MODERN SLAVERY ACT TRANSPARENCY STATEMENT
The following statement has been prepared in the fulfilment of Bollé Brands UK Ltd obligations under the Modern Slavery Act 2015 and constitutes our company’s slavery and human trafficking statement for the financial year ending 31 March 2021.
The Modern Slavery Act seeks to address the role of businesses in preventing slavery and human trafficking from occurring in their business and supply chains. The issue of modern slavery is a growing concern, not only in the UK, but throughout the world. Bollé Brands Group, as a leading and proactive company, has a responsibility to ensure its supply chain and its business is free from any sort of forced labour or modern slavery.
1. Bollé Brands’ structure, business and supply chains
Bolle Brands group is a leading eyewear and head protection group that designs, markets and distributes sunglasses, safety glasses, goggles and helmets. Bolle Brands Group develops highly reputed trademarks like Bolle®, Serengeti®, H2Optix® Cébé®, Spy® and Bolle Safety®. Bolle Brands group’s products are distributed and worn all over the world.
Thanks to the complementary know-hows and innovative technologies developed by the six brands in their respective fields of activities, Bollé Brands group’s expertise covers a large spectrum of products that meet the highest requirements in terms of protection, performance, innovation and style.
Bolle Brands group’s entities are located throughout the world in Western Europe, North America and in the APAC region. They all share a common goal of developing their business while ensuring the highest quality and safety of our products and strive for continuous improvement.
Our group has more than 300 employees and 8 offices worldwide, our headquarters are located in Villeurbanne, France, our UK subsidiary is Bollé Brands (UK) Ltd.
Bollé Brands group’s products are manufactured by independent contract manufacturers located in a variety of countries including but not limited to Italy, China and Taiwan.
2. Bollé Brands’ policies in relation to slavery and human trafficking
a) Our internal policies
Bollé Brands Group strongly believes employee’s holistic well-being is an essential requirement to develop a successful and responsible business. Therefore, our Company sets workplace standards to ensure a safe, comfortable and enjoyable working environment for all those affected by our undertakings. It namely starts with eliminating hazards, continuously maintaining and improving a clean, friendly and hazard free environment.
b) Our supply chain policies
Bollé Brands Group is well aware of the risks of modern slavery and human trafficking in global supply chains. We adhere and aim at upholding the highest standards of responsible business conduct, business ethics, fair dealing, integrity, transparency, respect of human rights and implementation of fair and safe working conditions.
To ensure consistency with these values Bolle Brands group is determined to ensure the highest standards of responsibility and integrity throughout its supply chain. We are committed to work with supply chains that respect fair and safe conditions and socially responsible practices. Therefore, Bolle Brands group requests that suppliers sign our Supply and Manufacture Agreement which include a strong commitment in relation with slavery and working conditions. All our suppliers must acknowledge and commit with our “Code of Labour Practice” (“the Code”) which is annexed to our Supply and Manufacture agreement.
This schedule sets out the fundamental ethical and business conduct requirements for our suppliers. The Code aims at ensuring that our suppliers commit to offer a decent living wage and decent working conditions to all the workers involved in the chain of production and that each subcontractor they may hire complies with the Code as well.
The Code requires that our suppliers comply with obligations in relation with: Forced Labour, Discrimination, Child Labour, Minimum wages, Hours of work, Environment, Health and Safety, Disciplinary Practices and Management systems.
The Code also allows us to request information and access to our suppliers’ facilities at any time to ensure their conformity to the requirements of our code. We also request from our suppliers that they maintain appropriate records to demonstrate their conformity to the Code. We also include another code regarding our Anti-corruption & Bribery policy.
3. Our due diligence processes in relation to slavery and human trafficking in our business and supply chains
a) Our supplier selection process
Before selecting a new supplier Bolle Brands Group lists the criteria which must be met by the candidate supplier. Starting from Financial Year 21/22 Bolle Brands Group has decided to include ethical and social criteria in such requirements. As part of this selection process the candidate supplier is then audited by our internal Quality Control (QC) Inspectors and/or our Sourcing department to ensure its compliance with the selection criteria.
b) Our audit and inspection process
Bolle Brands Group provides its best efforts to assess potential supply chain risks and will conduct regular on-site audits of its main suppliers to ensure their compliance with our Code of Labour Practice and Manufacture and Supply Agreement. As mentionned in these documents Bolle Brands Group reserves the right to terminate its relationship with one of its suppliers if it fails to comply with any legal requirement of our Supply and Manufacture Agreement including our policies regarding slavery and human trafficking.
The ethical audits will be conducted by independent third parties. In addition, our internal Quality Control Inspectors, located in China and Taiwan, are frequently in relation with our suppliers on-site and are able to report any act of non-compliance with our ethical, environmental, quality, and social policies they would witness during their product inspections.
To ensure a greater monitoring of the modern slavery concerns and strengthen our social and environmental commitments Bolle Brands Group decided to create a new position of ESG Manager who will, namely, be in charge, in association with our Compliance and Supply department, to implement policies and due diligences processes to ensure that slavery and human trafficking is not taking place in our business and supply chains.
This statement was approved by the board of directors of Bolle Brands UK Ltd.
Bollé Brands UK Ltd