Supply Chain Transparency
California Transparency in Supply Chains Act of 2010 Disclosures
The California Transparency in Supply Chains Act of 2010 (SB 657) and the UK Modern Slavery Act require companies doing business in California and the UK, respectively, and which exceed certain size thresholds, to disclose information regarding their efforts to address slavery and human trafficking within their supply chain. The actions that KEEN, Inc., on behalf of itself and its subsidiary KEEN Europe Outdoor B.V., is taking in this area include those set forth below.
KEEN assesses the risks related to its supply chain at the country and factory levels. Risk assessment is performed by KEEN's sourcing, corporate responsibility, and legal teams. KEEN works closely with its affiliated entities that conduct local sourcing and production activities, and visits its Tier 1 suppliers regularly.
KEEN operates under a Code of Conduct that is issued to each Tier 1 supplier with the expectation that it will be posted on the production floor in the local language. KEEN conducts various types of visits and audits, both announced and unannounced, to evaluate compliance with KEEN's standards. Audits are performed by staff of KEEN and its affiliates, and KEEN works with suppliers to remediate issues identified during the audit.
KEEN's Tier 1 suppliers sign a manufacturing agreement, which includes a statement by the supplier agreeing to at all times comply with all laws applicable to its performance under the agreement. Upon KEEN's request, the supplier must provide written certification of compliance, as well as any additional information about the relevant goods so that KEEN may comply with its legal obligations.
In addition, KEEN has requested that all of its Tier 1 and Tier 2 suppliers complete the Facility Module of the Sustainable Apparel Coalition's Higg Index. By using this tool, KEEN gathers valuable information about the environmental, social, and labor conditions at each facility, including both its affiliate-owned facilities and contract manufacturing facilities.
KEEN maintains internal accountability procedures for employees and contractors regarding company standards in slavery and human trafficking. In the case of non-compliance, KEEN will examine the specific situation and develop a strategy for resolution. If cases of non-compliance are not resolved within a timely manner, KEEN may terminate the business relationship. KEEN has a dedicated team responsible for its corporate responsibility program.
KEEN expects key members of its supply chain management staff to be knowledgeable and aware of the risks and issues surrounding its supply chain, including concerns about slavery and human trafficking.
KEEN collaborates with a number of non-governmental organizations and trade associations to raise awareness of social compliance issues, including the Outdoor Industry Association's Social Responsibility Working Group (KEEN has been a member since 2008), and the Sustainable Apparel Coalition (KEEN has been a member since 2013). KEEN regularly monitor reports and follows the developments of leaders in the industry, such as the Footwear Distributors and Retailers of America and American Apparel and Footwear Association.
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Last Modified: January 18, 2018. This statement relates to the year ended December 31, 2017.