PG1

MODERN SLAVERYAND TRANSPARENCY IN THE SUPPLYCHAIN STATEMENT
2023/24

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTINTRODUCTION

PG2Modern slavery is an umbrella term used to describe coercive labour practices. It is when a person
loses their freedom and is exploited for the personal or commercial gain of another, with threatof punishment or penalty. It covers forced and compulsory labour, bonded labour, child labourand human trafficking.
The number of people in modern slavery has risen in recent years and affects
every region of the world. The latest global estimates indicate there are 50
million modern slavery victims1 which is approximately one in every 150
people. Crises such as the Covid-19 pandemic, conflict and climate change
disrupt employment and education, increasing cases of extreme poverty
and forced migration, which all lead to the increased risk of all forms ofmodern slavery.
At Dr. Martens we expect high standards of each other and our global supply
partners. We will never accept modern slavery in any form and we take our
responsibility to tackle the problem seriously. As a global business we takeaccountability of our role in driving transparency and change. Each year weoutline our approach to prevent, detect and respond to cases of forced labour
through supply chain traceability, education and collaboration.
This statement covers Dr. Martens plc and other Group companies which arein scope (and together are referred to as “Dr. Martens”) and is made pursuant
to section 54 of the Modern Slavery Act 2015, California Transparency inSupply Chains Act of 2010 (SB 657) and Canada’s Fighting Against Forced
Labour and Child Labour in Supply Chains Act, SC 2023 (authorized inaccordance with subsection 14(4)(b)(ii)). This statement relates to the Dr.
Martens fiscal year from 1 April 2023 to 31 March 2024. All actions outlined
took place during this period unless stated otherwise.

International Labour Organization (ILO), Walk Free, and International
Organization for Migration (IOM) Global Estimates of Modern Slavery,
Forced Labour and Forced Marriage

1

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTSTRUCTURE, BUSINESS, AND SUPPLY CHAINS

PG3WHERE WE OPERATE:

WHO WE ARE:

We are a global business and operate a regional model:

FY24

11.5M

EMEA

Headquartered in Camden, London,
and with offices in Milan, Barcelona,
Paris and Düsseldorf.

PAIRS SOLD
THIS YEAR

FTE,
FY24

2,630

FY24

£877M

EMPLOYEES+ BUSINESSREVENUEAMERICAS

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

APAC£119.5M
EMEA£431.8M
AMERICAS£325.8M

APAC

Headquartered in Hong Kong with regional
offices in Tokyo, Shanghai and Seoul.

*Group’s revenue per region(Twelve months ended 31 March 2024)

Dr. Martens is an iconic British brand founded in 1960 in Northamptonshire.
Dr. Martens boots were originally produced for workers looking for tough, durable
footwear, but were quickly adopted by diverse subcultures and musical movements.
Six decades on, Dr. Martens products are worn by people around the world who
use them as a symbol of empowerment and their own individual rebellious selfexpression. Dr. Martens was listed on the London Stock Exchange in 2021.

Our products are sold through the following global revenue channels:

Our products are sold through the following global revenue
channels:• Wholesale: This encompasses wholesale partner relationships, together with country
distributor models and franchised stores.

Our product range is centred on our originals and made up of two groups, main-line (Originals,
Fusion, Casual, Kids and Accessories) and AMP (Collaborations, Archive and Made In
England, 14XX). The Originals category accounted for 40% of FY24 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 with a
43% male and 56% female split in FY242.

We employ 2,630 people (FTE) who are based in our stores, offices, factories and distribution
facilities all around the world. Our priority is to provide fair and safe working conditions for allof our employees, and to foster an environment where everyone feels supported, included
and empowered to express themselves.

2

The remaining 1% are those who do not identify as male or female.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT• Direct-to-consumer (DTC):+Ecommerce: Our consumer websites cover the majority of our markets.
+ Retail: We directly 239 stores globally (102 in EMEA, 61 in Americas,
and 76 in APAC).

