FITFLOP MODERN SLAVERY STATEMENT

Financial Year 2024-2025 (FY 24/25)

 

INTRODUCTION

Modern slavery and human trafficking are grave violations of human rights. FitFlop Limited (“FitFlop”) does not tolerate modern slavery in any form in our business or supply chain.

 

Our eighth Modern Slavery Statement complies with the UK Modern Slavery Act 2015 and the California Transparency in Supply Chains Act 2010 and relates to the financial year ending 31st March 2025. It describes the actions we have taken during the past year, and our ongoing efforts to identify and prevent modern slavery and human trafficking in our organisation and supply chain.

 

1. OUR BUSINESS & SUPPLY CHAIN

 

OUR BUSINESS

FitFlop is a global, multi-channel brand providing footwear to customers in more than 60 countries. Business activities include the design, development, sourcing, manufacture, transport and sale of products. FitFlop UK acts as a holding company for subsidiary undertakings in the US, India and Germany, with our headquarters in London, UK and operational offices in Hong Kong, China and Ho Chi Minh City, Vietnam . We use third-party warehouses located in Rugby, UK and Columbus, Ohio, US.

 

As of 31st March 2025, we have 259 direct employees across our own operations. We have one retail store and a showroom in New York, US and a showroom in London, UK. We deliver our products worldwide through our four e-commerce sites in Canada, the EU, UK and US, and a network of distributors, wholesalers and retailers.

 

GOVERNANCE

FitFlop’s CEO holds ultimate accountability for human rights within the business, supported by the Executive Leadership Team. Our Sustainability, Legal, Supply Chain, Operations and People teams develop and implement our modern slavery prevention programme.

 

We are currently working on implementing a thorough review of relevant global ESG legislation at least annually, starting June 2025. This proactive approach aims to keep us informed about existing and upcoming laws and ensure our systems are robust enough to maintain compliance with human rights and modern slavery legislation.

 

OUR SUPPLY CHAIN

We divide our suppliers into stock and non-stock suppliers. We classify our stock suppliers under one of four tiers:

Tier 1: Finished goods suppliers, Sampling centres

Tier 2: Branded component suppliers, Sub-cons, Midsoles, Footbeds, Specialised Uppers

Tier 3: Unbranded components, Printing

Tier 4: Raw material production, Leather tannery & Finishing

 

We have mapped the majority of our tier 1 and 2 sites. Over the coming year we will focus on gaining a better understanding of our sample centres and lower tiers.

 

We undertake the design and development of our products but outsource stock manufacturing to third-party factories where the production sites are often shared with other brands. We source finished footwear from Tier 1 factories in Bangladesh, China, India, Indonesia, Thailand and Vietnam. We also work directly with several Tier 2 component and material suppliers located in China, India, Indonesia and Vietnam.

 

Tier 1 Sites

Factory Country	No. of Sites
Vietnam	8
China	5
Indonesia	2
India	1
Bangladesh	1

 

Tier 2 Sites

Factory Country	No. of Sites
Vietnam	14
China	2
Indonesia	2
India	1

 

In addition, we carry out product testing and development work in Canada, China, India, Indonesia, Vietnam and the UK. FitFlop has built these relationships over many years in most cases .

 

Through our non-stock suppliers, we source a range of goods not for resale and services which support our business operations, such as printing, packaging, labelling, office cleaning, recruitment, warehousing, logistics, transport and shipping.

 

2. OUR POLICIES

Code of Conduct for Suppliers and Distributors

 

We require all material product, materials and service suppliers, and all distributors and franchisees as part of their FitFlop contract, to sign our Code of Conduct, which is based on national legislation, the Ethical Trading Initiative Base Code (ETI), International Labour Organisation (ILO) Conventions and industry standards. We also include contractual provisions that help us implement and enforce our modern slavery controls regarding auditing, access to wage and working hour records, treatment of workers, anti-bribery and compliance with laws.

 

FitFlop Code of Conduct Clauses

Code of Conduct Clause	Description
Compliance with Laws	Obligations to meet all legal requirements and regulations and operate in a manner that is consistent with the same. This section further stipulates the requirement of informing all local labourers and workers about the local labour law.
Health & Safety and Training	Ensure safe and fair working environments and practices and providing adequate training within the supply chain.
Forced Labour	Ensure forced labour (or similar practices) are not taking place.
Non-Discrimination	Ensure that no workers are discriminated against (on any grounds whatsoever).
Harassment & Abuse	Ensure that workers are protected in the workplace and are not subject to any form of bullying, harassment or abuse.
Freedom of Association & Collective Bargaining	The right of workers to join (or not to join) and organise associations of their own choosing and to bargain collectively.
Minimum Wage & Working Hours	Paying workers at least the legal minimum wage and setting working hours that are within the remit of local laws and benchmark industry standards.
Child Labour & Young Workers	Ensure children are not working within the supply chain and that young workers are adequately protected at work.
Anti-Bribery & Corruption	Give guidance on countering bribery and corruption and to assist in complying with the Bribery Act 2010.

 

Over the coming year, we plan to develop an internal supplier responsible exit policy. We will also identify additional policies that will support suppliers in reaching higher human rights standards.

 

Employees

 

We have the following key human rights policies in place to protect our employees throughout their time working for FitFlop:

Anti-Bribery Policy

Anti-Harassment and Bullying Policy

Disciplinary Procedure

Equality, Diversity and Inclusion Policy

Equal Opportunities Policy

Grievance Policy

Health & Safety Policy

Pay Policy

Whistleblowing Policy

 

We train our new employees during their induction on how to access these policies through our internal folders.

