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.