The California Transparency in Supply Chains Act of 2010 (SB 657) ( Act ) went into effect on January 1 , 2012. Salvatore Ferragamo S.p.A. (Ferragamo or the Company) supports the goals of the Act to eradicate slavery and human trafficking in its supply chain and to provide consumers with information regarding Ferragamo s efforts in this regard. Ferragamo has maintained a long-standing commitment to ensure human rights for all workers in its supply chain. The Company maintains a written Code of Ethics approved by its Board of Directors that explicitly renounces and opposes the exploitation of minors and the exploitation of employees in general. This Code of Ethics is distributed to employees, third party agents, consultants, and suppliers. In addition, Special Part G of the Company’s Organizational Model under Italian Law-Decree 231/ 2001 ( Organizational Model ) requires Ferragamo managers every two years to obtain from all third party suppliers certifications that they and their sub-contractors comply with all national labor laws, including those laws relating to minimum age, compensation, work conditions, and collective work agreements. Ferragamo has implemented the following efforts recognized in the Act to combat slavery and human trafficking in its supply chain:
Audit policies and procedures for verifying the supply chain: In accordance with the Organizational Model, Ferragamo s quality control inspectors audit third parties and sub-contractors in its supply chain for any Crimes Against Individuals, including slavery and human trafficking. The Company inspectors prepare a quality control report for each supplier that includes a section explaining any findings resulting from its audit that indicate the possible exploitation of workers. The audit reports are provided to the head of the legal department for consideration and further action, if appropriate.
Supplier certification: The Company requests that all suppliers and sub-contractors accept the principles and requirements set forth in the Code of Ethics and the Organizational Model, which include provisions prohibiting slave and forced labor.
Internal accountability standards: Ferragamo has implemented disciplinary measures applicable to employees and third parties for violation of the Company s Code of Ethics and Organizational Model. Violations are referred to the Organismo di Vigilanza (an internal compliance department), the head of the legal department and Human Resources department for disciplinary actions. Disciplinary actions include cancellation of a suppliers contractual relationship with the Company.
Employee training: Ferragamo provides training to its employees and managers on complying with the Company’s Organizational Model including Special section G that deals with Crimes Against Individuals. Ferragamo is committed to upholding human rights throughout the Company, including in its supply chain. The Company will continue to update its corporate policies to reflect its progress in preventing and addressing potential labor and human rights violations in its supply chain, particularly in the areas of slavery and human trafficking.