The California Transparency in Supply Chains Act of 2010 (SB 657)and the UK Modern Slavery Act require companiesdoing business in California and the UK, respectively, that meet certain criteria, to disclose information regarding theirefforts to address slavery and human trafficking within their supply chain. KEEN,Inc. (“KEEN”,on behalf of itself and itssubsidiaries, including KEEN Burope Outdoor BV, folows the below procedures to uphold the highest ethical standards in
our supply chain.
Verification
KEEN assesses the risks related to our supply chain at the country and factory levels. Risk assessment is performed byKEEN’s internal sourcing, corporate responsibility,and legalteams. KEEN works closely with our affiliated entities thatconduct local sourcing and production activities, and we regularly visit our Tier 1 and Tier 2 suppliers. All Tier 1manufacturers are pre-screened prior to producing KEEN products Tier1 suppliers manufacture products that they sell toKEEN. Tier 2 suppliers provide components or materials to Tier 1 suppliers.
Auditing
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 afiliates. KEEN works with
suppliers to remediate issues identified during audits.
Link to Code of Conduct HERE
Certification
KEEN’s Tier 1 suppliers sign a manufacturing agreement, which requires them to operate in full compliance with allaws
applicable to their performance under the agreement,and explicitly prohibits forced or involuntary labor. Upon KEEN’srequest, 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 too, KEEN gathers valuable information about the environmental conditions at each
facility, including both our affiliate-owned facilities and contract manufacturing facilities