Supply Chain Transparency
Supply Chain Transparency Disclosures
The California Transparency in Supply Chains Act of 2010 (SB 657) and the UK Modern Slavery Act require companies doing business in California and the UK, respectively, that meet certain criteria, to disclose information regarding their efforts to address slavery and human trafficking within their supply chain. KEEN, Inc. (“KEEN”), on behalf of itself and its subsidiaries, including KEEN Europe Outdoor B.V., follows the below procedures to uphold the highest ethical standards in our supply chain.
KEEN assesses the risks related to our supply chain at the country and factory levels. Risk assessment is performed by KEEN’s internal sourcing, corporate responsibility, and legal teams. KEEN works closely with our affiliated entities that conduct local sourcing and production activities, and we regularly visit our Tier 1 and Tier 2 suppliers. All Tier 1 manufacturers are pre-screened prior to producing KEEN products. Tier 1 suppliers manufacture products that they sell to KEEN. Tier 2 suppliers provide components or materials to Tier 1 suppliers.
KEEN operates under a Code of Conduct that is issued to each Tier 1 supplier and major Tier 2 supplier and must be posted on the production floor in the local language. KEEN conducts routine visits and audits, both announced and unannounced, to evaluate compliance with KEEN’s standards. Audits are performed by KEEN staff and KEEN affiliates. KEEN works with suppliers to remediate issues identified during audits.
KEEN’s Tier 1 suppliers sign a manufacturing agreement, which requires them to operate in full compliance with all laws applicable to their performance under the agreement, and explicitly prohibits forced or involuntary labor. Upon KEEN’s request, the supplier must provide written certification of compliance with the law and with KEEN’s Code of Conduct, as well as any additional information about the relevant goods.
In addition, KEEN requests that our Tier 1 and Tier 2 suppliers complete the Facility Module of the Sustainable Apparel Coalition’s Higg Index. By using this tool, KEEN gathers valuable information about the environmental conditions at each facility, including both our affiliate-owned facilities and contract manufacturing facilities.
KEEN maintains internal accountability procedures for employees and contractors regarding company standards on slavery and human trafficking. In the case of non-compliance, KEEN will examine the specific situation and develop a strategy for resolution. If cases of non-compliance are not resolved within a timely manner, KEEN may terminate the business relationship. KEEN has a dedicated corporate responsibility team and maintains a hotline that allows employees to anonymously report potential ethics violations.
KEEN expects key members of our supply chain management staff to be knowledgeable and aware of the risks and issues surrounding our supply chain, including concerns about slavery and human trafficking. KEEN also conducts supplier trainings to ensure that our suppliers understand our Code of Conduct and to set clear expectations around the treatment of workers, as well as their health and safety.
KEEN collaborates with a number of non-governmental organizations and trade associations to raise awareness of social compliance issues, including the Outdoor Industry Association (KEEN has been a member since 2008). KEEN regularly monitors reports and follows developments from leaders in the industry, such as the Footwear Distributors and Retailers of America and American Apparel and Footwear Association, specifically as they relate to slavery and human trafficking, among others.
Assessment of Effectiveness
KEEN measures our efforts to address slavery and human trafficking within our supply chain by monitoring the following metrics: (1) completion of visits to and audits of suppliers’ facilities by KEEN staff and staff of our affiliates; (2) each Tier 1 and major Tier 2 supplier’s posting of the KEEN Code of Conduct on the production floor in the local language and (3) results from our suppliers that complete the Sustainable Apparel Coalition’s Higg Index.
KEEN will continue to assess our business and supply chain to identify potential risks and implement appropriate safeguards against the mistreatment of persons within our business and supply chain.
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Last Modified: March 2021. This statement relates to the year ended December 31, 2020. View statement (pdf).