Cole Haan Fighting Against Forced Labour and Child Labour in Supply Chains Report

1. Introduction
This Fighting Against Forced Labour and Child Labour in Supply Chains Report (the “Report”) is the first report submitted by Cole Haan LLC (“Cole Haan”) in compliance with Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”). The Report covers Cole Haan’s activities mitigating the risks of both forced labour and child labour in its supply chain in its most recently completed financial year, ending on December 31, 2024 (“Reporting Period”).

Cole Haan undertakes certain activities, including assessments of its suppliers, factory partners, and operations to prevent and reduce the risks of forced labour and child labour used in its supply chains or distribution channels. This Report outlines the steps that Cole Haan has taken during the Reporting Period to prevent and reduce this risk in compliance with the Act. Further, Cole Haan’s implementation of internal policies and procedures allows Cole Haan to have visibility and control over its supply chains, which leads to more informed sourcing decisions, improved risk mitigation and stronger accountability.

2. Steps Taken in the Reporting Period to Prevent and Reduce Risks of Forced Labour and Child Labour
To reduce the risk of forced labour and child labour in the Reporting Period, Cole Haan takes a structured and proactive approach that aligns with its legal obligations and ethical standards. In practice, Cole Haan has undertaken the following initiatives during the Reporting Period: (a) risk mapping and assessment of its suppliers and factory partners; (b) policy implementation; (c) supplier and factory partner engagement and remediation; and (d) reporting and transparency.

(a) Risk Mapping and Assessment of Suppliers and Factory Partners
Cole Haan annually audits and assesses its suppliers and factory partners using a third party that applies the SA8000 standard. The SA8000 is a globally recognized social certification standard focused on improving workplace conditions and ethical labour practices within organizations. The SA8000 audit standard addresses issues including: child labour, forced labour, health and safety, discrimination and management systems. Cole Haan voluntarily uses the SA8000 standard to audit its suppliers and factory partners to promote socially responsible workplace practices across its supply chain and prevent the use of forced labour and child labour by its suppliers and factory partners.

(b) Policy Implementation
Cole Haan is also committed to mitigating the use of forced labour and child labour in its supply chains through the development and implementation of internal policies. Cole Haan has developed a clear policy framework, that includes: the Cole Haan Supplier Code of Conduct and Supplier Handbook, Cole Haan Ethics Code, and the Cole Haan Anti-Corruption Policy. These policies are further described at Section 4 below.

(c) Supplier Engagement and Remediation
In compliance with the Act, Cole Haan engages with its suppliers and factory partners in a manner that promotes ethical and legally compliant practices at every stage in its relationship with the applicable supplier and factory partner. Cole Haan has set clear expectations of its suppliers in its Supplier Code of Conduct, further outlined below. Additionally, Cole Haan actively monitors its suppliers by conducting an annual third party audit of its suppliers to assess and identify any risk factors of using forced labour or child labour. Instead of simply policing its suppliers and factory partners, Cole Haan supports it suppliers and factory partners in remediating any risks of forced labour or child labour.

(d) Reporting and Transparency
In compliance with the Act, Cole Haan has published this Report on its website detailing its efforts in mitigating any risks of forced labour or child labour prevalent in its supply chains.

3. Cole Haan’s Structure, Activities and Supply Chains
Cole Haan is an American brand specializing in footwear and accessories. As of 2023, Cole Haan operates over 500 stores worldwide and maintains dual headquarters in New York City and Greenland, New Hampshire. Six stores are located in Canada and are owned by Cole Haan Canada, ULC, which is controlled by Cole Haan. All suppliers and factor partners in the Cole Haan supply chain are required to comply with Cole Haan’s Supplier Code of Conduct and Supplier Handbook. Additionally, all of Cole Haan’s suppliers are compliant with the SA8000 international standard. If a supplier or factory partner is found to violate applicable law or Cole Haan’s internal policies and standards, the supplier or factory partner is responsible for continually improving performance against an action plan and implementing management system that support compliance with the Supplier Code of Conduct and both national and international expectations. If the supplier fails to make progress against its action plan, it is subject to further review and sanctions, including potential contract termination by Cole Haan.

