Required Disclosure under California Transparency in Supply Chains Act of 2010
California law requires companies to disclose their efforts to address the issues of slavery and human trafficking in their supply chains. Michael Kors Holdings Limited (the "Company") has a Code of Conduct which is based on principles of ethical business practice and recognition of the dignity of others. The Code of Conduct is applicable to all of the Company's vendors and licensees. The Code of Conduct expressly prohibits the use of prison or forced labor, or the acquisition of any materials used in any stage of the manufacture of any of our products from a third party who utilizes prison or forced labor. For a copy of the Company's Code of Conduct applicable to the Company's business partners, please see attached.
The Company has an audit program under which supplier audits are conducted by a third party auditor to assess compliance with its Code of Conduct. The vendors selected for audits each year are based on a risk assessment conducted by an analysis of: (i) preliminary inspection of each new vendor's facility, (ii) detailed questionnaires required from all potential vendors, and (iii) consideration of the anticipated output from each vendor, with repeat audits planned based on audit results obtained.
All of the Company's vendors are required as part of their vendor agreement to certify compliance with the Code of Conduct. All of the Company's licensees are required to represent and warrant compliance with the Company's Code of Conduct.
Failure of employees to abide by the Company's Code of Conduct can result in corrective action up to and including termination of employment. Failure of vendors to abide by the Company's Code of Conduct can result in corrective action up to and including the termination of all existing and future business. Failure of licensees to abide, and to cause all of their vendors to abide, by the Company's Code of Conduct constitutes a default under the license agreement and can result in termination of the license agreement and other remedies.
The Company requires all employees and management who have direct responsibility for supply chain management to take a course directed at raising awareness regarding the risks of human trafficking and slavery in supply chains, identifying potential risks and addressing those risks when human trafficking and slavery are suspected.