MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2020
Samsonite International S.A. (the "Company"), together with our consolidated subsidiaries (the "Group"), is the world's best-known and largest lifestyle bag and travel luggage company, with a heritage dating back over 110 years. We are committed to conducting business in a way that is consistent with our traditional values – acting responsibly, honestly and ethically at all times and complying with the laws of the various countries where we do business.
This statement is made pursuant to Section 54 of the UK Modern Slavery Act of 2015 and the California Transparency in Supply Chains Act of 2010 (SB 657) and constitutes the Group's modern slavery statement for the financial year ended December 31, 2020.
This statement sets out the steps we are taking to identify and mitigate risks of modern slavery in our business operations and supply chains.
Business Structure, Activities & Supply Chain
The Group is principally engaged in the design, manufacture, sourcing and distribution of luggage, business and computer bags, women’s bags, outdoor and casual bags, travel accessories and slim protective cases for personal electronic devices throughout the world. We sell our products primarily under the Samsonite®, Tumi®, American Tourister®, Speck®, High Sierra®, Gregory®, Lipault®, Kamiliant®, Hartmann® and ebags® brand names, as well as under other owned and licensed brand names.
As of December 31, 2020, the Group's products were sold in more than 100 countries.
The Company operates using a primarily decentralized structure across four key regions: Asia, Europe, Latin America and North America. We sell our products through a variety of wholesale distribution channels, through company-operated retail stores, and through e-commerce. Our principal wholesale distribution customers are department and specialty retail stores, mass merchants, catalog showrooms, and warehouse clubs.
The Company owns and operates manufacturing facilities in Oudenaarde, Belgium; Szekszárd, Hungary; Nashik, India; and, Cuautitlán Izcalli, Mexico. The remainder of our products are manufactured by independently owned and operated facilities. Most of the Company's third- party manufacturers are located in Asia, including Taiwan, China, Cambodia, Vietnam and Thailand.
To find out more about our company, please see: http://www.samsonite.com/investors
Modern slavery in any of its forms – whether as forced, bonded, or compulsory labor, or as human trafficking – represents some of the gravest forms of human rights abuse. The Group has a zero-tolerance approach to these illegal activities.
We are committed to maintaining systems that are designed to reduce the possibility of modern slavery occurring in our operations and supply chain.
We uphold this commitment through our policies: our Employee Code of Conduct, Samsonite Ethical Charter and Tumi Standards of Engagement, in addition to our governance process which is supported by our leadership team.
The Company's employee Code of Conduct is mandatory and extends to every person working at the Group. Included in it is the Company's corporate commitment to legal compliance, ethical behavior, and support for labor standards enshrined by the International Labor Organization (ILO). The Code of Conduct acknowledges the Company's support for the ILO's central tenant: that people throughout the world should be able to undertake decent and productive work in conditions of freedom, equality, security and human dignity. The Company's policies explicitly include a prohibition on the use of forced or other compulsory labor across our business, as well as our supply chain. Employees who fail to abide by the Group's policies are subject to discipline and dismissal, if warranted.
We work to ensure that our global supply chain partners follow socially responsible and ethically acceptable practices. The Samsonite Ethical Charter guides our approach to minimum standards in the supply chain. Samsonite requires all suppliers and their subcontractors to accept this commitment. The first clause of this charter states that:
“The use of forced labor is forbidden, and employees shall not be kept in locked premises nor shall their freedom be restricted in any other way. No compulsory deposits of money or identity cards etc. shall be demanded from employees as security against work, and they shall be free to resign their employment within a reasonable term. (ILO Conventions 29 and 105)”
In the case of the Company’s TUMI brand, a suppliers’ code of conduct, known as the Standards of Engagement, is in effect for its supply chain partners.
Collectively, these standards set forth the vision for acceptable business practices related to workers’ rights, working conditions, terms of employment, decent work, supplier systems, and worker protections. They are consistent with the ILO covenants, such as prohibitions against forced labor and child labor. The Company uses these standards as an integral component of our sourcing strategies, including how we evaluate supplier performance, and determine with which factories we will continue to engage and grow our business.
Due Diligence Processes & Risk Management
The Group does not support or knowingly maintain relationships with any business involved or connected in any way with modern slavery. Nevertheless, the Group understands that the greatest risk of modern slavery is in our product supply chain; as such, we have undertaken activities to identify and minimize those risks with our direct and indirect final assembly suppliers, and with raw material or component suppliers with whom we have a direct contract.
The Company conducts due diligence checks of new and existing suppliers with whom we have a direct contractual relationship in the form of either self-assessment questionnaires or a compliance audit conducted by or on behalf of the Company. If evidence of modern slavery is found, the Group will examine the circumstances and develop the best possible strategy for resolution. The Group may act against those suppliers that do not demonstrate sufficient commitment to the supplier codes of conduct or are in breach of it; subsequent actions can include terminating the supplier.
The Group seeks to ensure that all new and existing third-party suppliers with whom we contract abide by the Company’s policies. Supply contracts require compliance, and the Group’s social compliance audit personnel visit suppliers on a regular basis and audit their compliance. Failure to remedy violations of the policy may result in termination of the relationship with the supplier. Monitoring and verification activities are carried out by a team of trained professionals based in China and in India.
135 audits were conducted in 2020 compared to 314 in 2019. The reduction in the number of audits was due to reduced production activity corresponding to reduced consumer demand as a result of the Covid-19 pandemic.
For more information, please refer to the Company’s 2020 ESG Report. https://corporate.samsonite.com/en/reports-policies.html
The Company's employees are introduced to the Code of Conduct during their induction orientation. We educate our suppliers about the prohibition on human trafficking, child labor, and other violations of our standards through the process of requiring adherence to the Code of Conduct and through our on-site monitoring and verification processes.
Grievance Mechanisms and Remedy
The Group maintains and enforces internal accountability procedures for employees and suppliers who fail to meet our standards to prevent the incidence of modern-day slavery in our operations and/or supply chain.
We provide the opportunity for everyone who works in the Group to report suspected breaches of the Employee Code of Conduct, including via an anonymous confidential hotline and website reporting service. Members of the Group's management team in the finance, legal, human resources and internal audit departments review any information that is submitted via the hotline. The hotline is available toll-free and is publicized to employees electronically, in our Code of Conduct, and through posters and in worker handbooks throughout our operations.
Employees may use this hotline, anonymously if desired, if they have any workplace concern that they wish to report. Employees using the hotline are protected against retaliation. Reports are investigated and appropriate remedial actions taken as needed.
Evaluation of the effectiveness of our efforts to ensure that no human trafficking or modern slavery is present in the Company or in our supply chain rests with the country and regional management for employees, and with sourcing and production staff in the supply chain; this process is reviewed periodically by the internal audit team.
We know that our work to ensure we are appropriately tackling the issue of modern slavery requires our ongoing commitment. We are committed to playing our part to identify and tackle issues of modern slavery that touch our business.
Approved by the Board on March 17, 2021.
Signed on behalf of the Board of SAMSONITE INTERNATIONAL S.A.
Kyle Francis Gendreau Chief Executive Officer