4. Ethics Policy and Due Diligence Processes in Relation to Forced Labour and Child Labour
Cole Haan’s practices effectively mitigate against forced labour and child labour in compliance with the Act. Specifically, Cole Haan as a means of mitigating forced labour and has implemented (a) an Employee Ethics Policy; (b) a Supplier Code of Conduct; (c) a Supplier Handbook; and (d) an Anti-Corruption Policy.

(a) Employee Ethics Policy: This policy requires each employee of Cole Haan to uphold ethical behaviour and to use good judgment in the way they conduct business.

(b) Supplier Code of Conduct: The Supplier Code of Conduct applies to all suppliers and factor partners that produce goods for Cole Haan or any of its subsidiaries, divisions, affiliates or agents. The Supplier Code of Conduct sets out the basic requirements that all suppliers must meet when conducing business with Cole Haan, which are based on internationally accepted labour standards, including the International Labor Organization’s core conventions, the Universal Declaration of Human Rights, SA8000 and the Footwear Distributors and Retailers of America Code of Conduct. The Supplier Code of Conduct specifically requires that all suppliers and factor partners fully comply with national and local legal requirements and regulations, at a minimum. In addition, all suppliers and factor partners must comply with industry standards and the requirements set out by the Cole Haan. Suppliers and factory partners of Cole Haan must further commit to upholding the human rights of workers, treat them with dignity and respect, and to improve working conditions within the supply chain. The Supplier Code of Conduct requires that special consideration to be given to the rights of those most vulnerable to abusive labour practices, such as young workers, women, homeworkers, agency workers, temporary workers, migrant workers and smallholders. The Supplier Code of Conduct expressly prohibits suppliers and factory partners from engaging or supporting the use of forced or compulsory labour, including prison labour and human trafficking. Additionally, suppliers and factory partners of Cole Haan must not recruit child labour. Further, there must be no recruitment of “young persons” who meet the standards of the minimum working age but are between the ages of 15 and 18 for duties that do not comply with the applicable international labor standards. All Cole Haan production facilities are required to comply with all local laws and the International Labor Organization standards regarding the working conditions and restrictions for “young persons”.

(c) Supplier Handbook: The Supplier Handbook outlines Cole Haan’s Code of Conduct & Code Management Systems Guidance Program, which sets forth the basic requirements all suppliers must meet in order to conduct business with Cole Haan. This includes an express requirement that suppliers and factory partners of Cole Haan not engage or support in the use of forced or compulsory labour, including prison labour and human trafficking. Cole Haan specifically advises its suppliers and factory partners on how to prevent forced labour in the supply chain, including: having a written policy that prohibits the use of forced labour of any kind, training management and workers on policies and procedures regarding forced labour, verify that workers hired through an employment broker have not paid a fee, provide all workers with a written contract in their own language and ensure that overtime work is voluntary without the threat of penalty or dismissal. Additionally, the Supplier Handbook prohibits the recruitment of child labour. Cole Haan advises its suppliers and factory partners on how to prevent the use of child labour in the supply chain by: creating policies and procedures that clearly define how age is verified in the hiring process, communicate and train workers on age verification procedures, use tools to effectively track the hours permitted to be worked by young workers and ensure that an effective remediation policy is in place for what to do when a child labourer is discovered.

(d) Anti-Corruption Policy: The Cole Haan Anti-Corruption Policy encourages reporting of any suspected or known illegal, unethical or inappropriate behaviour to the employee’s supervisor, the President and/or General Counsel of Cole Haan. The policy permits anonymous reporting, and Cole Haan does not permit retaliation of any kind against anyone who makes a report or complaint in good faith and with a reasonable basis that unethical, illegal or inappropriate conduct has occurred.

