# FITFLOP MODERN SLAVERY STATEMENT **Financial Year 2025-2026 (FY 25/26)** **Published \[September 2026\]**   ### 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 ninth 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 31^st March 2026. 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 2026, we have 252 direct employees across our own operations. We have 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. During FY25/26, the Company operated one retail store in New York, US. However, this store was closed prior to the end of the financial year.   ### 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. In the past year we have established a Sustainability Steering Committee with all Executive Leadership roles assigned an area of focus and priority actions identified. This Committee leads and delivers the sustainability strategy, including but not limited to reviewing FitFlop’s approach to managing modern slavery risks, ensuring appropriate policies, due diligence, and actions are in place and effectively implemented. We regularly keep updated with global ESG legislation through participation in industry forums, conferences and through work with specialist consultancy firms. 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 continue to focus on gaining a better understanding of our sample centres and lower tiers with a focus on material suppliers. 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 (and samples) from Tier 1 factories in Bangladesh, China, India, Indonesia, Taiwan 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 | 7 | | China | 3 | | Indonesia | 2 | | India | 1 | | Bangladesh | 1 |   #### Tier 2 Sites | Factory Country | No. of Sites | | --- | --- | | Vietnam | 17 | | China | 11 | | Indonesia | 1 | | 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. | Last year we developed an internal supplier responsible exit policy which is currently in draft format. This year we will move this to be a published policy. We will also identify additional policies that will help to support suppliers in attaining 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 material suppliers and 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 90% 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.     ### 4. DUE DILIGENCE ### Audits We work with specialist external auditors to carry out independent, third-party announced audits against FitFlop’s Code of Conduct, every two years at our Tier 1 and 2 sites. The Reassurance Network (TRN) acts as FitFlop’s external ethical assessment partner. They carry out factory audits after suppliers begin production, reviewing compliance with FitFlop’s Supplier Code of Conduct. TRN also identifies potential modern slavery risks and provides expert judgement on whether further investigation is required. Where risks are identified, they support deeper investigations and help develop remediation actions, working with local experts to protect workers and address root causes. During FY 25/26, we conducted 6 factory audits which covered 42% (by spend) of our finished goods business. 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 and material suppliers, 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. Once our Supplier Responsible Exit Policy is live, teams will be required to follow this process in such circumstances. To date, our due diligence and grievance mechanisms have not revealed any evidence\[KA1\]  of modern slavery within our operations or supply chains. However, we recognise that modern slavery risks can be hidden, particularly in lower tiers and among vulnerable worker groups, and we continue to strengthen our controls accordingly.   ### 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. ### Purchasing practices In addition to supplier and employee due diligence, we will commence a purchasing practices’ review and supplier survey to identify business behaviours that could unintentionally increase the risk of modern slavery within our supply chain. This includes assessing factors such as lead times, order planning, cost negotiations and changes to orders. We will aim to complete this by Q2 in FY26/27 and begin to implement relevant changes identified during the remainder of the year. ### 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 This year we also provided 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.  Key topics covered included: - Identification of “red flags” and indicators of forced labour and human rights abuses - Practical tools and techniques for risk screening in FitFlop supplier operations - Responsibilities of teams visiting or working with factories (e.g. identifying and escalating risks) - This year we also rolled out Anti‑Bribery training to support colleagues who visit our factories or work closely with suppliers. The training equipped colleagues with the confidence and capability to recognise and respond to bribery risks across different roles, locations, and jurisdictions. Key topics covered included:Identification of common bribery risks and scenarios within global and supplier-facing operations - Understanding relevant legal and regulatory requirements across different regions - Responsibilities of colleagues in preventing, identifying, and escalating potential bribery concerns when visiting or working with factories ### 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 previous financial year, we conducted a sustainability double materiality assessment and strategy review. The findings have now shaped our strategic direction, strengthening our modern slavery programme through enhanced activities and governance mechanisms developed as a result of this exercise e.g. our Sustainability Steering Committee. The table below provides an update on our progress and outlines our new commitments.   | | | --- |

Area	25/26 Commitments	25/26 Progress	26/27 Future Commitments
Structure, Business & Supply Chains	Finalise Tier 1 and Tier 2 supply chain mapping and begin deeper mapping of lower-tier suppliers.	Continued supply chain mapping as an ongoing process, with improved visibility of material suppliers and further mapping of Tier 3 sites. Established a Sustainability Steering Committee to support governance.	Leverage the new internal Materials team structure to increase visibility of Tier 4 material suppliers.
Policies and Contracts	Develop Supplier Responsible Exit Policy and conduct an annual ESG legislation review to inform policy development.	Supplier Responsible Exit Policy is in draft. While a formal ESG legislation review was not implemented, we continue to monitor global ESG developments through industry forums, conferences, and specialist consultancy support.	Publish Supplier Responsible Exit Policy. Continue reviewing and updating policies to  ensure they remain business appropriate and aligned with evolving legislation, with a particular focus on whistleblowing.
Risk Assessment	Conduct a comprehensive review and update of the new supplier onboarding process.	This activity was not completed during the reporting period due to other business priorities. This has been delayed to the following FY.	Review and update new supplier onboarding process - including both stock and non-stock. Begin auditing material suppliers to strengthen risk identification and assessment in lower tiers.
Due Diligence	Develop and implement a more comprehensive supplier SAQ to improve early visibility of human rights risks.	This activity was not completed during the reporting period due to other business priorities. This has been delayed to the following FY.	Develop comprehensive supplier SAQ. Undertake a purchasing practices' review and supplier survey, with the aim of identifying and embedding improvements over time, recognising this will be a longer-term initiative.
Training & Capacity Building	Roll out tools and training to colleagues visiting factories to support identification and escalation of modern slavery risks.	Delivered targeted training to relevant teams, maintained modern slavery e-learning as part of core onboarding, and rolled out anti-bribery training.	Review the effectiveness of the e-learning module and update it as needed to ensure it remains fit for purpose.

### APPROVAL OF THIS STATEMENT

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