairman

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