UK Modern Slavery Act 2015

Modern Slavery Act 2015 Statement

Williamson-Dickie Europe Ltd. is committed to sourcing its products in an ethical, legal and responsible manner and does not tolerate forced, bonded or involuntary labour, human trafficking or any forms of slavery and is committed to taking the necessary steps to prevent it within its operations and supply chain.
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Williamson-Dickie Europe Ltd. and its subsidiaries during its financial year ending 31 December 2016, to prevent modern slavery in its business operations and supply chains. It has been approved by the Board of Williamson-Dickie Europe Ltd. and signed by Kirk Ehrlich, President WD Europe Ltd.

Business, Structure, and Supply Chains

Williamson-Dickie Europe Ltd. is the European subsidiary of Williamson-Dickie Mfg. Co., the world’s leading provider of professional-grade performance workwear. Specializing in designing, manufacturing and delivering performance workwear since 1922, the Company and its subsidiaries offer premium quality products across a vast assortment of apparel, footwear and accessories. As a wholly-owned subsidiary with offices and distribution centres in the UK, Germany and France, Williamson-Dickie Europe Ltd. is the category leader in the European workwear market. The business has a global supply chain and its products are manufactured in a number of owned, sourced or licensed facilities located in the UK, Europe, Asia, and Africa.

Policy on Slavery and Human Trafficking

Williamson-Dickie Mfg. Co. and subsidiaries prohibit its suppliers from engaging in bonded or forced labour, human trafficking, child labour and other similar forms of modern slavery as defined by sections 1 and 2 of the Modern Slavery Act 2015. The Company utilizes the terminology “forced labor or other compulsory labor” to encompass all definitions of modern slavery.

Williamson-Dickie Europe Ltd.’s purchasing agreements require all suppliers to comply with applicable laws within the country of business, international standards, and trade regulations regarding human trafficking and modern slavery.

The Company also provides a Hotline phone number where ethical violations may be reported.

Risk Analysis

Williamson-Dickie Europe Ltd. assesses the risk of human trafficking and slavery related to the apparel and footwear supply chain. Country Risk Analysis is annually utilized to assess potential trafficking and forced labour risks. Risk assessment is performed either internally or externally, or both. Williamson- Dickie utilizes British Standards Institution (BSI), the leading global provider of supply chain intelligence and audit compliance and risk management software solutions to help identify, manage and mitigate global supply chain risks through country analysis and news monitoring. We require that all manufacturing facilities comply with country and local labour laws as well as Williamson-Dickie’s Company policies. We hold all of our suppliers to the same standard and require that each abide by our “Code of Business Conduct and Ethics” policy. The Company will not knowingly conduct business with companies that use forced labour or other compulsory labour in the manufacture and distribution of products. Additionally, Williamson-Dickie Europe Ltd. holds current certificates of registration in ISO 9001:2008 Quality Management System and ISO 14001:2004 Environmental Management Systems for design, manufacture, procurement and distribution of corporate and industrial clothing and footwear. At the time of this disclosure, all direct suppliers have been audited against our Company “Code of Business Conduct and Ethics” and no instances of modern slavery or human trafficking have been discovered.

Due Diligence Processes

Williamson-Dickie Europe Ltd. has assessed that its greatest modern slavery risk rests in the product supply chain and therefore, the business has focused its resources in this area thus far.

Williamson-Dickie Europe Ltd. conducts code of conduct and supply chain security audits of direct suppliers before entering into any type of agreement or partnership. We have developed and issued a code of conduct to our direct suppliers which are evaluated on their compliance of our code through audits renewed annually or as necessary. If during the audit issues are identified, corrective actions are addressed and additional audits may be conducted as required to assure compliance. Our audits are generally announced with reserved right of unannounced visits and are performed by a global network of either third party auditors with specialist local knowledge, internal auditors, or both.

Williamson-Dickie maintains and rigorously enforces internal accountability procedures for employees and contractors regarding company requirements to prevent human trafficking and slavery. In the case of non-compliance, Williamson-Dickie reserves the right to examine the specific situation and in conjunction with the supplier as appropriate develop the best possible strategy for resolution. If cases of non-compliance are identified, Williamson-Dickie Europe Ltd. will terminate the business relationship.

Training and Governance

Williamson-Dickie Europe Ltd. conducts internal training on Williamson-Dickie’s code of conduct and supply chain security to ensure the necessary participants in supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including human trafficking and slavery, with a particular focus on mitigating risks.
Williamson-Dickie requires employees involved directly in Williamson-Dickie’s supply chain to regularly participate in external training programs, industry committees and seminars on social compliance issues including a required course on the issues of human trafficking and slavery conducted by the University of Delaware.

Additional Information

Additional information can be found on the Corporate Responsibility section of our website http://www.williamsondickie.com/

company/corporate-responsibility

The Company is committed to driving continuous improvement of standards in supply chain management and will update progress in next year’s statement. It is confirmed that this statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 31, 2016.

Approved and signed by:

Kirk Ehrlich
President WD Europe Ltd