OUR PRODUCT GLOBAL SUPPLY CHAIN
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.

TIER 1:
Our products are manufactured by our global networkof Tier 1 suppliers located across Asia and Europe.
We have one owned manufacturing site which islocated in the UK and produces Made In England andcollaboration products. We have mapped all of ourTier 1 suppliers.
When partnering with Tier 1 suppliers, we value
strong relationships and have worked with many of
our supply chain partners for decades. At FY24 year
end, there were 27 active Tier 1 supplier factories(13 footwear, 8 accessories, 6 outsole). Our Tier 1
factory list is shared on our website and is updated
approximately every six months.
We hold supplier conferences which are attended
by our Tier 1 suppliers and are hosted by our Chief
Operating Officer. These conferences promote anenvironment of trust and transparency, whilst allowing
us to build a deeper understanding of the issues facedby our suppliers. A constant narrative is held with
suppliers regarding corporate social responsibility(CSR) topics, including the expectation of highsocial and labour standards. These topics are also
addressed at the supplier conferences.
In addition to Tier 1 suppliers, we work directlywith Key Tier 2 suppliers who produce strategic
components including leather and outsole
MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

PVC granulate. We have visibility of all key component
suppliers and nominate our preferred Key Tier 2
and Tier 2 suppliers. Our top materials sourced
by volume are leather, outsole PVC granulate andcardboard packaging.
We operate with nine core distribution centres (DCs)across EMEA, Americas and APAC. One DC in the
UK is directly owned and operated and the otherDCs are all third party operated. DC activities include
receiving finished goods, 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 a trusted labour agent for
the recruitment of temporary employees for peaktrading periods.
Non-product suppliers:
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 technology providers.
All new suppliers, product and non-product, mustgo through our Third Party Due Diligence Process.

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STRATEGY AND GOVERNANCE
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HUMAN RIGHTS IS A KEY FOCUS
AREA OF OUR SUSTAINABILITYSTRATEGY

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Human rights continue to be a focus area of our Planet, Product, People
sustainability strategy and is included within the People pillar. The sustainability
strategy covers environmental and social aspects across eight areas basedon Dr. Martens material sustainability issues. Strategic projects relating tosustainability such as resale, repair and sustainable material adoption are
included in the business strategy to ensure sustainability is embedded acrossthe business. For additional information on our sustainability strategy pleasesee our latest Annual Report.

PG5

C
PA

GOVERNANCE
The Board is responsible for the oversight and integration of ESG-related issues andactivities across the business. The Chief Operating Officer (COO) is accountable
for supply chain human rights and the Chief People Officer (CPO) is accountable forhuman rights across our own operations.
Global Supply Chain Team: Representatives from our Global Supply Chain
Team are based in our manufacturing countries. They regularly conduct visits to our
suppliers and work closely with our CSR team to feed in any insights.
CSR Team: Ethical trade and human rights due diligence in the product supply
chain falls within the remit of the dedicated CSR Team. They work closely with our
suppliers and are based close to key sourcing locations. This helps them work
collaboratively and transparently with our suppliers. It also facilitates the quick
identification and remediation of any potential issues, including the completion ofcorrective action plans. Our COO chairs regular, periodic meetings with our CSR
MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTTeam to review CSR audits and results, so these are closely monitored toensure our high ethical standards are adhered to, and any non-conformities
are addressed appropriately.
Sustainability Team: Dr. Martens has a team of internal sustainability experts
who have the required skills and knowledge 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
FY24 Annual Report.

