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MODERNSLAVERY
AND TRANSPARENCY IN THE
SUPPLY CHAIN STATEMENT

2022/23

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTINTRODUCTION

PG2Modern slavery is an umbrella term which covers a range of coercive labour practices, including
forced and compulsory labour, bonded labour, child labour and human trafficking. It is when aperson loses their freedom and is exploited for the personal or commercial gain of another personwith threat of punishment or penalty. It is a global issue which occurs in almost all countries.
Modern slavery has grown in recent years. The latest estimates show that
globally there are almost 50 million victims each day . This works out tonearly one in every 150 people in the world. Crises such as the Covid-19
pandemic, armed conflict and climate change have disrupted employment
and education globally, increased cases of extreme poverty and forced
migration, which all lead to the increased risk of all forms of modern slavery.
Integrity is at the heart of what we do and how we show up at Dr. Martens.
We expect high standards of each other and our supply partners. As aresult, we will never accept modern slavery in any form and we take our
responsibility seriously. As a global business we accept the responsibility
we have to drive change and transparency.
This is our sixth Modern Slavery Statement and each year we are committed
to outlining our approach to prevent, detect and respond to slavery throughsupply chain traceability, education and collaboration.
This statement covers Dr. Martens plc and other Group companies which are in scope (and together
are referred to as “Dr. Martens”) and is made pursuant to section 54 of the Modern Slavery Act 2015,
California Transparency in Supply Chains Act of 2010 (SB 657) and Canada’s Fighting Against Forced
Labour and Child Labour in Supply Chains Act, SC 2023 (authorized in accordance with subsection 14(4)(b)(ii)). This statement relates to the Dr. Martens fiscal year from 1 April 2022 to 31 March 2023.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTSTRUCTURE, BUSINESS, AND SUPPLY CHAINS
WHO WE ARE:

Our products are sold through the following global revenue
channels:

FY23

60

PAIRS SOLD
THIS YEAR

2,591
EMPLOYEES+ Direct-to-consumer (DTC):SOLD IN
MORE THAN

13.8M
FTE,
FY23

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• Ecommerce: Our consumer websites cover the majority of our markets. In FY23,
ecommerce generated 28% of revenue.

COUNTRIES

FY23

£1BN
+ BUSINESSREVENUE

FY23

10M+ SOCIALMEDIA
FOLLOWERS

Dr. Martens is an iconic British brand founded in 1960 in Northamptonshire.
Originally produced for workers looking for tough, durable boots, the brand wasquickly adopted by diverse youth subcultures and associated musical movements.
Dr. Martens has since transcended its working-class roots while still celebrating its
proud heritage and, six decades later, “Docs” or “DMs” are worn by people aroundthe world who use them as a symbol of empowerment and their own individual
attitude.
The Company listed successfully on the main market of the London Stock Exchange
on 29 January 2021 (DOCS.L) and is a constituent of the FTSE 250 index.
Our product range includes footwear categories comprised of Originals, Fusion,
Kids and Casual, as well as a complementary range of Accessories. Our Originals
category accounted for 46% of FY23 total revenue. We create durable, high quality
and timeless footwear, and these principles are rooted in our sustainable, long-term
custodian approach. Our products are worn by a diverse consumer base who use
Dr. Martens boots and shoes as a symbol of their individual self-expression.
1
International Labour Organization (ILO), Walk Free, and International Organization for Migration (IOM)
Global Estimates of Modern Slavery, Forced Labour and Forced Marriage

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT• Retail: We operate 204 own stores globally (88 in EMEA, 54 in America, and 62 in APAC)
and they provide the opportunity to showcase our brand and products in the best possible
physical environment.
+ Wholesale: This encompasses wholesale partner relationships, together with country
distributor models and franchised stores, enabling us to reach more consumers and further
grow brand awareness.

