4.1.Policies in relation to slavery and human trafficking
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 were in effect for FY 2025 are communicated to all employees – either when they join Christian Louboutin, or when such policies become available or are updated – and include:
-Adherence to the UN Global Compact (since January 2025)
-Employee Code of Conduct, updated in 2024 with a dedicated section on human rights and health and safety
-Employee Handbooks (specifying notably the company’s equal opportunities and bullying and harassment policies
-Collective bargaining agreements covering employment relationships for employees working in Christian Louboutin’s own production facilities in Italy
-Christian Louboutin Code of Business Ethics (“CBE”), updated in 2024
-SpeakUp (Whistleblowing) Guide
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 Processes
In 2025, Christian Louboutin continues to reinforce its compliance programs after the creation of a new Compliance 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.
In 2025, Christian Louboutin further reinforced its due diligence process, which is structured around several fundamental pillars:
a. Responsible Selection Criteria
The Maison prioritizes working with partners who are certified according to internationally recognized standards, such as:
- Leather Working Group (LWG): to ensure high environmental performance of tanneries and promote safe working conditions throughout the leather supply chain. Christian Louboutin has surpassed its goal of sourcing 80% of leather from LWG-certified suppliers, with 97% achieved in FY25.
- Global Recycled Standard (GRS): for fabrics made from recycled fibers, ensuring both traceability and social responsibility in the sourcing and production process.
These certifications form part of Christian Louboutin’s broader commitment to ethical sourcing and the prevention of modern slavery and forced labor within its supply chain.
b. Contractual Commitment via the Christian Louboutin CBE
As part of its contracting processes, each supplier – including component, raw material and finished-goods suppliers – involved in Christian Louboutin’s supply chain are required to sign the Christian Louboutin CBE. 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. Each supplier must ensure the absence of modern slavery and human trafficking in its entire value chain. 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 Christian Louboutin CBE.
c. A Supply Chain Traceability Program
This supply chain traceability program aims to progressively map each stage of the production process, from the sourcing of raw materials to the final manufacturing of products and aims to identify the origin of components and materials. This approach not only enhances transparency but also enables the company to proactively identify and address potential risks, including – though not limited to – modern slavery and human trafficking.
d. Preliminary Compliance & Financial Screening of Suppliers at Risk
Christian Louboutin has established a comprehensive compliance screening process to be conducted prior to entering any business relationship. This process is based on internal criteria designed to identify entities or individuals involved in illicit activities, such as corruption, money laundering, or organized crime, as well as connections to politically exposed persons (PEPs), international sanctions, or media controversies. In addition, the screening includes the identification of negative media sources and legal proceedings concerning forced labor, violations of working conditions, or other human rights abuses.
e. Supplier Auditing & Monitoring
Each season, Christian Louboutin continues to carry out audits by independent third-party organizations to evaluate compliance of its manufacturing, raw material, and component suppliers with Christian Louboutin’s CBE. Christian Louboutin reserves the right to conduct compliance checks at any time without notice. In the event of a violation of the CBE and, depending on the nature and gravity of the violation, Christian Louboutin reserves the right to implement corrective actions to any non-compliance or terminate the relationship with the supplier or work with the supplier if necessary.
4.4.Internal Trainings
Employee trainings have taken place within the company on the following topics:
a. Health & Safety
In 2025, obligatory internal training on health and safety was carried out within its production activities in Italy.
b. Working Conditions & Human Rights
In February 2025, a dozen selected employees from various entities, regions, and functions—including those responsible for managing supplier relationships for components, raw materials, and finished goods—participated in dedicated awareness sessions focused on working conditions and human rights including the fight against forced labor. These sessions aimed to strengthen understanding of modern slavery and human trafficking risks within the supply chain and reinforce the company’s commitment to ethical sourcing and compliance with applicable legislation.
c. Employee Code of Conduct
In 2025, Christian Louboutin concluded its training campaign of the new version of the Employee Code of Conduct which provides a specific chapter dedicated to the respect of human rights and its grievance mechanism. Christian Louboutin met its FY25 goal, with at least 80% of employees worldwide completing and passing mandatory training on the Employee Code of Conduct.