C & J Clark International Ltd.

"The working condition standards we expect our suppliers to follow are set out in our Code of Practice. These standards apply to all those engaged in the production of our products. Our Code of Practice requires compliance with all local legal and regulatory requirements and the core labour principles of the United Nations International Labour Organization (ILO) conventions."[...]"No employee shall be subject to any discrimination....All work must be conducted on a voluntary basis, and not under threat of any penalty or sanctions. The Supplier shall not use any form of forced, bonded, indentured, trafficked, slave or involuntary prison labour....Workers have the right to form and join trade unions and bargain collectively without prior authorization from suppliers’ management. Suppliers shall not interfere with, obstruct, or prevent such legitimate activities. Where the right to freedom of association and collective bargaining is restricted or prohibited under law, suppliers shall not hinder alternative forms of independent and free worker representation and negotiation, in accordance with international labour standards....No children under 15 years or the minimum school leaving age of the country where it is higher are to be employed or engaged in the production of Clarks products...No worker will be subject to any physical, sexual, psychological, or verbal harassment, violence, exploitation, or abuse."

"No employee shall be subject to any discrimination in employment, including hiring, salary, benefit, advancement, discipline, termination, or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, pregnancy, maternity or social or ethnic origin."

"Remediation, as used within this plan, is the process of ending situations of child labour, all forms of forced labour and labour trafficking, and as far as possible correcting any harms experienced by victims. It is important that this puts an end to modern slavery and tackles the harms experienced by the affected people. If Clarks either causes or contributes to a negative impact they will be responsible for the remediation. Even if there is no contribution or direct link this should not prevent Clarks from taking an active part in the response and remediation process."

"Deforestation and Conversion Free sourcing Clarks foresees Deforestation and Conversion Free legislations will be established in the upcoming years globally. We strongly suggest our suppliers to source leather from tanneries that can trace leathers physically or / and paper trail back to cattle. Suppliers may be asked to provide evidence to ensure that our produce do not come from Deforestation and Conversion lands. [...] Wet blue tanneries, agents and other suppliers must source cow hides exclusively from slaughterhouses or suppliers that have established and can provide evidence of credible supply chain monitoring systems for their direct suppliers to ensure zero deforestation cattle sourcing, and they must have plans in place to expand their monitoring systems to include indirect suppliers."

"Clarks is committed to eliminating deforestation and conversion of natural vegetation in our bovine leather supply chains originating from Brazil, where cattle ranching is a leading driver of forest loss and conversion. Cow hides must not be sourced from animals farmed on ranches involved in any deforestation in the Brazilian Amazon biome after October 5, 2009. We also require that hides are not sourced from ranches involved invasion of indigenous lands and/or protected areas, or have any governmental embargoes"

"Clarks is committed to eliminating deforestation and we require our suppliers to ensure that hides sourced from Brazil and not from farms involved in any form of deforestation in the Amazon biome (Since October 2009). We take a collaborative approach to developing our policies, and have worked with conversation organisation the National Wildlife Federation to strengthen our requirements with regards to leather sourcing in Brazil.We also place a high importance on animal welfare and are committed to the responsible sourcing of animal derived materials. We work with our suppliers, and multi-stakeholder groups such as the LWG and the Textile Exchange Responsible Leather Roundtable to build understanding and support the wider industry as they make improvements within animal welfare, while our Responsible Sourcing Policy for Animal Derived Materials sets out the minimum standards we expect our suppliers to adhere to."

"ENVIRONMENT Suppliers shall comply with all applicable laws and regulations regarding the protection and preservation of the environment. Suppliers shall adopt environmental management practices to minimise the use of energy & natural resources; to minimise all forms of discharge & waste; to maximise reuse & recycling and to manage & minimise adverse impacts on the environment [...] We monitor suppliers’ adherence to the standards set out in Clarks Code of Practice through audits as well as informal visits and assessments. Suppliers are expected to support and co-operate in the undertaking of all audit and assessment activities by Clarks, or our designated representatives, whether they are announced or unannounced. Where feasible, audits will be undertaken as unannounced or semi-announced to ensure the conditions assessed as closely as possible reflect those on a normal working day."

They have a Clarks Integrity Line for grievances in their operations, and require that all suppliers must have an internal grievance process, but that anonymous and independent reporting is also available through the ethics@clarks.com, and suppliers can use the integrity line in severe cases.

"Clarks encourages suppliers and partners to establish effective communication practices that involve workers and their representatives in meaningful dialogue on workplace issues to ensure workers are aware of their rights and responsibilities and that these are met. Where necessary appropriate training should be provided to ensure all levels can participate effectively in this process...We monitor suppliers’ adherence to the standards set out in Clarks Code of Practice through audits as well as informal visits and assessments. Suppliers are expected to support and co-operate in the undertaking of all audit and assessment activities by Clarks, or our designated representatives, whether they are announced or unannounced. Where feasible, audits will be undertaken as unannounced or semi-announced to ensure the conditions assessed as closely as possible reflect those on a normal working day."