We employ 2,591 people (FTE) who are based in our stores, offices, factories anddistribution facilities all around the world. Our priority is to provide fair and safe
working conditions for all of our employees, and to foster an environment where
everyone feels supported, included and empowered to express themselves.

WHERE WE OPERATE:

We are a global business and operate a regional model:
EMEA

Headquartered in Camden, London, andwith offices in Milan, Barcelona, Parisand Düsseldorf.

APAC£129.1M
EMEA£443M

AMERICAS

Headquartered in Portland, Oregon, with
offices in New York and Los Angeles.

APAC

Headquartered in Hong Kong with regional
offices in Tokyo, Shanghai and Seoul. Japan,
China and South Korea are directly operated,
and there are a number of distributors for otherkey countries with Australia being the largest.

AMERICAS£428.2M*Group’s revenue per region(Twelve months ended 31 March 2023)

OUR PRODUCT GLOBAL SUPPLY CHAIN:

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We define our global supply chain tiers in the following way:
+ TIER 1 SUPPLIER: A supplier which manufactures or assembles finished products.
+KEY TIER 2: A supplier that produces a strategic component (e.g. tanneries, or outsole suppliers).
+ TIER 2: A supplier that produces other components.

DISTRIBUTION:

The majority of our products are manufactured byour global network of Tier 1 suppliers located acrossAsia and Europe. We have one Dr. Martens-owned
manufacturing site in the UK which produces Madein England and collaboration products. We havevisibility of all our Tier 1 suppliers.

TIER 1:
When partnering with Tier 1 suppliers, we value
strong longstanding relationships and have worked
with many of our supply chain partners for decades.
We also nominate a number of our Tier 2 suppliers
including tanneries and outsole suppliers. At FY23
year end, we had 17 Tier 1 footwear supplier factories
and 8 Tier 1 accessory suppliers. Currently, our Tier
1 suppliers are located in the UK, Vietnam, Thailand,Laos, China, Portugal and Taiwan. Our Tier 1 factory
list is shared on our website which we update every
six months.
We hold regular supplier conferences which areattended by our Tier 1 suppliers and hosted by our
Chief Operating Officer. These conferences promote
an environment of trust and transparency, whilst
allowing us to build a deeper understanding of theissues faced by our suppliers. We address CSR topics
including the expectation of high social and labour
standards at these conferences.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTTIER 2 SUPPLIERS:
In addition to Tier 1 suppliers, we work directly with
Key Tier 2 suppliers for components including leather
and outsole granulate material. We have visibilityof all key component suppliers. We provide a list of
nominated Tier 2 suppliers for certain components
which the Tier 1 suppliers are required to source from.
We shortlist preferred Tier 2 suppliers through an audit
process; the criteria for which includes conformity with
our Supplier Code of Conduct as well as adherence
to product quality and compliance standards,
including in connection with modern slavery laws andregulations. We monitor this nominated Tier 2 supplier
list on an ongoing seasonal basis. Our top materials
sourced by volume are leather, outsole PVC granulate
and packaging materials.

We operate with one Group owned and operated
distribution centre (DC) in the UK and nine third-party
DCs across EMEA, America and APAC. During FY23,
due to issues transitioning to a new third-party DC in
LA, we used temporary satellite warehousing sites tosort and store product. DC activities include receiving
finished goods from our third-party manufacturers andMade in England factory, inspecting and processing
those products (including returns), and shipping themto our customers and to our own stores. Temporary
employees in our distribution facilities are hired bylabour providers. In the distribution centre we directly
operate, we work with trusted labour agents for the
recruitment of temporary employees for peak trading
periods. We aim to only offer full time positions totemporary staff, unless the role requires particularexperience, or is a managerial position.

NON-PRODUCTSUPPLIERS:
We also work with non-product third-party suppliers
that support our wider business. These include
suppliers such as goods not for resale, service
providers, consultants and tech providers. All new
suppliers, product and non-product, must go throughour Third Party Due Diligence Process which you canfind out more about on page 8.

