UK MODERN SLAVERY ACT / California Transparency in Supply Chain Act of 2010 Disclosure
One of our core values is to “Do the Right Thing - Always.” Wolverine World Wide, Inc., including its UK subsidiaries Wolverine Europe Limited and Wolverine Europe Retail Limited (collectively, “Wolverine” or the “Company”), maintains high standards of business ethics and holds a deep regard for human rights. We recognize the importance of responsibly sourced products and are committed to working with supply chain business partners that are dedicated to safe, humane, and ethical working conditions that comply with international labor standards. We have established guidelines to assist in our efforts to select partners who share our ethical commitments. Wolverine has zero tolerance for forced labor, human trafficking, and slavery or involuntary work of any kind anywhere in our supply chain.
Pursuant to the requirements of the Modern Slavery Act of 2015 and the California Transparency in Supply Chain Act of 2010, Wolverine makes the following disclosures of our reasonable efforts to ensure that slavery and human trafficking do not occur in our supply chain:
OUR COMPANY
With a commitment to service and product excellence, Wolverine is one of the world’s leading marketers and licensors of branded casual, active lifestyle, work, outdoor sport, athletic, children’s and uniform footwear and apparel. The Company’s portfolio of highly recognized brands includes Merrell®, Sperry®, Hush Puppies®, Saucony®, Wolverine®, Keds®, Stride Rite®, Chaco®, Bates® and HYTEST®. The Company is also the global footwear licensee of the popular brands Cat® and Harley-Davidson®. Wolverine’s products are carried by leading retailers in the U.S. and globally in approximately 170 countries and territories.
OUR POLICIES
Wolverine requires that our factory partners abide by our Production Code of Conduct, found at http://www.wolverineworldwide.com. The Production Code of Conduct is the realization of Wolverine’s commitment to human rights. This commitment includes upholding the human rights of workers by treating them with dignity, respect, and improving working conditions within our supply chain. The use of child labor, labor from victims of human trafficking or slavery are all strictly prohibited under our Production Code of Conduct. Furthermore, production partners must ensure that Wolverine’s Production Code of Conduct is followed by all suppliers, contractors, and subcontractors. The Production Code of Conduct is available to all Wolverine suppliers.
DUE DILIGENCE
- Risk Assessment
Wolverine utilizes internal and external audit information as well as international labor resources to assess risk of potential supplier partnerships. All new factories are assessed prior to production and must be approved by the Company’s Social Compliance Team.
- Auditing and Verification
All factory partners receive a copy of our Production Code of Conduct and new factory orientation which further communicates our Social Compliance Program requirements and auditing processes. The Company has a Standard Operating Procedure and Assessment Tool that guides our auditing team and external partners. Wolverine utilizes a combination of internal and external auditors. The Company’s staff of internal auditors, based in China and Vietnam, are aided by industry-leading third-party audit firms who assist with Wolverine’s audit program. In 2020, we conducted 164 social compliance audits.
As a general rule, our factory partners are subject to annual audits. However, our core production partners, which represent approximately 80% of our volume, are audited three times per year, with two audits generally conducted by our internal team of auditors and the third audit conducted by a third-party audit firm. Wolverine reserves the right to conduct unannounced inspections of its factories where appropriate.
ACCOUNTABILITY
Wolverine maintains internal accountability procedures to ensure Company standards on slavery and human trafficking. Furthermore, decisions regarding where and what direct suppliers to engage in our supply chain do not occur at the local level. Instead, those decisions are made by the Wolverine World Wide, Inc. Sourcing Department, with appropriate input from our Product Integrity Group, brands, auditors, and others as appropriate to avoid actual or apparent conflicts of interests and to ensure appropriate review and audit of direct supplier operations. Wolverine requires compliance with its Production Code of Conduct, and we maintain a zero-tolerance policy with respect to human rights violations including slavery and human trafficking, forced labor, child labor, life-threatening health and safety conditions, harassment, and discrimination. Wolverine will terminate any factory relationship where any of these zero tolerance violations are confirmed.
TRAINING
Wolverine trains its employees who are directly responsible for sourcing finished goods on mitigating the risk of slavery and human trafficking in our supply chain. Strict audit guidelines are provided to the Company’s internal auditors when visiting production partner facilities. Audit results are reviewed by the Company’s Product Integrity group and any findings of non-compliance are reviewed by the Company’s Legal Department.
Wolverine also provides training to our factory partners to ensure understanding of our requirements and provide an opportunity to share best practices. An annual Social Compliance Summit is held with all factory partners and targeted training in local language assists in continuous improvement of specific areas of the Production Code of Conduct.
REPORTING VIOLATIONS
Wolverine maintains the Wolverine Reportline so that employees, as well as employees of our contracted factories and suppliers, may always ask any question or raise any concern confidentially, and anonymously if desired. The Reportline number operates 24 hours a day and is available anywhere in the world in multiple languages via local toll-free numbers or online at http://WolverineReportLine.com. The Company strictly prohibits any form of retaliatory action being taken against employees who report known or suspected violations.
This statement covers January 1, 2021 to December 31, 2021, and has been approved by the Board of Directors of Wolverine World Wide, Inc.
Kyle L. Hanson
Senior Vice President, General Counsel, and Secretary
Blake W. Krueger
Chairman and Chief Executive Officer