5. Forced Labour and Child Labour Risks
Cole Haan implements a rigorous internal framework to mitigate the risk of forced labour and child labour in its supply chain. All of the suppliers and factor partners that Cole Haan utilizes are thoroughly investigated and audited prior to being onboarded to ensure the practices of the supplier or factor partner are compliant with all applicable law and Cole Haan internal policies. Due to its rigorous framework, vetting of its suppliers and factory partners prior to onboarding, and continued annual audits, there is a minimal risk of forced labour and child labour being present in Cole Haan’s supply chain.

6. Measures Taken to Remediate Forced Labour or Child Labour
Cole Haan will work effectively with its suppliers and factor partners to remediate any identified risks of forced labour or child labour in the supply chain. Additionally, Cole Haan has a zero tolerance policy where if a significant, egregious and systemic violation of both the Cole Haan Code of Conduct and local law are identified, immediate corrective action must be taken, and Cole Haan reserves the right to terminate its business relationship with the supplier or factory partner that is not compliant. Where a supplier or factor knowingly and systematically uses forms of forced labour (including prison labour, trafficking, slavery and indentured workers) in which workers’ freedom of movement, ability to willingly leave work, and human rights are denied or severely restricted would precipitate a potential termination of the business relationship by Cole Haan. Additionally, if a supplier or knowingly employs workers below the age of 15 or younger than the applicable legal minimum age or international standard (whichever is stricter), Cole Haan may terminate its business relationship with the applicable supplier or factor partner.

7. Remediating the Loss of Income to the Most Vulnerable Families
Cole Haan acknowledges that efforts to prevent and reduce the risks of forced labour and child labour can have the unintended consequences of contributing to a loss of income for the most vulnerable families. Currently, Cole Haan is not aware of any instances to date where its respective efforts to mitigate the risk of forced labour and child labour in its activities and supply chains may have contributed to a loss of income for vulnerable families.

8. Training Provided to Employees on Forced Labour and Child Labour
Cole Haan is in the process of updating it employee training programs to expressly comply and train its employees in accordance with the Act. This includes building employee awareness, accountability and skills across its operations to mitigate the risk of any potential use of forced labour or child labour in its supply chains. In the coming financial year, Cole Haan will be further developing training content to comply with the Act, including provide general training to staff on the company’s commitment to ethical sourcing in its procurement process to identify high-risk suppliers and factory partners and flag labour violations.

9. Assessing our Effectiveness
Cole Haan is committed to effectively assessing and addressing forced labour and child labour risks in its operations and supply chains and aims to continually improve its ability to assess these risks over time through the implementation of the Cole Haan Supplier & Factor Partner Continual Improvement Process. Cole Haan has an established set of parameters that it uses to engage with and assess new suppliers or factor partners, the assessment is then confirmed by supplier and a third party monitoring firm. The assessment is thorough and includes a facility walkthrough, worker interviews and document review. If an assessment identifies any risks of forced labour or child labour, a corrective action is developed, caried out and a follow-up assessment scheduled as needed.

Cole Haan additionally audits its current suppliers and factory partners on an annual basis. If a supplier or factor partner receives a rating of Yellow or Orange, it must remediate the applicable issues and submit to an additional audit. If a supplier or factory partner has a rating of Orange for more than two years in a row, Cole Haan will review the future of its sourcing relationship. If a supplier or factory partner receives a rating of Red from an annual audit, production is paused until the issues are effectively remediated and additional audits are completed at three month intervals until all critical issues are resolved.

Cole Haan is distinctly committed to transparency in our efforts to combat and limit forced labour and child labour in its supply chains. Cole Haan recognizes that combatting modern slavery in the supply chain is an ongoing process requiring continued improvement.

10. Board of Directors Approval and Attestation Statement
This Report was Approved by the Board of Directors of Cole Haan pursuant to section 11(4)(b)(ii) of the Act.

In accordance with the requirements of the Act, and in particular Section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.