COLE HAAN’S ANTI-FORCED LABOUR AND CHILD LABOUR POLICY

1. Purpose
The purpose of this policy (“Policy”) is to affirm the commitment of Cole Hann LLC and its subsidiaries (“Cole Haan,” “we”) to preventing and addressing risks of forced labour and child labour within its operations and supply chains. This Policy is designed to comply with Canada’sFighting Against Forced Labour and Child Labour in Supply Chains Act(the “Act”).

2. Scope
This Policy applies to all employees, officers, and directors of Cole Haan (collectively, “Employees”) of Cole Haan, as well as all suppliers, vendors, factory partners, and subcontractors of Cole Haan (collectively, “Contractors”) who provide goods or services to the company.

The objective of this Policy is to mandate that both Employees and Contractors: (a) maintain the integrity and reliability of Cole Haan’s business operations; (b) comply with all of Cole Haan’s legal and regulatory requirements with respect to forced labour and child labour; and (c) reduce the risk of forced labour and child labour in Cole Haan’s supply chain.

3. Policy Statement
Cole Haan is committed to ethical sourcing and responsible business practices. We strictly prohibit the use of forced labour and child labour in any part of our business or supply chain. We recognize the heightened risks in global manufacturing and are dedicated to transparency, accountability, and continuous improvement to mitigate any risk of forced labour or child labour in the Cole Haan supply chain. This Policy has been established to enable Employees of Cole Haan to raise concerns forced or child labour of a Contractor on a confidential basis, free from discrimination, retaliation, or harassment, anonymously or otherwise.

4. Compliance & Supplier Code of Conduct
Applicable Employees must ensure that each Cole Haan Contractor adheres to Cole Haan’s Supplier Code of Conduct, which outlines expectations regarding labour standards, human rights, and ethical business practices. Cole Haan’s Supplier Code of Conduct is available here.

Each applicable employee is required to comply with this Policy. In addition, each Cole Haan manager is responsible for implementation and enforcement of this policy within the manager’s area of responsibility. Each operational unit and department at Cole Haan (a “Business Unit”) is responsible for ensuring Contractors engaged during business are not using or at risk of using forced labour or child labour in the provision of services to Cole Haan. Each manager of the applicable Business Unit is responsible for implementation and enforcement of this Policy within the manager’s area of responsibility.

The Legal, Human Resources, and Corporate Responsibility Business Units are responsible for conducting risk-based due diligence across direct operations of Cole Haan with Contractors to identify any risk of forced labour and child labour and work with the applicable Contractor to remediate any identified instance of forced labour or child labour. If any reported incident of suspected or known instance of forced labour or child labour by a Contractor is unable to be remediated by Cole Haan, or the applicable Business Unit, the contractual relationship with the applicable Contractor shall be terminated.

5. Due Diligence and Risk Assessment
Employees in the Legal, Corporate Responsibility, and Sourcing Business Units shall undertake activities, including assessments of its suppliers and factory partners, to prevent and reduce the risks of forced labour and child labour used in Cole Haan’s supply chains or distribution channels. Employees in the Legal and Corporate Responsibility Business Units are responsible for conducting annual audits and assessing Cole Haan Contractors via a third party, which applies the SA8000 standard. The SA8000 standard is a globally recognized social certification standard focusing on improving workplace conditions and ethical labour practices within organizations. Employees in the Legal and Corporate Responsibility Business Units shall conduct regular audits that specifically address issues of forced labour and child labour in Cole Haan’s supply chain.

6. Training and Awareness
To assist with compliance with this Policy, Cole Haan provides training to all Employees involved in procurement and supply chain management to help identify signs of forced labour and child labour. This includes building awareness, accountability, and skills across Cole Haan’s operations to mitigate the risk of forced labour or child labour by Contractors, in Cole Haan’s supply chains and more generally, in Cole Haan’s business operations.

7. Cole Haan Reporting Obligations
In accordance with the Act, Cole Haan publishes an annual report each year. The report details the steps taken to prevent and reduce risks of forced and child labour in Cole Haan’s supply chains. The report will be made publicly available on our website.

8. Compliance, Reporting and Enforcement
Cole Haan takes violations seriously and will act decisively to uphold our standards. As soon as an Employee becomes aware of a circumstance of suspected or known forced labour or child labour by a Contractor in the Cole Haan supply chain or within Cole Haan’s business operations, they must immediately report directly to the Legal and Corporate Responsibility Business Units or if they choose to report anonymously, reports may be made through https://colehaan.allvoices.co. An Employee reporting under this Policy may choose to disclose his or her identity but is guaranteed anonymity in the event of self-identification.

Employees who fail to adhere to this Policy will be subject to disciplinary action, up to and including termination of employment. Additional audits may be conducted to confirm that this Policy has been properly implemented and that Employees are complying with the requirements herein.

No Employee who in good faith makes a report under this Policy shall suffer retaliation, harassment, or an adverse employment consequence as a result of such submissions.

9. Updates
This Policy will be reviewed and updated as necessary to reflect changes in legislation, business operations, or risk assessments. Cole Haan remains committed to continuous improvement and engagement in our efforts to combat forced labour and child labour in our supply chains.

10. Contact Information
Business Units shall appoint an individual responsible for the implementation of and compliance with this Policy. Should you have any questions regarding the general application of this Policy, please contact:
SVP, Legal, Human Resources & General Counsel, Laura Kelley, and/or Director of EHS, Frank Herland.