UK and California transparency act in supply chains (MMXVIII)

Ralph Lauren Corporation and its affiliates and subsidiaries (including CHAPS and CLUB MONACO), has built its brand around the consistent production of high-quality products, from apparel and home furnishings to fragrances and accessories, and its commitment to conducting business according to the highest ethical and legal standards. We require all suppliers, factories, and contractors to adhere to our Operating Guidelines which set forth our business, legal, and ethical expectations and standards in the following areas: occupational health and safety, fair wages and benefits, work hours, transparent record-keeping practices, freedom of association, sub-contracting, customs compliance, product safety, conflicts of interest, anti-bribery, environmental sustainability, and prohibitions on child labor, forced labor, prison labor, discrimination, and harassment. In addition to our Operating Guidelines, our Foreign Migrant Workers Policy mandates ethical recruitment practices, including mandatory local language employment contracts, and the prohibition of worker-paid fees and end of contract travel expenses.


Ralph Lauren Corporation supports the California Transparency in Supply Chains Act of 2010 and the UK 2015 Modern Slavery Act.

Ralph Lauren Corporation requires all of its suppliers to prohibit the hiring of slave labor and prevent practices that could contribute to human trafficking.

To eradicate slavery and human trafficking from our supply chain, we:

1. verify product supply chains using third-party auditors to ensure that our product supply chains are compliant with our Operating Guidelines and our Foreign Migrant Workers Policy and all applicable laws and regulations prohibiting slave labor and human trafficking;


2. conduct independent audits of our suppliers to evaluate their compliance with our Operating Guidelines and our Foreign Migrant Workers Policy and all applicable laws and regulations prohibiting slave labor and human trafficking;


3. require certification by our suppliers that materials incorporated into our products comply with our Operating Guidelines and our Foreign Migrant Workers Policy and all applicable laws and regulations prohibiting slave labor and human trafficking in countries where our suppliers are doing business;


4. maintain internal accountability standards and procedures for employees and contractors failing to meet our Operating Guidelines and our Foreign Migrant Workers Policy prohibiting slave labor and human trafficking;


5. and provide training for our supply chain executives and employees on the prevention of human trafficking and slave labor.



Last revision 8.29.18


At Ralph Lauren Corporation, we are committed to producing high quality products responsibly. We require our suppliers across all regions of the world to meet our corporate, social and regulatory standards. We focus on strategic collaboration and partnerships with our suppliers to increase information sharing and to achieve meaningful progress on sourcing efficiencies, human rights and a sustainable supply chain.


RALPH LAUREN OPERATING GUIDELINES

RALPH LAUREN and its affiliates and subsidiaries (including CHAPS and CLUB MONACO) are dedicated to conducting our operations throughout the world on principles of ethical business practices and the recognition of the dignity of their employees. We expect our business partners and their suppliers, product suppliers, material and trim suppliers, service providers, and subcontractors to respect and adhere to our guidelines and to all applicable laws and regulations in the operation of their business. If the Company’s Guidelines or Policies conflict with a law, the highest standard shall prevail.

Our business partners and their affiliates must be transparent in all record keeping and embrace a fundamental effort toward operational efficiencies, social compliance, environmental sustainability and continuous improvement.
 

I. LEGAL AND ETHICAL STANDARDS

Our Suppliers must comply with all international, national and local laws including but not limited to: International Trade, Hazardous Substances, Product Safety, Anti-bribery, Conflicts of Interest, Labor and Intellectual Property.

INTERNATIONAL TRADE COMPLIANCE – Suppliers must comply with all applicable international laws relating to the import and export of products including country of origin labeling and product labeling. Suppliers are expected to participate in the Customs-Trade Partnership Against Terrorism Program (C-TPAT) as directed by the US Department of Homeland Security for all products and services.
 
PRODUCT SAFETY AND CONTINUING HAZARDOUS SUBSTANCES GUARANTEE –Suppliers must comply with applicable laws and regulations relating to product safety and hazardous substances for the state and the country of sale. We abide by the American Apparel and Footwear Association’s Restricted Substance Listing and REACH regulations.

CONFLICTS OF INTEREST / ANTI-BRIBERY – Suppliers shall never offer or accept, either directly or indirectly, compensation of any value (gifts, discounts, services, loans, payments) to or from any Ralph Lauren Corporation employee or affiliate, service provider or to government or political officials.