STRATEGY AND GOVERNANCE:
T

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PLANET

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&I

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Our Planet, Product, People sustainability strategy covers environmental andsocial aspects. It captures eight key areas based on the material issues identified
through an in-depth materiality assessment. Human Rights is a key focus area forthe business and is included within the People pillar of the strategy. Sustainability
projects are also included in the DOCS strategy to ensure that sustainability
becomes an operational requirement for all functions delivering our sustainability
commitments. For additional information on our sustainability strategy please see
our Annual Report.

E

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HUMAN RIGHTS IS A KEY FOCUS
AREA OF OUR SUSTAINABILITYSTRATEGY:

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COMMU

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product
CYC

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people

KA

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HUM
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GOVERNANCE:The Board is responsible for the oversight and integration of ESG-related activities
across the business. The Chief Operating Officer (COO) is accountable for supply
chain human rights and the Chief People and Sustainability Officer (CPSO) is
accountable for human rights across our own operations.
CSR Team: Ethical trade and human rights due diligence in the supply chain falls
within the remit of the dedicated Corporate Social Responsibility (CSR) Team. Thisis a specialist team of internal ethical trade experts who are located in key sourcing
locations such as Vietnam and who work closely with our supply chain partners.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

Sustainability Team: Dr. Martens has a team of internal sustainability experts
who have the skills and knowledge required to support decision-making on
environmental and social issues. They are also responsible for embedding
and championing the strategic sustainability projects throughout the business.
They attend all Sustainability Committee meetings and working groups toprovide specialist expertise when required.
Our full sustainability governance structure can be found on page 96 of our
FY23 Annual Report.

POLICIES AND CONTRACTUAL AGREEMENTS:

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We have a number of clear policies and procedures in place, along with strong supply chain management
processes to ensure our suppliers comply with our business terms and regulations.
Our policy needs in relation to human rights and modern slavery are reviewed by relevant teams including
our Legal, Compliance, Global Supply Chain and Sustainability teams. Policies are developed by using
international standards and benchmarking against best practices across the industry.

MASTER SUPPLYAGREEMENT

SUPPLIER CODE OF
CONDUCTMIGRANT WORKER
POLICY

Master Supply Agreements (MSA) havebeen introduced for our Tier 1 suppliers
and some of our Key Tier 2 suppliers. The
MSA includes relevant policies, such as
our Supplier Code of Conduct and MigrantWorker Policy, which cover our standards
and binding clauses on issues such as
human rights and modern slavery.

Our Supplier Code of Conduct sets out
our expectations for our suppliers on thetreatment of their workforce. It is basedon international conventions including
the Ethical Trade Initiative Base Codeand conventions of the International
Labour Organisation (ILO). Our Supplier
Code of Conduct contains clauses on
subcontracting and homeworking, as well as
detail on what constitutes modern slavery
or forced labour. The Code of Conduct is
contractually binding and is available for all
Dr. Martens employees on the complianceand training hub, as well as on our
corporate website.

Migrant workers in supply chains are more
vulnerable to modern slavery. Our MigrantWorker Policy sets out our expectations
on the treatment of migrant workers forour supply chain. It is based on the Dhaka
Principles, which were developed by theInstitute of Human Rights in Business(IHBR) and are based on international bestpractices, which address the issues migrant
workers may face. It is also available forall Dr. Martens employees on theinternal compliance and training hub.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTPG7

ANTI-SLAVERY AND
HUMAN TRAFFICKING
POLICYDOCTRINE

We have an Anti-Slavery and Human
Trafficking Policy to ensure that our own
employees are aware of their obligations
under the Modern Slavery Act and otherapplicable laws concerning forced labour(including child labour). It is available forall Dr. Martens employees on the internal
compliance and training hub.

In addition to our Supplier Code of Conduct,
we also have a global business Code of
Conduct called the ‘DOCtrine’ which raises
awareness and expectations amongst ourown employees regarding human rights
and modern slavery. It is made available
via a number of channels, including in the
induction pack for all new employees, on
the internal policy hub and on our
corporate website.

