Click here to view the Code of Conduct adopted by Fendi, the principles and rules of which inspire us in our daily activities
FENDI UK Ltd.
Modern Slavery Act 2015 – Year 2023 Statement
Introduction
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “MSA”) on behalf of Fendi U.K. Limited (“Fendi UK”) and sets out the steps Fendi UK has taken during its financial year ending 31 December 2023 to ensure that slavery, servitude, forced or compulsory labour, and human trafficking (collectively, "Modern Slavery") is not taking place in any part of its business or in its supply chains.
Business
Fendi UK is a subsidiary of Fendi Srl (hereinafter also referred as “FENDI”), which is part of the LVMH Moët Hennessy Louis-Vuitton SE (“LVMH”) Group (“LVMH Group”). References in this statement to “Fendi UK”, “FENDI”, “LVMH”, “LVMH Group”, “we,” “us,” or “our,” are to these named entities.
Fendi UK sells luxury and high-quality products under FENDI trademarks as leather goods, bags, ready-to wear, shoes, accessories (the “Products”), to clients in the United Kingdom.
Fendi UK purchases the Products from its controlling entity, FENDI, which are mainly manufactured in Italy, and purchases directly from local suppliers’ products and services necessary to run its business.
FENDI’s Supply Chain is founded on the long-lasting collaboration with a large number of small suppliers, mostly located in Italy, on which FENDI can rely on to deliver high level of artisanship and craftsmanship.
Further information on our Supply Chain is available on FENDI’s website, sustainability section, at https://www.fendi.com/sustainability/.
Policies and Practices
FENDI’s commitment is to act with integrity in all its business dealings and to promote ethical conduct, to enhance compliance with applicable laws and to provide guidance with respect to business conduct. It has a number of policies that are relevant to this commitment, which set out what FENDI expects from its employees, its subsidiaries and its external suppliers.
Our policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Key Policies are:
1. LVMH Suppliers' Code of Conduct ("Suppliers' Code of Conduct")
FENDI requires its suppliers, their suppliers and contractors, to commit (as a minimum) with same LVMH Group values and to act in full compliance with the relevant laws, including all national, local and international laws relating to the management of their businesses.
FENDI requires its suppliers to seek approval before subcontracting any part of their supply chain process and FENDI’s approval is subject to acceptance by the subcontractor of the Suppliers' Code of Conduct and all other applicable conditions that FENDI determines.
The Suppliers’ Code of Conduct is available at the following Link.
2. LVMH Code of Conduct
The LVMH Code of Conduct states the commitment of each of the LVMH Group companies to act to the highest standards of integrity, social and environment responsibility in their behaviours and in the way that they conduct business every day, everywhere. This code further states that the LVMH Group companies, including FENDI, will inform all its commercial partners of its ethical principles and expectations and will ask them to comply with the principles set out in the Suppliers' Code of Conduct. In particular, this code specifies compliance with social issues under the following relevant sections "Implementing and promoting a responsible approach" and "Acting as a socially aware company" in particular when it comes to respecting and supporting human rights.
New employees are required to acknowledge the LVMH Code of Conduct upon joining Fendi UK as part of the onboarding program.
The LVMH Code of Conduct is available at the following Link.
3. FENDI Organizational, Management & Control Model
The Italian Legislative Decree No. 231/2001 has introduced the administrative liability of entities with respect to certain types of criminal offences perpetrated in their interest or to their advantage by executives of persons under their management or supervision. To ensure that the criminal offences under the Legislative Decree No. 231/2001 are prevented, FENDI has adopted the Organizational, Management & Control Model (the “Model”) and has appointed a Supervisory Board, overseeing the functioning and the observance of the Model.
The offence of placing or holding any person in conditions of slavery or servitude as well as the offence of illicit intermediation and labour exploitation are included among the criminal offences considered by Legislative Decree No. 231/2001 and therefore addressed in the Model.
4. Procurement Policy
FENDI’s Procurement Policy, applicable at worldwide level, sets out the rules to be followed in the selection of suppliers in accordance with applicable laws and regulations.
Both documents mentioned under points 1 and 2 above are available on FENDI’s website. The Model is available on FENDI’s website.
