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AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

2021/22

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTINTRODUCTION
The Ethical Trade Initiative refers to modern slavery as an umbrella term that includes: forced and compulsory labour,
bonded labour, human trafficking and slavery. The term “modern” is used to distinguish the complexity of today’s
slavery from historical slavery associated with the legal possession of one person by another.
Integrity is at the heart of what we do and how we show
up at Dr. Martens. We expect high standards of eachother and our supply partners. As a result, we will neveraccept modern slavery in any form and we take our
responsibility seriously.
We are committed to improving our approach year on
year. In this, our fifth Modern Slavery Statement, weoutline the steps we are taking to prevent, detect andrespond to slavery through supply chain traceability,
education and collaboration.
This statement covers Dr. Martens plc and other group companies which are inscope (and together are referred to as “Dr. Martens”) and is made pursuant tosection 54 of the Modern Slavery Act 2015 and California Transparency in Supply
Chains Act of 2010 (SB 657). This statement covers activities between 1st February
2021 and 31st March 2022.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

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STRUCTURE, BUSINESS, AND SUPPLY CHAINS
WHO WE ARE:

WHERE WE OPERATE:
Our global head office is located in London.
We operate a regional model from three regions:

SOLD IN

OVER

60

14M

+ PAIRS SOLDA YEAR

COUNTRIESGLOBALLY

EMEA
headquartered in London

FTE

FY22

FY22

2,229

£908.3M

9.8M+ EMPLOYEESBUSINESSREVENUE

SOCIAL MEDIAFOLLOWERSAMERICAS
headquartered in Portland
APAC
headquartered in Hong Kong

APAC
£127.1M

EMEA£398.5M

AMERICAS£382.7M*Group’s revenue per region(Twelve months ended 31 March 2022)

Dr. Martens is an iconic global footwear brand. Our productrange includes a footwear portfolio comprised of the Originals,
Fusion, Kids and Casual categories, as well as a complementary
range of Accessories. Our Originals category accounted for
51% of total revenue during FY22. We create durable, highquality and timeless footwear, and these principles are rooted
in a sustainable, long-term custodian approach. Our products
are worn by a diverse consumer base who use Dr. Martens bootsand shoes as a symbol of their individual self-expression.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

Our products are sold through a number of channels including our owned retail stores,
franchise stores, concessions, distributors, wholesale customers, and via e-commerce.
We have 158 owned stores globally (41 in the Americas region, 80 in EMEA, and 37 inAPAC). Our website ships internationally and ecommerce accounted for 29% of Grouprevenue in FY22.

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OUR PEOPLE:

SUPPLY CHAIN

We directly employ 2,229 people (FTE) who are based in ourstores, offices, factories and distribution facilities all aroundthe world.

We define our global supply chain tiers in the following way:

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 andempowered to express themselves. Our employees are treated in a fair, lawful
and professional manner. Robust recruitment processes are carried out in linewith employment laws including right to work document checks. Pay is reviewed
annually and all employees are included within the bonus scheme.

+ Tier 1 supplier: Manufacturing and assembly of finished products.
+Key Tier 2: A supplier that produces a strategic component.
+ Tier 2: A supplier that produces other components.
The majority of our footwear and accessories are manufactured by our Tier 1
suppliers across Asia and Europe, with a small amount of footwear being madeat our owned manufacturing site in the UK. Our Tier 1 factory list is shared on our
website and is updated every six months.
The first pair of Dr. Martens were manufactured on April 1st 1960 at our Cobbs
Lane factory, located in Wollaston, England, and were so called the ‘1460’. We have
manufactured footwear from this location ever since and it remains home to ourMade In England (MIE) manufacturing facilities. More than 90 people work at our
MIE site and it is where our “Made In England” range is produced.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTDISTRIBUTION:
Throughout FY22 we operated with 2 Group-operated
distribution facilities and 9 third-party distribution facilities
to warehouse and ship our products to distributors, wholesalecustomers, own retail stores, franchise stores, concessions,and e-commerce consumers throughout the world.
Distribution centre activities include receiving finished goods from our third-party
manufacturers and “Made in England” factory, inspecting and processing those
products (including returns), and shipping them to our customers and to our own
stores. Temporary employees in our distribution facilities are hired by labour
providers.
In the distribution centres we directly operate, we work with trusted labour agentsfor the recruitment of temporary employees for peak trading periods. We aim to
only offer full time positions to temporary staff, unless the role requires particularexperience, or is a managerial position.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

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SUPPLIERS:

WE SOURCE THE MAJORITY OF OUR PRODUCTS THROUGH TRUSTED THIRD-PARTY MANUFACTURERS. WE BELIEVE IT
IS IMPORTANT TO DEVELOP AND FOSTER LONG-TERM PARTNERSHIPS AND HAVE WORKED WITH MANY OF OUR SUPPLYCHAIN PARTNERS FOR DECADES.
When partnering with Tier 1 suppliers, we value strong
long-term relationships in order to obtain quality,
service, value for money and maintenance of expectedlabour and environmental standards. We also nominate
a number of our Tier 2 suppliers including tanneries
and outsole suppliers.