SUBCONTRACTING – Suppliers may only subcontract to preapproved suppliers for manufacturing or services according to our corporate requirements. Suppliers are responsible for ensuring that their subcontracted suppliers meet the same criteria herein. We have zero tolerance for unapproved and/or unauthorized subcontractors.


Please refer to Ralph Lauren Corporation’s Vendor Compliance Packet for additional information on our policies.

II. LABOR STANDARDS

EMPLOYMENT RELATIONSHIPS  – All engagement and employment of work must be strictly voluntary. Obligations to employees under labor or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of schemes designed to circumvent national or local wages, benefits or other labor laws. Suppliers should use temporary contracts only when absolutely necessary and to gradually provide permanent employment.

WAGES AND BENEFITS – Suppliers must comply with all laws regulating national and local wages, overtime compensation, and legally mandated benefits. Wage and benefit policies must be consistent with prevailing national standards.


WORKING HOURS  – All regular and overtime hours must be voluntary and in accordance with national laws. Employees must not be required to work excessive working hours and overtime and have at least one day off in seven. HEALTH AND SAFETY - Our business partners must ensure that their employees are provided a safe and healthy work environment, and are not subject to unsanitary or hazardous conditions.

TRANSPARENT RECORD KEEPING – We have zero tolerance for incomplete record keeping. We expect that all record keeping will be accurate and transparent at all times.

CHILD LABOR  - Suppliers must not use child labor, defined as employees under the age of 16. Employees between the ages of 16 and 18 should not be subject to night work or hazardous work. Apprenticeship programs will be reviewed on an individual basis.

FREEDOM OF ASSOCIATION  - Suppliers should respect the legal rights of employees to freely, and without harassment, participate in organizations of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining is restricted under law, the supplier allows the development of parallel means for independent and free association of bargaining. Workers who have made the decision to participate in such organizations shall not be the object of discrimination or disciplinary actions. Representatives of the organizations shall have access to their members under conditions of local laws or mutual agreement between the employer and the organization.

FORCED OR BONDED LABOR  - Suppliers will not work with or arrange for purchase of any materials or services that supports or utilizes forced labor, bonded labor, or labor obtained through human trafficking, coercion or slavery. Ralph Lauren Corporation’s Migrant Worker Policy provides additional standards for the hiring and employment of Migrant Workers.

DISCIPLINARY PRACTICES  - Suppliers will not employ any form of physical or mental coercion, or punishment or monetary fines against employees.

DISCRIMINATION AND HARASSMENT - Suppliers will not practice any form of discrimination or harassment in hiring and employment, based on race, color, religion, sex, gender, sexual orientation, age, marital status, disability, and ethnic or national origin or any other characteristic protected by law.

III. ANIMAL WELFARE AND ENVIORNMENTAL STANDARDS

Our Suppliers must embrace a fundamental concern for animal welfare and for environmental protection and conduct their operations consistent with local and internationally recognized environmental laws and best practices. They must also operate and source in such a manner that respects the environment and local communities, with particular concern to avoid deforestation, pollution, habitat loss and rising greenhouse gas emissions.

ANIMAL SOURCING PRINCIPLES  – Suppliers must share our commitment to principles, practices and regulations that require animals in our supply chain to be treated ethically and humanely. We expect suppliers to comply with the Five Animal Freedoms in the care of any animals. Please refer to Ralph Lauren Corporation’s Animal Welfare Policy for additional standards and guidelines for all animal sourced products.


ENVIRONMENTAL PERMITS  - Suppliers must comply with all applicable environmental laws and regulations in the country where it operates. All relevant licenses and permits must be current.

WASTEWATER MANAGEMENT – Suppliers should strive to use water efficiently. All discharges of wastewater must be in compliance with relevant local laws.

WASTE MANAGEMENT – Suppliers should strive to minimize waste and have procedures in place to properly dispose of both hazardous and nonhazardous waste.

CHEMICAL MANAGEMENT – Chemicals must be properly stored and labelled. Chemicals used in our product comply with the American Apparel and Footwear Association’s Restricted Substance Listing and REACH regulations.

Last Revision: March 2019