At Kenneth Cole Productions (“KCP”), we take supply chain responsibilities very seriously. We are committed to conducting business in an ethical, lawful, and responsible manner. Furthermore, we seek out suppliers that share our commitment and incorporate responsible practices in their operations. Therefore, we evaluate our suppliers (including analyzing the countries where they operate) to address risks of human trafficking and slavery.

KCP’s Business Partner Terms of Engagement apply to all of our suppliers. The Business Partner Terms of Engagement prohibit forced and involuntary labor of any kind, including the use of child, prison, indentured, bonded or forced labor. Every supplier producing goods for our brands must review, sign, and abide by our Business Partner Terms of Engagement. In addition to providing guidance on a range of issues important to KCP, we require every supplier to certify that its employment practices are in compliance with all applicable laws, including those in the countries where it operates.

KCP engages third-party inspectors to conduct both announced and unannounced periodic audits of supplier manufacturing facilities to evaluate compliance with all applicable laws and with our Business Partner Terms of Engagement. The inspectors provide reports on each factory visit, detailing any deficiencies they find, and provide corrective action plans with timelines to address deficiencies as appropriate. After a corrective action plan is issued, KCP monitors the supplier’s progress until it meets KCP’s standards. KCP will also ask the independent monitors to visit facilities again to verify that all concerns have been addressed properly. If a supplier cannot meet KCP’s standards within a reasonable period of time, KCP will cease business operations with the supplier.

In addition to independent monitors, KCP employees responsible for factories in our supply chains are also required to complete training to aid them in identifying and addressing human rights issues, including forced labor. Our employees visit factories regularly and address any concerns they have with factory managers and owners. Any employee who fails to meet our standards regarding slavery and trafficking will be held accountable, including being terminated. We are committed to doing business only with those partners who share our ethical standards and put these standards into practice in their business operations.