Modern Slavery Act 2015 – Christian Louboutin Statement

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 on behalf of Christian Louboutin UK Limited as well as CL International SA (Switzerland), and Christian Louboutin Suisse SA (Switzerland), which supply goods and services in the UK market.

It underlines the steps taken by Christian Louboutin during its financial year ended 31 August 2023 to prevent risks of modern slavery within its businesses and supply chain.

2.1.Structure

The Christian Louboutin group of companies whose parent company is the French company Christian Louboutin SAS (collectively, “Christian Louboutin”) has retail affiliates across the world including Christian Louboutin UK Limited and Christian Louboutin Suisse SA (Switzerland).

Products are supplied to Christian Louboutin UK by CL International SA (Switzerland). Christian Louboutin Suisse SA (Switzerland) is in charge of the European e-commerce platform and shipping goods to UK customers.

2.2.Business

Christian Louboutin is a luxury fashion brand of footwear, handbags and small leather goods, kids and pet accessories, cosmetics and perfumes, and accessories for men and women (“Products”).

2.3.Supply Chain

Christian Louboutin has a properly owned manufacturing site in Italy as well as a close network of manufacturing partners mainly in Italy, but also in France, Spain, and Portugal which supply finished goods. This network also extends to raw material suppliers such as leather and tanneries as well as components which are directly selected by Christian Louboutin.

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 preventing all forms of slavery and human trafficking within Christian Louboutin’s sphere of influence.

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.

4.1.Policies

Christian Louboutin has implemented various policies which underline the commitment of the group in relation to the prevention of modern slavery and, in general terms, the protection of human rights and which are applicable to Christian Louboutin employees and suppliers.

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

• Christian Louboutin Employee Code of Conduct which will be updated in 2024 with a dedicated section on human rights
• Employee Handbooks (specifying notably the company’s Equal Opportunities Policy and its Bullying and Harassment Policy)
• Collective bargaining agreements cover employment relationships for employees working in Christian Louboutin’s own production facilities
• Christian Louboutin Code of Business Ethics which will be updated in 2024
• SpeakUp (Whistleblowing) Guide – NEW

4.2.Organization and Management Model 231

Within its production and service activities in Italy, an organization and management model has been implemented known as the “Modello 231,” aiming at preventing criminal offences – which specifically lists slavery, human trafficking, and illegal intermediation in labor and forced labor, among others – by employees of such companies and entrusting the supervision and verification of the efficiency and effectiveness of the model to an autonomous supervisory committee. Modello 231 includes trainings provided to all employees involved in the integrated production activities in Italy.

4.3.Due Diligence

In 2024, Christian Louboutin will continue to reinforce its compliance programs after the creation of a new Compliance & Privacy division within the Legal Department and the arrival of a new Compliance Manager in 2023 with the responsibilities, among others, of continuing to monitor and manage modern slavery and child labor risks within the global operations and supply chains of Christian Louboutin. It will particularly be reinforcing its supply chain traceability during the next financial year.

4.3.1. Direct Suppliers Certification

Christian Louboutin is committed to ensure transparency in its own business and in its approach to tackling modern slavery throughout the supply chain. Christian Louboutin expects the same high standards from all its contractors and suppliers; as part of its contracting processes, each supplier involved in Christian Louboutin’s supply chain are required to sign the Christian Louboutin Code of Business Ethics. 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 raw-material and finished-goods suppliers and their own suppliers to hold the same high standards. In case of sub-contracting, Christian Louboutin requires prior approval of the sub-contracting partner and to ensure that their own suppliers adhere to the same obligations.

4.3.2. Suppliers Auditing

Christian Louboutin continues to carry out audits by independent third-party organizations to evaluate compliance of its manufacturing and component suppliers with Christian Louboutin’s Code of Business Ethics and reserves the right to conduct compliance checks at any time without notice. In the event of a violation of the Code of Business Ethics and depending on the nature and gravity of the violation, Christian Louboutin reserves the right to terminate the relationship with the supplier or work with the supplier to implement corrective actions to any non-compliance.

4.4.Internal Trainings

Employee trainings have taken place within the company on the following topics:

Health & Safety

In 2023, an obligatory internal training on health and safety were carried out within its production activities in Italy.

CSR Initiatives

Since March 2022, Christian Louboutin has accelerated its Corporate Social Responsibility (CSR) initiatives with the arrival of a new Group CSR Director who is supported by nominated CSR ambassadors. The mission of these representatives is to contribute to the implementation of CSR within all levels and activities of Christian Louboutin.

• In 2022, Christian Louboutin carried out a one-day training on CSR for all ambassadors.
• In 2023 and 2024, the CSR ambassadors’ network will be extended to cover other international affiliates including within the UK.

Employee Code of Conduct

In 2024, all Christian Louboutin employees will be required to validate training on the Employee Code of Conduct which provides a specific chapter dedicated to the respect of human rights and its grievance mechanism.

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, their human resources department, or the Compliance and Privacy Division about any issue or suspicion of modern slavery in any parts of our business or supply chain.

A new, group-wide SpeakUp procedure was put in place in the third quarter of 2023. Employees of Christian Louboutin and workers of suppliers may submit concerns via a confidential, secure channel put in place by the company to raise any concern, issue, or suspicion of modern slavery in any part of Christian Louboutin business or related supply chain: https://cl-alert.integrityline.app/.

They may also write, in confidence, to the Compliance Manager at 19, rue Jean Jacques Rousseau Paris 75001 France.

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 from any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery, of any form, is or may be taking place in any part of its own business or its supply chain. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern.

Christian Louboutin’s 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.