Modern Slavery Statement California – Christian Louboutin

This statement is made pursuant to the California Transparency in Supply Chains Act of 2010 (SB 657) on behalf of Christian Louboutin LLC (USA) and CL US Distribution Corporation (USA).

It underlines the steps taken by Christian Louboutin LLC (USA) and CL US Distribution Corporation (USA) during the financial year ended 31 August 2023 to prevent risks of modern slavery and human trafficking within its business and supply chain.

Slavery and human trafficking are criminal offences within the United States of America and the State of California, and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced, and compulsory labor, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

Christian Louboutin fully adheres to the principles and fundamental rights outlined in the Universal Declaration of Human Rights and is committed to preventing all forms of slavery and human trafficking within Christian Louboutin’s sphere of influence.

Christian Louboutin has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or in any of its supply chains.

3.1. Internal Accountability Policies

Christian Louboutin has implemented various policies which underline the commitment of the group in relation to the prevention of modern slavery and, in general terms, the protection of human rights and which are applicable to Christian Louboutin employees. 

These policies – which are shared with all employees (either when they join Christian Louboutin, or when such policies become available or are updated) include:

• Christian Louboutin Employee Code of Conduct which will be updated in 2024 with a dedicated section on human rights
• Employee Handbooks (specifying notably the company’s Equal Opportunities Policy and its Bullying and Harassment Policy)
• Collective bargaining agreements cover employment relationships for employees working in Christian Louboutin’s own production facilities in Italy
• SpeakUp (Whistleblowing) Guide – NEW

3.2. Organization and Management Model 231

Within its production and service activities in Italy, an organization and management model has been implemented known as the “Modello 231,”, aiming at preventing criminal offences – which specifically lists slavery, human trafficking, and illegal intermediation in labor and forced labor, among others – by employees of such companies and entrusting the supervision and verification of the efficiency and effectiveness of the model to an autonomous supervisory committee. Modello 231 includes trainings provided to all employees involved in the integrated production activities in Italy.

3.3. Due Diligence

In 2024, Christian Louboutin will continue to reinforce its compliance programs after the creation of a new Compliance & Privacy division within the Legal Department and the arrival of a new Compliance Manager in 2023 with the responsibilities, among others, of continuing to monitor and manage modern slavery and child labor risks within the global operations and supply chains of Christian Louboutin. It will particularly be reinforcing its supply chain traceability during the next financial year.

3.3.1. Direct Supplier Certification

Christian Louboutin is committed to ensure transparency in its own business and in its approach to tackling modern slavery throughout the supply chain. Christian Louboutin expects the same high standards from all its contractors and suppliers; as part of its contracting processes, each supplier involved in Christian Louboutin’s supply chain are required to sign the Christian Louboutin Code of Business Ethics. Christian Louboutin has included specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and requires its raw-material and finished-goods suppliers and their own suppliers to hold the same high standards. In case of sub-contracting, Christian Louboutin requires prior approval of the sub-contracting partner and to ensure that their own suppliers adhere to the same obligations.

3.3.2. Supplier Auditing

Christian Louboutin continues to carry out audits by independent third-party organizations to evaluate compliance of its manufacturing and component suppliers with Christian Louboutin’s Code of Business Ethics and reserves the right to conduct compliance checks at any time without notice. In the event of a violation of the Code of Business Ethics and depending on the nature and gravity of the violation, Christian Louboutin reserves the right to terminate the relationship with the supplier or work with the supplier to implement corrective actions to any non-compliance.

3.3.2. Internal Trainings

Employee trainings have taken place within the company on the following topics:

• Health & Safety

In 2023, an obligatory internal training on health and safety were carried out within its production activities in Italy.

• CSR Iniatives

Since March 2022, Christian Louboutin has accelerated its Corporate Social Responsibility (CSR) initiatives with the arrival of a new Group CSR Director who is supported by nominated CSR ambassadors. The mission of these representatives is to contribute to the implementation of CSR within all levels and activities of Christian Louboutin.

In 2022, Christian Louboutin carried out a one-day training on CSR for all ambassadors.

In 2023 and 2024, the CSR ambassadors’ network will be extended to cover other international affiliates.

• Employee Code of Conduct

In 2024, all Christian Louboutin employees will be required to validate training on the Employee Code of Conduct which provides a specific chapter dedicated to the respect of human rights and its grievance mechanism.

Christian Louboutin employees are encouraged to raise concerns with their managers, their human resources department or the Compliance and Privacy Division about any issue or suspicion of modern slavery in any parts of our business or supply chain.

A new, group-wide SpeakUp procedure was put in place in the third quarter of 2023. Employees of Christian Louboutin and workers of suppliers may submit concerns via a confidential, secure channel put in place by the company to raise any concern, issue or suspicion of modern slavery in any part of Christian Louboutin business or related supply chain: https://cl-alert.integrityline.app/.

They may also write, in confidence, to the Compliance Manager at 19, rue Jean Jacques Rousseau Paris 75001 France.

Christian Louboutin aims at encouraging openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Christian Louboutin is committed to ensuring no one suffers from any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery, of any form, is or may be taking place in any part of its own business or its supply chain. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern.

Ultimate responsibility for the prevention of modern slavery rests with each of the company that approved this statement in relation to their own activity and their directors have overall responsibility for ensuring this policy and its implementation comply with their legal and ethical obligations.

Christian Louboutin’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter.

This statement will be communicated to Christian Louboutin employees in the USA and will form part of the induction training process for new employees.