Modern Slavery Act 2015 – Christian Louboutin Statement

Christian Louboutin is a luxury fashion brand of footwear, handbags, small leather goods and accessories for men and women (“Products”), which are mainly manufactured in Italy. Christian Louboutin has over 1700 employees worldwide.

Christian Louboutin UK Limited is the retail affiliate in the United Kingdom of the Christian Louboutin group of companies (“Christian Louboutin”), whose majority shareholder is the French company Christian Louboutin SAS.

The Products are supplied to Christian Louboutin UK Limited by the Swiss company CL International SA.

This statement is made by Christian Louboutin UK Limited, CL International SA, and Christian Louboutin Suisse SA, in charge of the European ecommerce platform, who therefore distributes Products in the UK. 

This statement aims at underlining the steps taken by Christian Louboutin during its financial year ended 31 August 2021 to prevent opportunities for modern slavery to occur within its businesses or supply chain.

Modern slavery is a criminal offence in the UK under the Modern Slavery Act 2015 and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

Christian Louboutin fully adheres to the principles and fundamental rights outlined in both the Universal Declaration of Human Rights and the Charter of Fundamental Rights of the European Union and is committed to fighting all forms of slavery and human trafficking.

Christian Louboutin has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or in any of its supply chains.

3.1. BEING AN EMPLOYEE AT CHRISTIAN LOUBOUTIN

Policies in place

Christian Louboutin has implemented various policies which underline the commitment of the group to ensure the protection of human rights and which are applicable to Christian Louboutin employees.

These policies – which are shared with all employees (either when they join Christian Louboutin, or when such policies become available or are updated) include:

• Health and Safety Policies
• Employee Handbook (specifying notably the company’s Equal Opportunities policy and its Bullying and Harassment policy)
• Whistleblowing policy
• Anti-bribery Code
• Christian Louboutin Employee Code of Conduct
• New smart working policies
• Covid 19 policies.

Christian Louboutin also has strict and thorough right to work checking processes in place.

Production facilities’ employees

For employees working on Christian Louboutin’s integrated production facilities, collective bargaining agreements are covering employment relationships.

In addition, a specific and local framework has been implemented “Modello 231”, aiming at preventing offences to be committed by the employees of such production companies and avoiding criminal liability on the companies in case employees or management commit such offences. Modello 231 includes health and safety obligations. Training is provided to all employees involved on integrated production in Italy.

Worldwide Diversity Equity and Inclusion Committee

During the 2020-2021 financial year, the group has created a Worldwide Diversity Equity and Inclusion Committee (DE&I). The mission of the DE&I committee is to cultivate an environment where employees of all backgrounds have a safe space to discuss, celebrate, and champion for a workplace which enables everyone to succeed professionally and personally. This Committee is composed of ten members, three in each region where the group has employees (Americas / Europe - Middle East – India / Asia - Pacific) and one representative for the headquarters in Paris.

3.2. PREVENTION OF MODERN SLAVERY ON CHRISTIAN LOUBOUTIN SUPPLY CHAIN

Christian Louboutin is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout the supply chain, consistent with the disclosure obligations under the Modern Slavery Act 2015. Christian Louboutin expect the same high standards from all its contractors, suppliers and other business partners; as part of its contracting processes, Christian Louboutin has included specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and requires its suppliers and their own suppliers to hold the same high standards. 

Since 2019, all suppliers involved on Christian Louboutin supply chain (finished products, raw materials, components) have been required to adhere to a Code of Business Ethics, which include strict requirements regarding social and environmental sustainability, as well as anti-corruption obligations. In case of sub-contracting, Christian Louboutin requires the suppliers to ensure that their own suppliers adhere to the same obligations. Christian Louboutin reserves the right to check adherence to these principles and to conduct compliance audits at any time without notice. In the event of a violation of the Code of Business Ethics and depending on the nature of the violation, Christian Louboutin will either terminate the relationship with the supplier or work with the supplier to implement corrective action to remedy the non-compliance.

During the past financial year, Christian Louboutin has strengthened the level of commitment from its suppliers of finished goods by signing a specific manufacturing agreement, which includes the respect of the Code of business ethics as an essential obligation of the suppliers.

In 2022, Christian Louboutin will launch an audit of its supply chain, with regards to its suppliers’ compliance to the Code of Business Ethics.

Ultimate responsibility for the prevention of modern slavery rests with each of the company that approved this statement in relation to their own activity and their directors have overall responsibility for ensuring this policy and its implementation comply with their legal and ethical obligations.

Christian Louboutin employees are encouraged to raise concerns with their managers about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

Members of the public or people not employed by Christian Louboutin can write, in confidence, to the Group General Counsel at 19, rue Jean Jacques Rousseau Paris 75001 France to raise any concern, issue or suspicion of modern slavery in any part of Christian Louboutin business or related supply chain. Whilst Christian Louboutin will take seriously any concerns raised anonymously anyone raising a complaint is encouraged to put their names to allegations to help with investigations.

Christian Louboutin aims at encouraging openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Christian Louboutin is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of its own business or in any of its supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

Christian Louboutin zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter.

This statement has been communicated to Christian Louboutin employees in the UK. It forms part of the induction training process for new employees and is available in English.