POLICIES AND CONTRACTUAL AGREEMENTS
Our policies, procedures and strong supply
chain management processes ensure
our suppliers comply with our businessterms and regulations. Our human rights
and modern slavery policy needs arereviewed by relevant teams including
Legal, Compliance, Global Supply Chain
and Sustainability. Policies are developed
through a multi-stakeholder approach andare benchmarked against international
standards and best practices acrossthe industry.
All Dr. Martens policies are available
to employees via our policy hub andare available in relevant languages.
Supplier policies are also translated andcommunicated with suppliers in relevant
languages. Some of our policies are also
publicly available on our plc website. Our
compliance platform allows policies andtraining to be consistently distributed
globally across all regions in relevant
languages. It also provides live views andup to date reporting and monitoring of
progress rates, therefore allowing targetedtraining and communication where needed
throughout Dr. Martens.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTMASTER SUPPLYAGREEMENTOur Tier 1 suppliers and priority Key
Tier 2 suppliers sign our Master Supply
Agreements (MSA). The MSA includes
relevant policies, such as our Supplier
Code of Conduct & Workplace Standards
and Migrant Worker Policy, which cover ourstandards and binding clauses on issues
such as human rights and modern slavery.

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SUPPLIER CODE OF
CONDUCT
Our Supplier Code of Conduct sets out
our expectations for our suppliers on thetreatment of their workforce. It is based oninternational conventions including
the Ethical Trade Initiative Base Code andconventions of the International Labour
Organisation (ILO).

MIGRANT WORKER
POLICYRESPONSIBLE
PURCHASING
PRACTICES CHARTER

Migrant workers are three times more at
risk of becoming a victim of forced labour.
Our Migrant Worker Policy sets out our
expectations on the treatment of migrant
workers for our supply chain. It is based oninternational best practices and the Dhaka
Principles, which were developed by theInstitute of Human Rights in Business(IHBR) and addresses the specific issues
migrant workers may face.

In 2024 we also launched a Responsible
Purchasing Practices Charter. The charter
was developed following internal andexternal stakeholder engagement including
supplier interviews, and covers topics suchas planning, fair costing and training. As partof this pledge, we have visibility to labourcosts to ensure workers are paid fairly by our
suppliers. Further details can be foundon page 9.

PG7
Our People

DOCTRINE
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.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT‘SPEAK UP’
WHISTLEBLOWINGPOLICYANTI-SLAVERY AND
HUMAN TRAFFICKING
POLICY

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 tohuman rights, modern slavery, or any otherarea covered in the DOCtrine can be raised
here. The Global Compliance team manage
the response process.

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.

Other relevant policies include our Global
Health and Safety Policy, Global Sanctions
Compliance Policy and Third Party Due
Diligence Process.

RISK MANAGEMENT, SUPPLY CHAIN
MONITORING AND DUE DILIGENCE PROCESSESPG8ENVIRONMENTAL, 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
Environmental, Social and Governance (ESG)
risks are integrated into Dr. Martens broader risk
management framework, 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
framework is on page 38 of the FY24 Annual Report.
Following the third party assessment of our humanrights due diligence procedures during FY23, weestablished an implementation plan and agreed
priorities. During FY24 we kicked off work to develop
a formal Human Rights Policy for our business which
was identified as a gap in our existing programme.
We are also investigating how we can build upon ourdue diligence processes to capture more in depth andregular risk assessments of all third party suppliers
we engage with. In FY24, we continued the rollout of

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

our new Product Lifecycle Management (PLM) system
to help deliver enhanced visibility across our productlifecycle. The PLM system supports enhanced visibility
across our product suppliers. We are also investigatinga traceability tool to map our supply chain which will
help in our commitment to transparency.

RISK ASSESSMENT
FOR NEW SOURCING
COUNTRIES
Before placing production in a new country, we havea thorough process for reviewing and approving
new sourcing countries. We conduct an in depth
feasibility review which includes a detailed country risk
assessment, including human rights and forced labour.
Risks are identified and, prioritised and mitigation
strategies are included in the proposal for any risks
identified before Board level review.