TIER 1:
The majority of our products are sourced throughtrusted supply chain partners, many of which we haveworked with for decades. Our footwear is manufactured
in six different countries at 19 sites across theUnited Kingdom, Vietnam, China, Thailand, Laos andBangladesh. Across the Tier 1 factories, there areapproximately 30,000 workers.

AW22 FOOTWEAR MANUFACTURING LOCATIONS
30% South of Vietnam
22% North of Vietnam
22% Laos
10%

China

8%

Bangladesh

7%

Thailand1%

UK

We organise regular supplier conferences which areattended by our key suppliers and hosted by our
Chief Operating Officer. These meetings 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. The frequency of our
supplier conferences was increased to every six weeks
during the pandemic to address the ever-changing
environment.
Our Tier 1 suppliers are audited by an independent
third-party specialist auditing company. For more
information about this see the ‘due diligence’ section.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTTIER 2 AND OTHERSERVICE SUPPLIERS:
In addition to Tier 1 suppliers, we work directly with our
key suppliers for leather and outsole granulate material
and provide a list of nominated Tier 2 suppliers forother components, which we require the Tier 1 suppliers
to use. Our top materials sourced by volume areleather, outsole granulate and packaging materials.
We shortlist preferred Tier 2 suppliers through an audit
process; the criteria for which includes conformity with
our Supplier Code of Conduct which is based on bestpractice standards set out in the Ethical Trade Initiative
Base Code and conventions of the International Labour
Organisation as well as adherence to compliance(including in connection with modern slavery laws andregulations) and product quality standards. We monitor
this nominated Tier 2 supplier list on an ongoingseasonal basis.

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STRATEGY AND GOVERNANCE:HUMAN RIGHTS IS A KEY FOCUS AREA OF OUR SUSTAINABILITY PROGRAMME:

CLI

In 2022 we launched our new Planet, Product, People sustainability strategy. This
strategy captures our eight key areas which were based on the material issues
identified through an in-depth materiality assessment.

+

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HU M A N R

We are also working to include sustainability across all parts of the business.
Sustainability has been integrated into the DOCS corporate strategy. Sustainability
projects are included in each of the DOCS pillars to ensure that sustainability becomesan operational requirement for all functions delivering our long term sustainability
commitments which are part of our strategy.

DE

Human Rights was identified in the materiality assessment as a key focus area for thebusiness and is included within the ‘People’ sphere of the sustainability strategy.

PA

GOVERNANCE:The Board and the Executives are collectively responsible for ensuring we meet our humanrights and supply chain responsibilities and operationally, the Chief Operating Officer andChief HR Officer take responsibility for this on a day-to-day basis. Ethical trade and humanrights in the supply chain due diligence falls within the remit of the dedicated Corporate Social
Responsibility (CSR) Team.
The Sustainability Team are responsible for embedding and championing the sustainability
strategy projects throughout the business. The overarching sustainability strategy is overseenby the Sustainability Steering Committee, which is chaired by the CEO and reports directly
MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

to the Board. The Legal, HR, Supply Chain and Facilities Teams are also responsible for the
implementation of policies and procedures that support Dr. Martens to meet its human rights
responsibilities.
Our full sustainability governance structure can be found on page 87 of our FY22 Annual Report.

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POLICIES AND CONTRACTUAL AGREEMENTS:
SUPPLIER POLICIES:

We have a number of policies and procedures to ensure our suppliers comply with our business terms, as well as employment,
environmental and other relevant laws and regulations. We have contractual provisions to require that our agents, distributors andfranchisees also comply with the same terms.
MASTER SUPPLIER AGREEMENT

SUPPLIER CODE OF CONDUCTMIGRANT WORKER POLICY

Master Supplier Agreements (MSA) have been
introduced for our Tier 1 suppliers and key Tier 2
suppliers. The MSAs, which are signed by our Tier 1
and key Tier 2 suppliers and third-party distribution
facilities, includes our policies, such as our Supplier
Code of Conduct and Migrant Worker Policy, which
cover our standards and binding clauses on issues
such as human rights and modern slavery. In 2020
a modern slavery clause was included in our new
standard contract agreements. Where contracting on
supplier’s terms, we negotiate compliance with modern
slavery commitments into the contract.