 

3. RISK ASSESSMENT

 

The Sustainability, Legal, Operations and People teams are responsible for carrying out human rights risk assessments. These assessments involve desk research, analysis of third-party ethical audits, our own audits against FitFlop’s Code of Conduct, interviews with workers, site visits by our internal teams and consultations with human rights experts . When assigning risk, we consider the following factors: product and service type, geographical location, worker type, including vulnerable worker groups, high risk labour practices, such as excessive working hours, and the likelihood of involvement of recruitment and labour agencies and intermediaries.   We have determined the primary risk for our business due to the risk factors above is our product supply chain located in Asia-Pacific countries. Within the next two years, we will also focus on agency workers within our warehouses, who can face increased human rights risks due to the nature of their employment.   Within our own operations we assess the risk of modern slavery to be minimal, as 92% of our employees are on permanent contracts.   Every Tier 1 and Tier 2 factory is expected to meet our bi-annual audit requirements, and we grade these audits depending on the issues found.   Our risk assessment process is dynamic and evolves as the risk landscape changes. Our yearly ESG legislation review will further inform this process.

 

4. DUE DILIGENCE

 

Audits

We work with specialist external auditors to carry out independent, third-party announced audits against either FitFlop’s Code of Conduct or SMETA (SEDEX Members Ethical Trade Audit) methodology, every two years at our Tier 1 and 2 sites.   During FY 24/25, we conducted 17 factory audits. All our partners are provided with an approved corrective action plan that is closely monitored and supported by our teams, who work with the facilities on a continuous improvement plan.   Within the next two years, we will also look to incorporate higher risk non-stock suppliers, such as our warehouses , into our due diligence programme.

 

Remediation

We analyse the outcome of audits and decide what action, if any, needs to be taken, including providing advice to factories through our third-party auditors and our internal teams who regularly visit all our factories. We assign audit risk ratings for all Tier 1 and Tier 2 factories to inform prioritisation and remediation. We are committed to working with agents, suppliers and factories to help them improve over time. If there are repeated serious violations or if a supplier or site is unwilling to make necessary improvements, FitFlop may decide to terminate the relationship. Over the next year, we will create guidelines to outline the process for responsibly exiting partnerships with sites.   To date, our due diligence and grievance mechanisms have not revealed any evidence of modern slavery within our operations or supply chains.

 

Employees

We manage our recruitment and selection through in-house recruiters and a small number of vetted recruitment agents. These agents are chosen for their reputation, expertise, quality of service and commitment to ethical practices, ensuring fairness and preventing discrimination in the hiring process. As part of our recruitment process, we undertake checks on all workers to verify their identity, age and eligibility to work in that country.

 

5. TRAINING & CAPACITY BUILDING

 

Employee Modern Slavery Training

Employees are required to complete our e-learning modern slavery awareness training module. Content includes:

• Understanding the definition of modern slavery and human trafficking, and the relevant legislative frameworks surrounding them.
• Being able to identify warning signs of modern slavery and human trafficking.
• What action should be taken if modern slavery is suspected and how to report it to relevant authorities.

 

We also began to investigate additional training and tools for colleagues visiting factories to help them identify and report internally any potential modern slavery indicators as well as high risk health and safety issues. We plan to roll out these tools and training during the coming year.

 

6.EFFECTIVENESS OF OUR APPROACH & FUTURE GOALS

 

Reporting on Progress Made & Our Future Areas Of Focus

We aim to continuously improve our efforts to identify, prevent and mitigate human rights risks. In the latter part of the year, we conducted a sustainability double materiality assessment and strategy review. The findings from these will be used to enhance our modern slavery prevention programme, policies and procedures.   The table below provides an update on our progress and outlines our new commitments.

 

Area	24/25 Commitments	24/25 Progress	25/26 Future Commitments
Structure, Business & Supply Chains	We planned to continue to monitor supply chain information and ensure that it is regularly updated. We planned to continue to dig into our supply chain so we gained more visibility into our lower tiers.	We continued to monitor, map and update tier 1 & 2 supplier information. We determined new tier definitions.	We will finalise tier 1 & 2 supply chain mapping and start to dig more into our lower tiers.
Policies & Contracts	We planned to continue to review our suite of policies to ensure they are fit for purpose and brought up to date with relevant legislation.	We carried out a double materiality assessment and strategy review. The findings of which will help us to improve our policies.	We will create Supplier Responsible Exit Guidelines and carry out an ESG legislation review at least annually to help inform policy development.
Risk Assessment	We planned to continue to review our existing supply chains, evaluating all existing and potential suppliers. We also planned to strengthen our new supplier onboarding process.	We made some changes to strengthen our onboarding process. We also ensured we had audits for all Tier 1 factories.	We will carry out a comprehensive review and update of our new supplier onboarding process.
Due Diligence	We planned to continue with our audit cycle but also to trial a new provider of this service to compare our current approach.	We trialled and fully onboarded another third-party audit provider who specialise in deep dive audits and remediation.	We will develop and roll out a new, more comprehensive supplier SAQ to enable us to gain better insight into a supplier's human rights performance from the outset.
Training & Capacity Building	We planned to conduct training on modern slavery awareness, and introduce e-learning modules for all employees to be aware of modern slavery indicators and risks. We also planned to investigate training for in-factory colleagues to be aware of risks in production facilities with the intention of rolling this out in the following financial year.	We delivered e-learning training for employees on modern slavery. We established a partnership with a human rights consultancy to develop modern slavery tools and training for colleagues visiting factories.	We will roll out tools and training to colleagues visiting factories to help them identify modern slavery risks and understand how to flag concerns.

APPROVAL OF THIS STATEMENT

FitFlop’s previous Modern Slavery Statements can be found here.