"We have updated our list of suppliers to include those used in the production of the majority of our products for the Spring Summer 2022 season. This list includes the footwear suppliers we directly manage, who produce approximately 80% of our branded footwear, as well as the majority of footwear and non-footwear suppliers that are used through agents and licensees. In total these suppliers represent over 99% of Clarks production by volume."

"Suppliers are expected to sign a declaration of conformity each year to confirm that they have received and will comply with the requirements set out in this policy. [....] Compliance - Clarks suppliers must have documented evidence in place to demonstrate compliance to this policy and to conduct routine checks with their suppliers (e.g., of materials) on a seasonal basis. If Clarks determines that a material does not conform to the terms of this policy, the non-compliant party agrees to: • Begin an investigation into the cause and extent of the non-conformity; • Undertake corrective action, as approved by Clarks; • Clarks will take any steps required to ensure that the corrective action has successfully addressed the non-conformity; • Clarks reserves the right to cease the use of the non-compliant material and charge any costs as a result of a non-compliant materials back to the supplier of that material; and • Corrective action will be taken if any breaches are brought to our attention. For materials that are found to be noncompliant, Clarks reserves the right have material returned to suppliers at the suppliers cost and terminate our relationship with that supplier."

"Suppliers are expected to sign a declaration of conformity each year to confirm that they have received and will comply with the requirements set out in this policy. [....] Compliance - Clarks suppliers must have documented evidence in place to demonstrate compliance to this policy and to conduct routine checks with their suppliers (e.g., of materials) on a seasonal basis. If Clarks determines that a material does not conform to the terms of this policy, the non-compliant party agrees to: • Begin an investigation into the cause and extent of the non-conformity; • Undertake corrective action, as approved by Clarks; • Clarks will take any steps required to ensure that the corrective action has successfully addressed the non-conformity; • Clarks reserves the right to cease the use of the non-compliant material and charge any costs as a result of a non-compliant materials back to the supplier of that material; and • Corrective action will be taken if any breaches are brought to our attention. For materials that are found to be noncompliant, Clarks reserves the right have material returned to suppliers at the suppliers cost and terminate our relationship with that supplier."

"The working condition standards we expect our suppliers to follow are set out in our Code of Practice. These standards apply to all those engaged in the production of our products. Our Code of Practice requires compliance with all local legal and regulatory requirements and the core labour principles of the United Nations International Labour Organization (ILO) conventions."[...]"No employee shall be subject to any discrimination....All work must be conducted on a voluntary basis, and not under threat of any penalty or sanctions. The Supplier shall not use any form of forced, bonded, indentured, trafficked, slave or involuntary prison labour....Workers have the right to form and join trade unions and bargain collectively without prior authorization from suppliers’ management. Suppliers shall not interfere with, obstruct, or prevent such legitimate activities. Where the right to freedom of association and collective bargaining is restricted or prohibited under law, suppliers shall not hinder alternative forms of independent and free worker representation and negotiation, in accordance with international labour standards....No children under 15 years or the minimum school leaving age of the country where it is higher are to be employed or engaged in the production of Clarks products...No worker will be subject to any physical, sexual, psychological, or verbal harassment, violence, exploitation, or abuse."

"No employee shall be subject to any discrimination in employment, including hiring, salary, benefit, advancement, discipline, termination, or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, pregnancy, maternity or social or ethnic origin."

"Remediation, as used within this plan, is the process of ending situations of child labour, all forms of forced labour and labour trafficking, and as far as possible correcting any harms experienced by victims. It is important that this puts an end to modern slavery and tackles the harms experienced by the affected people. If Clarks either causes or contributes to a negative impact they will be responsible for the remediation. Even if there is no contribution or direct link this should not prevent Clarks from taking an active part in the response and remediation process."

"ENVIRONMENT Suppliers shall comply with all applicable laws and regulations regarding the protection and preservation of the environment. Suppliers shall adopt environmental management practices to minimise the use of energy & natural resources; to minimise all forms of discharge & waste; to maximise reuse & recycling and to manage & minimise adverse impacts on the environment [...] We monitor suppliers’ adherence to the standards set out in Clarks Code of Practice through audits as well as informal visits and assessments. Suppliers are expected to support and co-operate in the undertaking of all audit and assessment activities by Clarks, or our designated representatives, whether they are announced or unannounced. Where feasible, audits will be undertaken as unannounced or semi-announced to ensure the conditions assessed as closely as possible reflect those on a normal working day."

They have a Clarks Integrity Line for grievances in their operations, and require that all suppliers must have an internal grievance process, but that anonymous and independent reporting is also available through the ethics@clarks.com, and suppliers can use the integrity line in severe cases.