SPEAK UPCOMPLIANCE
PLATFORM

Issues can be reported through our free,
confidential Speak Up hotline. It is available
for anyone seeking guidance or to raise
concerns and grievances. Issues relating
to human rights, modern slavery, or any
other area covered in the DOCtrine can beraised here. The Compliance team manage
the response process.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

Our internal compliance platform allows
consistent and relevant policies and training
to be distributed globally across all regions
in relevant languages. It also provides
live views and up to date reporting andmonitoring of the business’ progress rate,
therefore allowing targeted training andcommunication where needed
throughout Dr. Martens.

RISK MANAGEMENT, SUPPLY CHAIN
MONITORING AND DUE DILIGENCE PROCESSES:PG8ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) RISKS ARE
INTEGRATED INTO DR. MARTENS BROADER RISK MANAGEMENTFRAMEWORK, AND ARE SUBJECT TO THE SAME GOVERNANCE,ANNUAL REVIEW PROCESS AND MANAGEMENT ATTENTION AS
OTHER RISKS RECORDED ON OUR GROUP RISK REGISTER.
FURTHER DETAIL ON OUR RISK MANAGEMENT FRAMEWORKIS ON PAGE 55 OF THE FY23 ANNUAL REPORT.

HUMAN RIGHTS RISKASSESSMENT:

THIRD PARTY DUEDILIGENCE PROCESS:

During FY23, we engaged with a specialist consultancy
to assess our management systems for identifying andmanaging human rights risks. The aim was to identify
the strengths and gaps in our human rights programme
and to provide recommendations for improvement.
The methodology was aligned with upcoming legislativerequirements for human rights due diligence and OECD
Guidelines. The project involved a thorough document
review and engagement with key internal stakeholders.
The exercise identified we have solid foundation for ourhuman rights programme and recommended areas
we can improve in a phased approach over the next
three years. These included formalisation of existingprocesses, strengthening policy commitments andclearer accountability. The next step is to establish an
implementation plan and agree priorities.

When we engage third parties, we must complete
sufficient due diligence before entering any
arrangement. We have a third-party due diligenceprocedure in place which is conducted before we
contract with any supplier (product and non-product)selling products, technology or services to Dr. Martens.
The process involves appropriate due diligence checks
on the supplier including a Vendor Risk Assessment,
contract review, compliance screening and a Data
Protection Impact Assessment (where applicable).
The level of due diligence depends on factors suchas the supplier’s location, activities to be performed
and the length and value of contract and is reviewed
on an annual basis per supplier. This process involves
teams across the business including Global Security,
Compliance, Data Protection and Legal, and will flag
any risks associated with a supplier, including ethicalconcerns such as modern slavery risk (including child

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

We use different due diligence tools to
support our commitment to human rights:+ Policies and contracts+ Group risk management framework+ Country approval process+ Supplier onboarding+ Supplier monitoring programme+ Training and workshops

labour). We follow a thorough risk assessment process
which is aligned to international standards. If criticalrisks are identified, such as previous unlawful practices,
we may not proceed with the contract

RISK ASSESSMENT
FOR NEW SOURCING
COUNTRIES:
Dr. Martens has a thorough process for reviewing andapproving new sourcing countries to ensure they areassessed for risks, including human rights and forced
labour risks. Before placing production in a new country,
we conduct a feasibility study review which includes adetailed country risk assessment. Risks are identified
and prioritised and mitigation strategies are includedin the proposal for any risks identified.

PG9

SUPPLIERONBOARDING:

SUPPLIER MONITORINGPROGRAMME:

Our supplier onboarding process is carried out
before production starts to ensure our productsuppliers meet our expectations. This processincludes a self-assessment questionnaire, ourthird-party audit partner will conduct an audit whichmust meet the required standard, plus visits by our
specialist CSR team.

