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Modern Slavery Act 2015 – Year 2020 Statement
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “MSA”) on behalf of Fendi U.K. Limited (“Fendi UK”) and sets out the steps Fendi UK has taken during its financial year ending 31 December 2020 to ensure that slavery, servitude, forced or compulsory labour, and human trafficking (collectively, "Modern Slavery") is not taking place in any part of its business or in its supply chains.
Fendi UK is a subsidiary of Fendi Srl (hereinafter also referred as “FENDI”), which is part of the LVMH Moët Hennessy Louis-Vuitton SE (“LVMH”) Group (“LVMH Group”). References in this statement to “Fendi UK”, “FENDI”, “LVMH”, “LVMH Group”, “we,” “us,” or “our,” are to these named entities.
Fendi UK sells luxury and high-quality products under FENDI trademarks as leather goods, bags, ready-to wear, shoes, accessories (the “Products”), to clients in the United Kingdom.
Fendi UK purchases the Products from its controlling entity, FENDI, which are mainly manufactured in Italy, and purchase directly from local suppliers’ products and services necessary to run its business.
FENDI’s Supply Chain is founded on the long-lasting collaboration with a large number of small suppliers, mostly located in Italy, on which FENDI can rely on to deliver high level of artisanship and craftsmanship. Further information on our Supply Chain is available on FENDI’s website, sustainability section, at https://www.fendi.com/sustainability/.
Policies and Practices
FENDI’s commitment is to act with integrity in all its business dealings and to promote ethical conduct, to enhance compliance with applicable laws and to provide guidance with respect to business conduct. It has a number of policies that are relevant to this commitment, which set out what FENDI expects from its employees, internal business and its external suppliers. Our policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Key Policies are:
1. LVMH Suppliers' Code of Conduct ("Suppliers' Code of Conduct")
FENDI requires its suppliers, their suppliers and contractors, to commit with the same values and to act in full compliance with the relevant laws, including all national, local and international laws relating to the management of their businesses.
FENDI requires its suppliers to seek approval before subcontracting any part of their supply chain process and FENDI’s approval is subject to acceptance by the subcontractor of the Suppliers' Code of Conduct and all other applicable conditions that FENDI determines.
2. LVMH Code of Conduct
The LVMH Code of Conduct reiterates the commitment of each of the LVMH Group companies to act to the highest standards of integrity, respect and engagement in their behaviours and in the way that they conduct business every day, everywhere.
This code further states that the LVMH Group companies, including FENDI, will inform all of its commercial partners of its ethical principles and expectations and will ask its suppliers to comply with the principles set out in the Suppliers' Code of Conduct. In particular, this code specifies compliance with social issues under the following relevant sections "Implementing and promoting a responsible approach" and "Acting as a socially aware company" in particular when it comes to respecting and supporting human rights.
3. FENDI Organizational, Management & Control Model (the “Model”)
The Model was adopted on ___ pursuant to the Legislative Decree No. 231/2001 that has introduced the administrative liability of entities with respect to certain types of criminal offences perpetrated in their interest or to their advantage by executives of persons under their management or supervision. To ensure that the criminal offences under the Legislative Decree No. 231/2001 are prevented, FENDI has adopted the Model and has appointed a Supervisory Board, overseeing the functioning and the observance of the Model. The offence of placing or holding any person in conditions of slavery or servitude as well as the offence of illicit intermediation and labour exploitation (so called “caporalato”) are included among the criminal offences considered by Legislative Decree No. 231/2001 and therefore addressed in the Model.
4. Procurement Policy
FENDI’s Procurement Policy, applicable at worldwide level, sets out the rules to be followed in the selection of suppliers in accordance with applicable laws and regulations.
Both documents mentioned under points 1 and 2 above are available on FENDI’s website. The Model is available on FENDI’s website.
Supplier Due Diligence
Prior to engaging into any new contractual relationship with a supplier, FENDI requires suppliers to sign and acknowledge the Suppliers’ Code of Conduct.
FENDI reserves the right to check its new and existing suppliers’ adherence to the principles set out in the Suppliers' Code of Conduct and to conduct compliance audits at any time. Upon reasonable request, FENDI’s suppliers shall supply the necessary information and grant access to FENDI’s representatives to verify compliance with the requirements of the Suppliers’ Code of Conduct. Suppliers shall further keep proper and complete records to prove compliance with the Suppliers’ Code of Conduct and further provide access to complete, original, and accurate files to FENDI representatives.
Upon reasonable request, FENDI’s suppliers must improve and correct any deficiency discovered during any such audits.
FENDI shall use its best endeavours to ensure that all its suppliers’ template contracts contain clauses requiring our suppliers to adopt similar anti-slavery standards and practices.
In the course of 2020, FENDI has created a new page on its website entirely dedicated to the sustainability practices we are undertaking and which provides transparent information on its supply chain.
We have a compliance team who is actively working on ensuring that slavery and human trafficking do not take place in our business and supply chains. In addition to the WW Compliance Manager, such team consists of representatives from departments across the organisation including members of Legal, Internal Control, Procurement, Industrial and Supply Chain & Logistics teams.
Training and Awareness
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business FENDI conducts regular training for its employees to ensure compliance with legal requirements across the group for mandatory training and policies. Examples include, but are not limited to, training relating to the Model and corporate liability law, Anti-Corruption and Competition Law.
The training enables FENDI to reduce the risk of non-compliance through efficient processes and reliable data and reporting. All documentation, policies, learning material and resources are provided for and are easy accessible to all employees via the company’s intranet.
It is mandatory for all FENDI employees to familiarise themselves with this statement and it will form part of the induction process for new employees.
FENDI has also created a specific function in charge of sustainability matters that works, among other things, to prevent and mitigate the risk of modern slavery and human trafficking among FENDI’s supply chain.
All FENDI’s employees have access to the LVMH Alert Line which represents a grievance mechanism to anonymously report, any breach of the Code of Conduct or internal policies. Since the end of 2020, access to LVMH Alert Line has been extended to third parties, including partners and suppliers working with LVMH Maisons, including FENDI.
We are in the process of implementing certain key performance indicators across the Group to measure and assess how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. We expect to formalise these measures during the course of this financial year.
Following a review of the effectiveness of the steps we have taken this year to ensure that here is no slavery or human trafficking in our supply chains, FENDI’s commitment to prevent slavery, servitude and any other form of modern slavery in its supply chain is an ongoing process and the steps taken so far are part of a long-term commitment to uncover, tackle and prevent the issue of forced labour.
This statement is made pursuant to Section 54 of the MSA and constitutes Fendi UK’s Modern Slavery Statement for the financial year ending 31 December 2020. Fendi UK will ensure that this statement is reviewed and updated on an annual basis.
The Board of Directors of Fendi UK has approved this statement and it has been duly signed by the following director:
Alberto Da Passano
Fendi U.K. Limited
17 June 2021