California Transparency Act
MEETING COACH’S OBLIGATIONS UNDER THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT (SB657):
Coach, Inc.'s (“Coach”) objective is to be a good employer and a responsible and socially sensitive corporate citizen in the locations and manner in which we conduct business. In order to accomplish these objectives, Coach has operated a Global Business Integrity Program since the date of our incorporation. This Program sets forth the ethical and legal responsibilities that all Coach employees, contractors and suppliers are expected to uphold.
The Global Business Integrity Program consists of three published documents. These documents are publicly available on Coach’s website www.coach.com:
- 1. A guide to the Global Business Integrity Program
- 2. The Global Operating Principles which sets forth the minimum standards by which strategic partners must operate
- 3. Supplier Selection Guidelines for parties from whom Coach sources products, including contractors, joint venture partners and suppliers of goods and services
These documents clearly state Coach’s views on the ill treatment of workers, including our refusal to do business with those engaging in child labor, forced labor, discrimination, health and safety violations or the overwork of workers. Coach’s business principles and philosophies are founded on dignity and respect for the individual, a strong commitment to common sense, fairness, diversity, and ethical business practices and policies.
In order to monitor adherence to our Global Business Integrity Program, Coach created the Global Business Standards Committee, comprised of senior executives, which meets quarterly. Coach also has a GBS Hotline (1-800-396-1807) on which employees and consumers alike can report issues with and deviations from Coach's principles and philosophies.
THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT (SB657):
To meet our obligations under the California Transparency in Supply Chains Act (SB657), Coach dedicated significant resources to researching and complying with the law. Coach is hereby publicly disclosing the efforts that we routinely undertake to identify and address slavery and human trafficking. It is our hope that these efforts will assist our customers and the public alike to make more informed choices regarding their support of companies.
Coach has adopted the following broad definition of slavery: “the act of holding the worker against his or her will and controlled physically or psychologically by violence or its threat for the purpose of appropriating their labor” as defined by the international non-governmental organization Free the Slaves (see www.freetheslaves.net).
Coach has adopted the following broad definition of human trafficking: “any recruitment, harboring, transportation, provision or obtaining of a person for labor services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery” as defined in the Victims of Trafficking and Violence Protections Act of 2000.
Coach assesses our risk of slavery and human trafficking as low for the following reasons:
- 1. Verification of Product Supply Chain: Coach verifies its product supply chain by conducting audits at all of our factories to ensure compliance with our code of conduct and guidelines, including Coach’s Global Business Integrity Program. Both human trafficking and slavery fall within our code’s definition of “forced labor” and, as such, are strictly prohibited, and penalized, at all stages of the product supply chain.
- 2. Conducts Audits of Suppliers: In addition to Coach employees, Coach also hires independent third party auditors who routinely undertake unannounced visits to all Coach manufacturing locations and provide Coach with foll reports on the living and working conditions of people retained to work at those locations. Each location receives at least one unannounced audit visit in a year.
- 3. Requirement for suppliers to certify compliance: Coach requires that all direct suppliers provide an annual certification of their compliance with Coach’s standards for employment - including a certification on the part of the supplier that all materials sourced for and incorporated into Coach products comply with slavery and trafficking laws of the country or countries where the supplier is doing business.
- 4. Maintains internal accountability standards: Coach has developed a code of conduct for all parties working with Coach - as embodied in the Global Business Integrity Program. In the case of non-compliance, Coach reserves the right to examine the specific situation and develop a strategy for resolution. If non-compliance is not resolved within a timely manner, Coach may terminate a business relationship.
- 5. Conducts Training: Coach conducts internal trainings of Coach employees to ensure that participants in the supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including human trafficking and slavery, with a particolar focus on mitigating risks. In addition, on December 20, 2011 Coach conducted a training seminar in China for external personnel - including suppliers and key factory personnel - to educate them on the requirements for compliance with and adherence to SB657. Coach will assess the need to repeat this type of training again at a later date.