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

THIRD PARTY DUEDILIGENCE PROCESS
We have a third party due diligence procedure in place
which is aligned to international standards and isconducted before we contract with any supplier. The
process involves due diligence checks on the supplier
including a Vendor Risk Assessment, compliancescreening, Data Protection Impact Assessment andcontract review (where applicable). An ESG risk
rating is also calculated per supplier. The level of due
diligence depends on factors such as the supplier’s
location, activities to be performed and the length andvalue of contract. This process involves teams acrossthe business including Global Security, Compliance,
Data Protection and Legal, and will flag any risks
associated with a supplier, including historical ethicalconcerns such as modern slavery violations (includingchild labour). If critical risks are identified, such asprevious unlawful practices, we may not proceed withthe contract.

SUPPLIER ONBOARDING
Following appropriate due diligence checks, oursupplier onboarding process is carried out before
production is approved to begin to ensure our productsuppliers meet our high expectations. This includes
a self-assessment questionnaire, a third party audit
which must meet the required standard, plus visits byour specialist CSR team.

SUPPLIER MONITORINGPROGRAMME
We have an ongoing CSR monitoring programme forfactories in our supply chain, which is one mechanism
we use to identify and address risks relating tohuman rights and modern slavery. The programme
is managed by our Global Supply Chain Quality andCompliance Team, which is comprised of experienced
CSR professionals.
The Workplace Conditions Assessment (WCA)
is the audit protocol conducted by Intertek, our
specialist third party audit partner. The WCA monitors
compliance with 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 issues identified. We takea collaborative 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.
When needed, we also engage with worker tradeunions in our supply chain to rectify issues. Moredetails about the WCA can be found on our website.
During FY24, 100% of our audited Tier 1 footwear
suppliers met our high standard in the WCA audit3.
MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

We also audit some of our Key Tier 2 suppliers. In
FY24, we focussed on auditing certain tanneries, PVC
granulate and welt suppliers. The selected Key Tier 2
suppliers audited under the WCA protocol also met our
expected high standards4. For those Key Tier 2 we do
not audit through the WCA in the year, we request thefactory to provide a recognised social audit report fromwithin the last 12 months. No cases of forced labour orchild labour were identified in our supply chain during
FY24.

SUPPLIER ONBOARDING
Following appropriate due diligence checks, oursupplier onboarding process is carried out before
production is approved to begin to ensure our productsuppliers meet our high expectations. This includes
a self-assessment questionnaire, a third party audit
which must meet the required standard, plus visits byour specialist CSR team.

RESPONSIBLE
PURCHASING
PRACTICESIn FY24, we worked with third-party experts to develop
the first iteration of our Responsible Purchasing
Practices Charter. Purchasing practices refer tothe importance of commercial buying practices
and supply chain management. Good purchasing
practices act as a safeguard for the fair treatment ofworkers and provide a healthy work environment andbusiness relationship. The charter was developed
following a review of our current practices, processes
and policies, as well as both internal and supplierinterviews.
Dr. Martens endeavours to interact and treat ourmaterial, product and service suppliers according
to the following principles:

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1. RELATIONSHIPS - We invest in our suppliers,and value long-term partnerships in which we can work
together to improve mutual business performance.
2. PAYMENT TERMS - We operate to an agreed
payment schedule.
3. PLANNING - We forecast and communicate ourorder requirements well in advance so that our suppliers
can carefully plan for what they need.
4. FAIR LABOUR COSTING - We ensure legallycompliant and competitive provision for wages andbenefit.
5. TRAINING - We train all our relevant teams on what
it means to purchase responsibly.
6. COMMUNICATIONS - We value transparency
and understand the importance of two-way, open andhonest communication.
7. SUPPLIER EXIT - We will only undertake asupplier exit after full consideration and in a responsibly
managed way.
8. SUSTAINABILITY - We work with our suppliers
to set clear expectations around sustainability,
including human rights and environmental values andcommitments.
We expect our suppliers to adopt the spirit of theseprinciples with their own suppliers. Following thedevelopment of the Charter, we now plan to embed its
adoption through the development of training for ourpeople and suppliers.
3

 udit results of 75% or more, in line with Intertek
A
Workplace Conditions Assessment scoring methodology.

