Modern Slavery Act 2015 – Christian Louboutin Statement

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”), which are mainly manufactured in Italy. Christian Louboutin has over 1,900 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 for Christian Louboutin UK Limited, CL International SA, and Christian Louboutin Suisse SA, in charge of the European e-commerce 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 2022 to prevent risks of modern slavery within its businesses or supply chain.

Modern slavery is a criminal offense 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.

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.

Christian Louboutin is reviewing in 2023 its ethical policies to reinforce company procedures.

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, known as the “Modello 231”, aiming at preventing offenses to be committed by the employees of such production companies and entrusting the supervision of the compliance of the model to an autonomous supervisory committee. Modello 231 includes health and safety obligations, and training is provided to all employees involved in the integrated production activities in Italy.

Worldwide Diversity Equity and Inclusion Committee

After formalizing its mission statement on Diversity, Equity, and Inclusion (DE&I) and integrating this vision into recruitment processes during the financial year 2020-2021, Christian Louboutin continues to develop a foundation on which all employees and managers can now rely.

Network of committed collaborators

 Christian Louboutin has appointed a person in charge of DE&I within the group, in order to maintain the momentum, represent, and coordinate these topics. Training on cognitive biases and diversity awareness has been deployed around the world. Finally, the DE&I Committee, created during the financial year 2020-2021, represents all Christian Louboutin’s activities and subsidiaries. The Committee identified a strategy, relayed ideas and discussions, and actively collaborated on several initiatives to support inclusion and propose projects that will be launched in the next financial year.

Concrete projects to nourish DE&I in all its dimensions

Based on a 3-pillar strategy: (1) Enriching diversity, (2) Ensuring equity and (3) Promoting inclusion, the DE&I committee proposed an action plan to raise awareness among all employees on different themes including ethnic origins, sexual orientation, gender, age, state of health, disability, and others.

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, the CSR ambassadors network will be extended to cover other international affiliates including within the UK.

Compliance & Privacy Division

Christian Louboutin will be reinforcing its Compliance programs with the creating 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 manage any human rights and modern slavery risks within the global operations and supply chains of Christian Louboutin.

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 expects 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 the Christian Louboutin Code of Business Ethics, which includes 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 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 remedy any 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 Christian Louboutin Code of Business Ethics as an essential obligation of the suppliers.

In 2022, Christian Louboutin began verifying its suppliers‘ adherence to the Christian Louboutin 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. A group-wide whistleblowing procedure exists and is made available to all employees within the company.

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 disclose their identity with their 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 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 is currently reviewing its group whistleblowing policy and will be implementing new procedures to reinforce the collection and treatment of ethical reports.

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 and is available in English.