We have an ongoing and established monitoring
programme for factories in our supply chain, which isone mechanism we use to identify and address risks
relating to modern slavery. The programme is run by
our Global Supply Chain Quality and Compliance
Team, which is comprised of experienced CSR
professionals based across Europe and Asia. It is thefoundation of our relationship with our suppliers inorder to maintain fair and safe working conditions.
The Workplace Conditions Assessment (WCA) is theaudit protocol conducted by Intertek, our specialist
audit partner. The WCA monitors compliancewith labour and environmental laws, regulations,industry standards and our own policies, such as our
Supplier Code of Conduct. The frequency of audits
is determined by the audit rating, which depends
on the severity of any issues identified. We take acollaborative approach with the suppliers and, whenissues are found, a corrective action plan is agreed to
remedy non-conformances in a timely manner.
We then carry out further follow-up checks to verify thecorrective actions have been taken. Should a supplierfail to remediate issues identified by an audit, thesupplier partnership is reviewed and may be ended.
We also engage with worker trade unions in our supply
chain to rectify issues where relevant. More details
about the WCA can be found on our website.
During FY23, 100% of our Tier 1 footwear suppliers
were found to meet our high standards . We are also
working to audit our Key Tier 2 suppliers. In FY23,
all Key Tier 2 audited were found to meet our highstandards in the WCA audits . For those Key Tier 2 we
do not audit through the WCA in the year, we request
the factory to provide a recognised social audit report
within the last 12 months. No cases of forced labour orchild labour were reported.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTRESPONSIBLE
PURCHASING
PRACTICES:
During FY23, we conducted extensive internal
engagement in partnership with an expert third party
to develop a Purchasing Practices Charter. Purchasing
practices refer to the importance of commercial
buying practices and supply chain management tosustainability. Good purchasing practices act as asafeguard for the fair treatment of workers and provide
a healthy work environment and business relationship.
The aim is to define responsible principles to uphold in
our engagement with suppliers which:+ Foster strong relationships that support sustainable

practices in our supply chain.

+ Enable us to further improve our buying practices,while generating additional insights into forecasting,pricing and other key areas for responsible sourcing.

+ Ensure we manage clear and effective

communication with our suppliers and have realistic,
agreed expectations on things such as lead times
and payment terms.

The Charter builds on the responsible buying practices
we have applied in the past and includes a focus on
key areas such as production scheduling optimisation,
forecasting and pricing. We continue to progress withthis project through the incorporation of anonymous
supplier feedback.

TRAINING, COLLABORATION AND
AWARENESS BUILDING:FORCED LABOUR
AND ETHICAL TRADE
E-LEARNING MODULE:

DR. MARTENS FOUNDATIONPARTNERSHIPS TACKLING
MODERN SLAVERY:

Education is a key pillar in our approach to tacklingmodern slavery. In FY23 we launched the Forced
Labour And Ethical Trade e-learning module which isa bespoke training module available to all Dr. Martens
employees. Initially this has been made available
to all staff. Over the coming year, through a phased
risk based approach it will be set to mandatory tocertain departments across the business such as
Distribution Management and Facilities. This shortcourse provides an introduction to the issue ofmodern slavery and forced labour, the different formsof modern slavery, how to spot the signs, and what to
do if there is a suspected case. So far, 346 employees
have completed the module.

The Dr. Martens Foundation is an independent charity
with a separate Board of Trustees. It receives thelarge majority of its funding from Dr. Martens Plc.
The charity donates to causes tackling social
injustices, including those tackling human rights
violations such as modern slavery.