4

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

TRAINING, COLLABORATION
AND AWARENESS BUILDING
Education is a key pillar in our approach to tacklingmodern slavery. We continue to offer a bespokee-learning module on Forced Labour And Ethical
Trade training to all employees. The module
introduces the issue of modern slavery and forced
labour, the different forms of modern slavery, how
to spot the signs, and what to do if there is asuspected case.
Human rights and modern slavery awarenessis included in the onboarding process for new
employees. The onboarding workshop includes asegment on modern slavery and an overview of ourdue diligence processes across the supply chain.

DR. MARTENS FOUNDATIONPARTNERSHIPS TACKLING
MODERN SLAVERYThe Dr. Martens Foundation is an independent charity
with a separate Board of Trustees. It funds causes
tackling social injustices, including human rights
violations such as modern slavery.
During FY24, the Foundation continued to fund STOP
THE TRAFFIK. STOP THE TRAFFIK apply innovativetechnology and intelligence tools to uncover trafficking
routes and hotspots, with the aim of preventing therecruitment of those vulnerable to being trafficked. A
key way they do this is through the STOP App whichallows people to confidentially report suspicions orincidents of human trafficking. The grant awarded in
March 2024 will go towards creating bespoke content
and features to better reach the Albanian community,
and share lived experience stories to increase

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

engagement and interaction with NGOs. Alongside
the projects driven by our previous grants, this will
increase engagement and facilitate the expansion of
the STOP App into multiple new and emerging highrisk areas, which creates a more accurate picture ofhuman trafficking where it’s most needed and a more
effective approach to combatting it.
The Dr. Martens Foundation also supported The A21
Campaign who seek to eradicate human trafficking
through awareness, intervention and traumainformed holistic aftercare for survivors. As the threatof human trafficking across the globe continues to

PG10grow, so does the need for victim-centred supportand suitable independent accommodation options to
reduce a survivor’s vulnerability to re-trafficking. A21’s
Freedom Centres provide survivors with a safe placeof acceptance as well as supportive services aimed at
empowering, rehabilitating and reintegrating them into
society. The focus is to strengthen their independence
and reduce victimisation. The three-year grant, first
awarded in 2023, supports A21 in keeping theirFreedom Centres and other survivor services running,enabling them to reach more survivors trying to breakthe cycle of human trafficking.

PROGRESS

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

Key area

Progress since last statement+M APPING THE RISKS• C
 ontinued to embed use of a Product Lifecycle Management (PLM)system. Once fully operational, this will deliver enhanced visibility
across our product lifecycle (page xx).

IN OUR SUPPLY CHAIN
AND OPERATIONS+E
 DUCATION AND
TRAINING+E XPAND AND

IMPLEMENT BESTPRACTICE DUEDILIGENCE+C
 OLLABORATION AND
PARTNERSHIPS• Commenced investigations into a specific traceability mapping tool tomonitor risks and opportunities across our supply chain.

• R olled out Purchasing Practices Charter to communicate and establish
responsible purchasing principles.
• C ontinued to monitor all Tier 1 suppliers and expanded audit
programme across select Key Tier 2 suppliers.
• C ommenced implementation plan to strengthen human rights due
diligence processes.
• C onducted supplier engagement to develop and finalise Purchasing
Practices Charter.

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 19 September 2024 and signed on its behalf by Kenny Wislon, CEO
MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

Next steps• C ontinue to embed PLM system and progresswith selection of traceability mapping tool.

• D evelop Purchasing Practices Charter
communications plan, including training
for employees.

• D evelop and roll out internal Human Rights
Policy and continue to review and develop due
diligence processes.

• C ontinue to engage suppliers and employees
on human rights issues through training andworkshops.