The California Transparency in Supply Chains Act requires us to disclose our efforts to eradicate slavery and human trafficking from our direct supply chains. We take seriously the federal and international efforts to end all kinds of forced labor – whether in the form of prison labor, indentured labor, bonded labor, human trafficking or otherwise – through standards set forth in our Code of Conduct, and detailed in the section "Forced and Compulsory Labor".
Supply Chain Verification
Our policy is to evaluate potential contract factories before they enter our supply chain to assess facility and country related risk for issues relating to forced labor, human trafficking and slavery. We use both internal and external audits as a means of performing this evaluation.
We monitor contracted factories' adherence to our standards through internal and external audits, as well as through collaboration with other brands, and as informed by our partnership with Social Accountability International, a global non-governmental organization advancing human rights at work. Each year, we monitor a subset of our contract factories base.
Direct Suppliers' Certification of Materials
We are working on mapping out and understanding any potential impacts further up the supply chain, to develop standards for upstream suppliers of our contracted manufacturers. We are also members of the Leather Working Group, and source the majority of our leather from BLC Leather Technology Centre Ltd (BLC) medal rated tanneries.
Standards for Compliance
If a contracted factory is found to violate laws or our standards, it is responsible for continually improving performance against a master action plan and implementing management systems which support Code of Conduct, local, and national expectations. If the factory fails to make progress against that plan, they are subject to further review and sanctions, including potential contract termination.
Employees and management with direct responsibility for supply chain management are provided training on forced labor, including human trafficking and slavery.
For more information on the Code of Conduct and the "Forced and Compulsory Labor" section of the Supplier Handbook you may contact the Cole Haan Corporate Responsibility Department at: firstname.lastname@example.org.