We have developed a bespoke Forced Labour and Ethical Tradee-learning module for our employees which is due to be rolled out
in FY23.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

During FY23, the Foundation supported STOP THE
TRAFFIK. STOP THE TRAFFIK apply innovativetechnology and intelligence tools to uncovertrafficking routes and hotspots with the aim ofpreventing the recruitment of those vulnerable tobeing trafficked. A key way they do this is throughtheir STOP APP, which allows people to confidentiallyreport suspicions or incidents of human trafficking.
The grant paid for enhancements to the STOP APP
to increase intelligence gathered and audienceengagement. The project successfully upgraded
the language capabilities of the STOP APP, whichenabled expansion into multiple new and emerging
high-risk areas.
The Dr. Martens Foundation also supported
the A21 Campaign, a global NGO with a
mission to eradicate human trafficking throughawareness, intervention, and trauma-informed
holistic aftercare for survivors. Without adequate
aftercare support, survivors remain vulnerable tore-trafficking. A21 Freedom Centres provide survivors
with a safe place of acceptance where they have thefreedom to restore wellness, reintegrate safely back

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into society and live independently, which reduces
their vulnerability to re-victimisation. The grants
awarded enabled A21 to support more survivors withongoing holistic care through their Freedom Centres
in Bulgaria and Greece. The grants supported A21
Bulgaria to provide 30 survivors with individualised
support tailored to their specific needs, with 15
survivors able to find employment. A21 Bulgaria
reported a 50% increase in survivors being referredto the Freedom Centre. A21 Greece assisted 84
survivors through the Aftercare program in 2022,
a 40% increase compared to 2021.

EMPLOYEE ONBOARDING:
Human rights and modern slavery awarenessis included in the onboarding process for new
employees. The onboarding workshop includes
a segment on modern slavery and an overview ofour due diligence process across the supply chain.
New employees are pointed to the modern slavery
statement on our website for more information andthe training available.

2
Audit results of 75% or more, in line with Intertek Workplace
Conditions Assessment scoring methodology.

Audit results above 70% or more, in line with Intertek Workplace
Conditions Assessment scoring methodology.

3

PROGRESS:

PG11This is a summary of the actions we have taken since the last Modern Slavery Statement and theareas we want to focus on next. For more information on each of these points, please see thedetailed sections above:

Key area

Progress since last statement

Next steps+M APPING

Developed a Product Lifecycle Management (PLM) system. Once fully
operational, this will deliver enhanced visibility across our productlifecycle (see page 78 of the FY23 Annual Report).

Continue to investigate a specific traceability mapping
tool to monitor risks and opportunities across our
supply chain.

+E DUCATION AND

Rolled out modern slavery e-learning training module to employees
globally and tracked completion rates (page 10).

Introduce the modern slavery e-learning module asmandatory to specific internal teams.

Continued to engage internal teams including Sourcing, Finance andSupply Planning, to develop a Supplier Charter to establish responsible
purchasing principles (page 9).

Roll out Purchasing Practices Charter to communicate
and establish responsible purchasing principles.

100% of Tier 1 suppliers and Key Tier 2 suppliers audited achieved our
expected high standard in the Workplace Conditions Assessment (WCA)
audits (page 9).

Continue to monitor all Tier 1 and expand audit
programme across Key Tier 2 suppliers.

THE RISKS INOUR SUPPLYCHAIN ANDOPERATIONSTRAINING+E XPAND AND

IMPLEMENTBEST PRACTICEDUE DILIGENCE+C OLLABORATIONANDPARTNERSHIPS

Conducted a Human Rights Risk Assessment of our business and supply
chain (page 8).
Continued to develop a Purchasing Practices Charter to establish
responsible purchasing principles (page 9).
Conducted a Human Rights Risk Assessment of our business and supply
chain (page 8).

Review outputs of the Human Rights Risk Assessment
and kick off implementation plan to strengthen due
diligence processes.
Conclude and roll out Purchasing Practices Charter.
Review outputs of the Human Rights Risk Assessment
and kick off implementation plan to strengthen due
diligence processes.

Additional information about our Planet, Product, People sustainability strategy can be found on our website: www.drmartensplc.com/sustainability
This statement was approved by the Board on [28/09/2023] and signed on its behalf by by [Kenny Wilson, CEO (28th September 2023)].
MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT