Equip Outdoor Technologies UK Limited
Modern Slavery Statement 2023-24
Equip Outdoor Technologies UK Limited (Equip) supports the UK’s Modern Slavery Act 2015(“the Act”) and has taken steps to prevent modern slavery from occurring in its supply chain
and within its operations. This statement, relating to the financial period January 2023-January2024, has been published in accordance with Section 54 of the Act and applies to Equip andthe Equip subsidiaries listed in the appendix.

1. Equip’s business and supply chain structure
Equip is an international business with a head office in
Derbyshire, UK. We are proud to own two specialist
outdoor brands – Rab (established in 1981) and Lowe
Alpine (established in 1967). Equip’s mission is toinspire adventure. We do this by building technicalproducts that last, whilst driving industry-wide change toprotect the planet, respect human rights, and increase participation in the outdoors.
We employ approximately 180 team members in the UK. 130 of these team members work in
Equip’s head offices designing, marketing, and selling our products or providing core business
functions. 50 of these team members work in Equip’s distribution warehouse and factory,
where we fill our down sleeping bags, distribute them to retailers and consumers, and operate
a service centre for washing and repairing our products.
A further 50 Equip employees work across Germany, the Netherlands, Norway, Finland,
Canada, and the USA, marketing and selling our products to international markets and runningour product service centres. We also have small teams in China, Bangladesh, and Vietnam
who are responsible for monitoring manufacturers in Asia.
Equip does not own or operate any overseas manufacturing facilities but contracts partners to
manufacture products to our required standards. We work closely with manufacturers andhave long-term stable contractual relationships with them.
In 2023-24, we worked with 19 manufacturing partners who operated 25 sites acrossBangladesh, China, India, Indonesia, Myanmar, the Philippines, and Vietnam as well as oursite in the UK. Over 13,000 people are employed by our manufacturing partners globally.
Figure 1: Equip’s 2023-24 manufacturing sites by country

2. Managing risk in our operations
2.1 The risk
The majority of Equip’s direct employees operate in roles that are low risk for modern slavery.
These include design, marketing, sales and other core functions. However, we recognise that
employees who work in our UK factory and warehouse are in roles that are considered highrisk for modern slavery by the UK Gangmaster and Labour Abuse Authority (GLAA). According
to the GLAA, using agency staff in these sectors undermines accountability and reduces
oversight of workers’ experiences.

2.2 Equip’s policies and due diligence
All of Equip’s regular team members in the factory and warehouse are Equip employees, nottemporary agency staff. By keeping our teams in-house, we mitigate much of the risk
associated with our operations. We occasionally use temporary agency staff during peak
periods. This typically occurs a handful of times a year and involves small numbers who
remain on-site for a few weeks. Section 3.2.7 outlines the due diligence conducted on ourlabour provider.
There is still a small risk for direct employees as modern slavery can affect anybody. We
manage this by having clear recruitment policies and processes where relevant checks arecarried out on all new starters. We maintain open relationships with employees with regularface-to-face check-ins.
We have a Whistleblowing Policy that provides all employees, including permanent andtemporary team members, a formal procedure for reporting criminal offences or breaches oflegal obligations, including modern slavery. Team members at our factory and warehouse also
have access to the Fair Wear Foundation Complaints Helpline, detailed on posters displayed
throughout the site. In 2023-24, we received no complaints regarding UK operations from the
Fair Wear Helpline.

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3. Managing risk in our supply chains
3.1 The risk
Following the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment
and Footwear Sector, Equip conducts Human Rights Due Diligence (HRDD) as part ofstandard operating procedures. This includes routinely conducting risk assessments to identify
actual and potential harms in our supply chain, including forced labour and modern slavery.
Our HRDD risk assessment is guided by Fair Wear’s resources including country studies,
external resources published by international bodies, NGOs, social audits, worker complaints,
and annual self-assessments completed by manufacturing partners. For more information on
Equip’s HRDD processes, see Equip’s 2023-24 Social Report.
Our risk assessment highlights that the final product manufacturing stage, known as ‘cut maketrim’ (CMT) is the most labour-intensive tier of apparel manufacturing and is where mostviolations occur. As well as prioritising by sector, the country of operations can impact the riskof modern slavery. According to the Global Slavery Index (2018), of the countries our
manufacturers operate in, Myanmar1 and India have the highest risk for modern slavery. In
China, we have an additional risk that our supply chains will be associated with forced labourand human rights violations inflicted upon the Uighur people.
In addition to wider risk assessment, primarily focusing on final product assembly, we conduct
tier / sector-specific assessments.
Trim suppliers and subcontractors
Equip’s HRDD processes primarily focus on the two sectors that are the most material to our
supply chain; fabric manufacturing and product assembly. However, there are suppliers
operating in other tiers that may pose a risk of forced labour, which includes suppliers of:• trims (such as zip pullers and care labels),• manufacturing partners’ subcontractors, and• suppliers of factory-sourced components.
In 2022, we conducted a risk assessment of these suppliers based on country, sector, andcommodity risk. Our assessment showed that the sectors with the highest risks were:• injected-moulded plastic components (such as buckles),• leather components, and• metal components (such as eyelets).
Cotton was the commodity risk of main concern due to its association with forced labour inmultiple countries, including China.
Of nearly 400 suppliers assessed, we categorised 40 as a priority for further due diligencebased on their risk. They either manufacture components containing cotton; or operate in highrisk countries in above-average-risk or high-risk sectors in above-average-risk countries.
UK-based service suppliers
Equip uses suppliers in the UK to provide a range of services, from professional to on-site
provisions. Using GLAA sector risk typologies to assess our service supply chain, we identified

1 As of 18th January 2024, we have completed our responsible disengagement from Myanmar and nolonger source from the country. See our Myanmar Statement for further information.

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cleaning services, agency staff, and security personnel from UK-based service providers, as
the greatest risk due to their economic sector.

3.2 Equip’s policies and due diligence
Since 2020, Equip has been a member of the Fair Wear
Foundation, a movement for change that seeks to push
the garment industry towards a world where working
conditions are fair for the people who make our clothes.
We are committed to supporting garment workers’ rights
to safe, dignified and properly paid employment, andmaking garment production fair for everyone. We upholdand promote Fair Wear’s Code of Labour Practices(COLP), which includes a specific standard for ensuring freely chosen employment.
The Equip Responsible Business Conduct (RBC) Policy establishes the principles of how
Equip conducts business. It outlines what stakeholders can expect from Equip and, where
relevant, what Equip expects from them. The RBC includes the commitment that Equip will
ensure the prohibition of forced and child labour throughout our supply chain and conduct
HRDD on all relevant harms, including forced labour and modern slavery.
Equip’s Human Rights Due Diligence (HRDD) Policy integrates the commitments made in our
RBC into our daily business practices. It follows the ‘OECD Due Diligence Guidance for
Responsible Supply Chains in the Garment and Footwear Sector’ when taking steps to cease,prevent, mitigate and remediate harms when they do occur.
The commitments, expectations, and procedures established in the RBC and HRDD policies,
are communicated to our manufacturing partners through Equip’s Manufacturing Supplier
Manual. This internal document is issued annually and signed by each manufacturing partner.
Below is a summary of Equip's relevant due diligence steps. For a full overview and progress
per manufacturing partner, see Equip’s 2023-2024 Social Report.
Supplier selection and onboarding
Equip’s Human Rights Due Diligence Policy establishes the checks that all potential suppliersmust undergo during selection. This includes an evaluation of each supplier’s working
conditions and employment practices. Our CSR team reviews suppliers’ completed evaluation
surveys, relevant policies, and audit reports. A potential supplier’s CSR performance isincluded in their scorecard and contributes to the selection decision.
Once selected, all suppliers are informed of what Equip’s Fair Wear membership means tothem. We require all our manufacturers to:•••Endorse Fair Wear’s Code of Labour Practices (COLP),
Inform their workers of the COLP and Fair Wear’s Complaints Helpline by displaying
information in their workplaces, in the local language, andCo-operate with Equip to remedy complaints submitted by workers or findings identified
in audits, addressing root causes where possible.

Suppliers must sign Equip’s Manufacturing Supplier Manual annually, which contractuallybinds them to abide by Fair Wear standards and other sourcing requirements.

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Supplier monitoring
We maintain long-term relationships with our manufacturing partners enabling them to invest
in both the individual workers and the facilities they provide. While long-term partnerships don’t
guarantee good working conditions, we believe our influence and support contribute toimproving conditions over time.
We have regular in-country meetings with manufacturers to help forge long-term relationships.
Personnel from Equip at all levels, including directors, design, operations, materials andbuying, as well as our corporate social responsibility team, have regular discussions and makefrequent site visits.
Equip employees use our Site Visit Checklist when visiting manufacturing sites, to raise any
concerns or feedback to our CSR team who investigate further.
Since 2019 we have required our manufacturers to be audited against the amfori BSCI Codeof Conduct which establishes standards they must abide by to protect their workers’ humanrights. As established in our Human Rights Due Diligence Policy and Manufacturing Supplier
Manual, we require manufacturers to be audited by third parties at least every two years, share
the audit reports with us, and work with us to correct any non-compliance. Several
manufacturing partners have also been audited by Fair Wear whose methodology emphasises
the importance of on and off-site worker interviews.
In 2023-24, we introduced supplier scorecards for all our tier-one manufacturing partners. The
annual scorecards allow us to monitor and arrange constructive fact-based discussions
relating to opportunity areas, improvement areas, and risk areas in the partner’s operations.
We include three social measures that we feel highlighted the most important risks: social
improvement and remediation, social dialogue and freedom of association and living wages.
Worker training
Since 2021, we have commissioned Fair Wear training for workers at our key manufacturing
partners. This in-person training delivered by Fair Wear trainers teaches workers about theirrights and the standards they should expect; explains how they can use the Complaints
Helpline to raise violations of the COLP; and promotes social dialogue between the workers
and management.
In 2023, we also commissioned Fair Wear’s anti-gender harassment training at our key
partner's site in Bangladesh. Our HRDD risk assessment had identified it as a significant risk.
In 2023-24, over 55% of our production volume was manufactured at sites where workers hadreceived Fair Wear training in the last three years.
Responsible purchasing practices
As a member of Fair Wear, Equip follows fair purchasing practices that promote safe, dignified,and properly paid employment. Our commitment to responsible purchasing practices are
summarised in our Sourcing Principles. We are committed to ensuring continuous production
for manufacturers and provide yearly production forecasts to help them plan accordingly. We
avoid short-term deliveries as we recognise this places undue pressure on manufacturers andincreases the chance of excessive overtime or temporary workers. We pay for finished goods
upon receiving the bill of lading with no delay in payment. If partners require us to alter
standard payment terms, such as partial upfront payment, we remain willing to meet theirrequests as far as practically possible.

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Sourcing restrictions
In response to the risk of forced labour in China, we have taken active steps to ensure thatnone of the cotton sourced for our products originates from the Xinjiang region of China andthat none of our manufacturers or their subcontractors operate in the region. We also prohibit
the use of cotton from Turkmenistan in our products due to the risk of forced labour. In 2022,
we lifted our prohibition of Uzbeki cotton in response to the Cotton Campaign ending their callfor a global boycott.
Trim suppliers and subcontractors
Following our risk assessment of the trim suppliers and subcontractors, we conducted
additional due diligence on 40 suppliers identified as a priority. These suppliers completed aself-assessment regarding their employment practices, provided audit reports whereavailable, and submitted evidence of their cotton’s country of origin where relevant. Suppliers
operating in China were asked additional questions regarding the regions their workers camefrom, and their involvement in poverty alleviation labour transfers (so-called “Xinjiang Aid”)
that can be connected to Uighur forced labour. Having reviewed all suppliers’ responses andfollowing up on any queries, Equip is satisfied that these suppliers have been able toeffectively mitigate the risk of forced labour.
UK-based service suppliers
In 2021-22, we conducted due diligence on the high-risk service suppliers identified in our risk
assessment – cleaning, labour providers, and security. These suppliers completed a modern
slavery survey and were required to provide relevant employment and recruitment policies.
Reviewing these documents and any press coverage and online reviews of the companies,
Equip concluded that all our high-risk suppliers are mitigating their risk sufficiently. None ofthese high-risk service suppliers have changed since we last conducted the due diligence.

4. Training
All Equip employees that visit our manufacturing partners are made aware by our CSR team,of potential human rights issues, including modern slavery. Employees are expected to raise
any concerns with the factory management at the time or report to the Equip CSR team using
the Site Visit Checklist to be investigated further.
In 2022-23, our CSR team delivered training on the risks of forced labour and modern slavery
to teams that visit and most engage with our manufacturing partners. Equip employees fromproduct development, production, and merchandising all attended. The training covered an
introduction to forced labour and modern slavery, relevant legislation, how our industry is
impacted, the risks in our supply chains, and how to report concerns. It also included a specificsection on the risk of Uighur forced labour in China, recognising the risk is no longer limited to
the Xinjiang region.

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5. Measuring Performance
5.1 KPIs
Since Equip’s 2020-21 Modern Slavery Statement, we have reported on the following key
performance indicators:
Key Performance Indicator
Fair Wear Brand Performance Check score forreporting year.
This annual assessment scores Equip’s approach to
improving working conditions for workers in our supply
chain. Our purchasing practices, supplier monitoring
programme and transparency are all assessed. Fair Wear’s
assessment methodology is available here.

20-21

21-22

22-23

23-24

NA

59

80

66*

1st Year
MemberRating:Good

Rating:LeaderRating:Leader

89%

86%

74%

76%

89%

46%

94%

94%

58%

62%

50%

59%

Percentage of Equip’s production volume frommanufacturers where a business relationship hasexisted for at least five years.
This indicator measures how well Equip knows our
manufacturers. Long-term relationships allow us toencourage our manufacturers to introduce strong humanrights safeguards.

Percentage of Equip’s production volume frommanufacturers that have been visited by one of
our team members in the reporting year.
This indicator measures our supply chain oversight anddemonstrates our commitment to maintaining close
relationships with our manufacturers. Third-party audits are
conducted in addition to these visits.

Percentage of Equip’s production volume frommanufacturers that we provide a continuous
production planThis indicator measures how we mitigate fluctuating
demand for our suppliers, enabling them to employ workers
permanently rather than on temporary or seasonal
contracts.

*Note: Fair Wear updated their scoring methodology in 2023-24, increasing the standards that member companies
must exceed in response to the increased calls for corporate human rights due diligence legislation.

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5.2 Equip’s Progress and Commitments
In our 2022-23 Modern Slavery Statement, we outlined two further steps we intended to takein 2023-2024 to build on our human rights performance:
2023-24 Commitment
Work with our partner in Indonesia to explore how we can support wage
increases now we have set a wage baseline and living wage target

Progress
Complete

Further improve our HRDD processes to ensure outputs are integrated
Complete
into teams’ decision-making and all relevant tiers are assessed routinely
Explore how we can better address gender equality in our supply chains Ongoing
Using an independent third-party cost of living assessment conducted by WageIndicator, we
successfully calculated and financed a wage rise at our key partner’s site in Indonesia. This
wage has been paid to workers since October 2023, and we intend to continue checking thatit meets the local living costs periodically.
Our new supplier scorecards, which include measures for social performance, have enabled
us to formally integrate outcomes of our partner risk assessments and monitoring into ourdecision-making. These scorecards now inform discussions during site visits and sourcing
strategy.
In 2023-24, we improved the data we collect annually from partners relevant to genderequality, including asking for average wage data per gender. Additionally, we commissioned
Fair Wear’s anti-gender harassment training at our partner’s site in Bangladesh as we
identified it as high risk. However, we recognise there are still further improvements we canmake and will keep this action open for next year.
In 2024-25 we intend to:•••Continue to address gender equality in our supply chains
Compare our payment practices to the Common Framework of Responsible
Purchasing Practices (CFRPP) and identify improvements.
Formally capture feedback from tier-one manufacturing partners on Equip’s sourcing
practices.

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6. Statement Approval
This statement covers the financial period 1 February 2023-31 January 2024 and has been
approved by the Board of Equip Outdoor Technologies UK Ltd on 23 July 2024.

Signed by
Matt Gowar
Executive Chair
Equip Outdoor Technologies UK Ltd.
23 July 2024

6.1 List of Equip Subsidiaries
Equip Deutschland GmbH
Equip Benelux BV
Equip Outdoor Technologies UK Ltd
Equip Outdoor Technologies Ltd
Equip USA LLC
Equip Canada Inc
Equip Norway AS

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