5. Supplier Due Diligence
Prior to engaging into any new contractual relationship with a supplier, FENDI requires suppliers to sign and acknowledge the Suppliers’ Code of Conduct through its vendor onboarding system. They must also ensure that their own subcontractors and suppliers, when approved by FENDI, do the same when performing their activities for FENDI.
FENDI reserves (and systematically exercises) the right to check its new and existing suppliers’ adherence to the principles set out in the Suppliers' Code of Conduct and to conduct compliance audits at any time. FENDI’s suppliers shall supply the necessary information and grant access to FENDI’s representatives to verify compliance with the requirements of the Suppliers’ Code of Conduct. Suppliers shall further keep proper and complete records to prove compliance with the Suppliers’ Code of Conduct and further provide access to complete, original, and accurate files to FENDI representatives.
FENDI’s expectation is that each supplier swiftly corrects any non-compliance discovered during any such audits. Lack of doing so or possible not curable non-compliances will result in relationship termination.
FENDI imposes obligations in certain supplier contracts under which the supplier undertakes to comply with the Suppliers’ Code of Conduct (this applies to all suppliers) and an anti-modern slavery commitment. Under such terms the supplier also agrees to grant FENDI audit rights to check compliance with the Suppliers’ Code of Conduct,
At the date, FENDI continues to publish (and to keep updated) on its website an entire page entirely dedicated to the currently adopted sustainability practices and which provides transparent information on its supply chain.
FENDI has a compliance team who is actively working on ensuring that slavery and human trafficking do not take place in its business and supply chains.
In addition to the WW Compliance Manager, such team consists of representatives from departments across the organisation including members of Legal, Internal Control, Procurement, Industrial, Supply Chain & Logistics teams.
Investigation Process
LVMH and FENDI have well-established processes for the global reporting of compliance incidents and apply a zero-tolerance approach in relation to human rights violations. When identified, those incidents, which could include suspicions of human rights violations, are investigated, sanctioned when appropriate and relevant follow-up actions are taken. If those incidents involve a third party, full cooperation of that third party is expected in the investigation and any follow-up actions (e.g. access to relevant information, adoption of remedial actions when appropriate etc.).
Training and Awareness
FENDI, to ensure a high level of understanding of the risks of modern slavery and human trafficking in its supply chains, conducts regular training (both in person and from remote) for its employees to ensure compliance with legal requirements across the group. Examples include, but are not limited to, training relating to the Model and corporate liability law, Anti-Corruption and Competition Law.
The training enables FENDI to reduce the risk of non-compliance through efficient processes and reliable data and reporting. All documentation, policies, learning material and resources are provided for and are easily accessible to all employees via the company’s intranet.
It is mandatory for all FENDI and Fendi UK employees to familiarise themselves with this statement and it will form part of the induction process for new employees.
All FENDI’s employees have access to the LVMH Alert Line which represents a grievance mechanism to anonymously report, any breach of the Code of Conduct or internal policies. FENDI issues regular communications to employees about this whistleblowing system, notably when onboarding new employees. Employees are informed in particular about how they can access the system.
The access to LVMH Alert Line has been extended (since the end of 2020) to third parties, including partners and suppliers working with LVMH Maisons, including FENDI.
Retaliation is prohibited against whistleblowers who report in good faith (and anyone who helps them or is connected to them), even if the reported allegations turn out to be inaccurate.
Following a review of the effectiveness of the steps we have taken this year to ensure that here is no slavery or human trafficking in our supply chains, FENDI’s commitment to prevent slavery, servitude and any other form of modern slavery in its supply chain is an ongoing process and the steps taken so far are part of a long-term commitment to uncover, tackle and prevent the issue of forced labour.
During the financial year, FENDI and Fendi UK did not receive through the LVMH Alert Line System any report of suspected modern slavery or human trafficking relating to its UK business or supply chain.
This statement is made pursuant to Section 54 of the MSA and constitutes Fendi UK’s Modern Slavery Statement for the financial year ending 31 December 2023. Fendi UK will ensure that this statement is reviewed and updated on an annual basis.
The Board of Directors of Fendi UK has approved this statement and it has been duly signed by the following director:
Enrico Sorenti, Managing Director
Fendi U.K. Limited