BROAD APPROACH:

According to the statement, Christian Louboutin UK takes active steps to prevent opportunities for modern slavery to occur within its direct suppliers (and sometimes indirect suppliers). It has a "zero tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships" and then "implementing and enforcing effective systems and controls" to prevent modern slavery and human trafficking. According to the 'Policy Statement' on page 1, CL is specifically "committed to fighting all forms of slavery and human trafficking," including "forced and compulsory labour and human trafficking."

* Each company and directors within the statement (UK, International, and Swiss CL) accepts responsibility for its unique supply chain, according to section 4 "responsibility for the policy."

DIRECT AND INDIRECT:

It "expect[s] the same high standards [against modern slavery] from all its contractors, suppliers and other business partners."

* Specifically, when contracting, CL includes specific prohibitions with its direct suppliers to prevent the forced labour of adults and children AND requires its indirect suppliers to "hold the same high standards" (although whether this includes implementing the same prohibitions is unclear).

* As of 2019, direct and indirect suppliers in CL's supply chain involved in "finished products, raw materials, [and] components" must adhere to a Code of Business Ethics. Amongst other things, it targets 'social sustainability' for employees. It requires suppliers to promote this in themselves and their own suppliers, and it can check adherence at any level "at any time without notice" and then either terminate ties or assist with corrective remedial action if a violation is found. Only with the direct suppliers of finished goods is the Code of Business Ethics an essential written obligation within a specific manufacturing agreement.

** DEVELOPMENT: In 2022, CL will initiate an audit of its supply chain's compliance to the Code.

As mentioned 'suppliers and their own suppliers'. We have considered that this applies to 'beyond Tier 1'.

pg. 2

“Christian Louboutin expect the same high standards from all its contractors, suppliers and other business partners; as part of its contracting processes, Christian Louboutin has included specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and requires its suppliers and their own suppliers to hold the same high standards.”

There is no mention of Code of Business Ethics includes modern slavery. Hence, removed 'Code of conduct include MS clause'.

“Since 2019, all suppliers involved on Christian Louboutin supply chain (finished products, raw materials, components) have been required to adhere to a Code of Business Ethics, which include strict requirements regarding social and environmental sustainability, as well as anticorruption obligations. In case of sub-contracting, Christian Louboutin requires the suppliers to ensure that their own suppliers adhere to the same obligations.”