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Focuses on risk mitigation efforts on direct (tier 1) suppliers.
We also have a Code of Conduct that is applicable to all of the Company’s suppliers (including our third-partymanufacturing contractors and product licensees) (the “Supplier Code”). The Supplier Code expressly prohibits theuse of any form of slave, forced, bonded, indentured, or prison labor in any stage of the manufacture of our products.All work must be voluntary and workers must be free to terminate their employment at any time, without penalty.Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of persons bymeans of threat, force, coercion, abduction, fraud, or payments to any person having control over another person forthe purpose of exploitation.The Supplier Code provides that suppliers must ensure that no fees or costs have been charged, directly or indirectly,in whole or in part, to job-seekers and workers for their services directly related to recruitment for temporary orpermanent job placement, including when using the services of private recruiters, labor brokers or employmentagents or performing recruitment activities directly. Workers must not be required to pay employers’ or their agents’recruitment fees or other similar fees to obtain their employment (such as host country fees like levies, fees for workpermits, or fees for renewing work documents, or home country fees like visa fees, medical checks, or any other coststhat are not the legal responsibility of the worker). We require that our suppliers must repay these fees to the workerif found to have been paid by workers. Our suppliers must also ensure that the third-party recruitment agencies(including labor brokers) they use are compliant with the provisions of the Supplier Code and applicable law, and mustprovide us with a list of the recruitment agencies they are using and the amount of fees being paid to such agencies.Workers must receive a written contract in a language understood by the workers stating in a truthful, clear mannertheir rights and responsibilities in connection with their employment. Our suppliers may not retain any documents ordemand monetary deposits or other collateral as a condition of employment. Workers must not be subject to thewithholding of wages, original identification cards, original passports or other original travel documents or personalbelongings. In addition, the Supplier Code provides that our suppliers must comply with all laws regulating localwages, work hours and benefits.Our factory social compliance program requires that we communicate the Supplier Code initially as part of our directsupplier onboarding process and thereafter periodically from time to time, including when there are updates. TheSupplier Code is also available on our website at www.capriholdings.com.Pursuant to our factory social compliance program, all of the Company’s direct suppliers are required to certifycompliance with the Supplier Code in writing. We also generally require that the terms of any contracts with oursuppliers also include an undertaking to comply with our Supplier Code. In the event of a violation of the SupplierCode, we reserve the right to either terminate our relationship with the supplier or to work with the supplier toimplement corrective action to remedy the non-conformance. We expect our direct suppliers for recently acquired brands to be in compliance with our factory social complianceprogram within one year from the date of acquisition. In cases where full compliance by this date is challenging forone or more business partners of a recently acquired company, we will nonetheless continue to work with businesspartners that are honest, transparent and committed to making continuous improvements towards compliance