Our Supplier Code of Conduct sets out our
expectations for our suppliers and it is based on the
Ethical Trade Initiative Base Code and conventionsof the International Labour Organisation (ILO).
Our Supplier Code of Conduct contains clauses on
subcontracting and homeworking, as well as detailon what constitutes modern slavery or forced labour.
The Code of Conduct is reviewed annually and iscontractually binding. It is issued to our Tier 1 and key
Tier 2 suppliers for their annual re-commitment to thespirit and the letter of the Code of Conduct. It is also
referenced in each supplier conference by the Chief
Operating Officer. It is also available for all Dr. Martens
employees to review on the internal policy hub, as wellas on our website here.

Our Migrant Worker Policy sets out our expectations
on the treatment of migrant workers for our supply
chain. It is based on the Dhaka Principles, whichwere developed by the Institute of Human Rights in
Business (IHBR) and are based on international bestpractices, which address the issues migrant workers
may face. Migrant workers in supply chains are more
vulnerable to modern slavery because they are lesslikely to understand their rights or raise grievanceswith their employers or the authorities. The MigrantWorker Policy is reviewed annually and is issued to
our Tier 1 and key Tier 2 suppliers for their annual
recommitment. It is also available for all staff on the
new compliance and training hub.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTPG9INTERNAL POLICIES:

ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY
We have an Anti-Slavery and Human Trafficking
Policy to ensure that our own employees are awareof their obligations under the Modern Slavery Act.

DOCtrine
In addition to our Supplier Code of Conduct, we also havea global business code of conduct called our 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 plc website.
SPEAK UPWe also have a confidential hotline as an additional
means for Dr. Martens employees to raise concerns andgrievances relating to human rights, modern slavery, or
any other area covered in the DOCtrine.
COMPLIANCE PLATFORM:
The platform, named ‘How We Do Business’ 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 datereporting and monitoring of the business’ progress
rate, therefore allowing targeted training andcommunication where needed throughout Dr. Martens.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTHOW OUR POLICIES ARE DEVELOPED:RISK ASSESSMENT APPROACH:

Our policy needs in relation to human rights andmodern slavery are regularly reviewed by relevant
teams including our Legal, Compliance, Global Supply
Chain and Sustainability Teams. Policies are developedby using international standards and benchmarking
against best practices across the industry. They arereviewed by the Board or Executive directors before
being rolled out.

Before placing production in a new sourcing country,
we conduct a thorough feasibility study review.
One element which feeds into this is a country risk
classification. Six governance indicators are used
to assess the level of risk as identified by the World
Bank. One of these include ‘Voice and Accountability(VA) – capturing perceptions of the extent to which a
country’s citizens are able to participate in selecting
their government, as well as freedom of expression,
freedom of association and a free media.’

RISK MANAGEMENTPROCESS:RISK MANAGEMENT PROCESS:
Our approach to risk, including Environmental, Socialand Governance (ESG) risks, is an integrated part ofthe overall governance and management of the Group.
Management at various levels are involved in thegovernance and risk management process, including
the Board, Audit and Risk Committee, the Operational
Risk Committee and the Regional Risk Committees.
Throughout the year, we have continued to mature andembed our overall risk management process, including
a focus on risk appetite. Risk governance, oversight andmore details on our principal risks can be found frompage 97 of the FY22 Annual Report.

SUPPLY CHAIN MAPPING TOOL:
We are currently investigating a supply chain mapping
tool which will allow data sets such as human rights
and modern slavery risk to be overlayed onto our
supply chain.

SUPPLY CHAIN MONITORING AND DUE DILIGENCE PROCESSES:
SUPPLIER MONITORING PROGRAMME:THIRD PARTY DUE DILIGENCE:WE HAVE IN PLACE AN ONGOING MONITORING PROGRAMME FOR FACTORIESIN OUR SUPPLY CHAIN, WHICH IS ONE MECHANISM WE USE TO IDENTIFY AND
ADDRESS RISKS AND INCLUDES MODERN SLAVERY RELATED RISKS.
All our suppliers across Tier 1 and key suppliers fromour Tier 2 are monitored by an independent third-party
auditing company for compliance with labour andenvironmental laws, regulations, industry standards andour own policies, such as our Supplier Code of Conduct,
which is based on the ETI base code. The frequency ofaudits 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 supplier failto remediate issues identified by an audit, the supplierpartnership is reviewed and may be ended.
The programme is run by our Global Supply Chain
Compliance Team comprised of experienced CSR
professionals based across Europe and Asia and is thefoundation of our relationship with our suppliers in orderto maintain fair and safe working conditions.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

PG10During FY22, 100% of Tier 1 footwear suppliers CSR
audited were found to meet our high standards and nocases of child labour or forced labour were reported by
the independent third-party audits in our supply chain.
We are also committed to setting similar high standards
for our Key Tier 2 suppliers. Under our CSR monitoring
programme, we are now working to extend the Workplace
Conditions Assessment (WCA) across our most significant
Key Tier 2 suppliers with a focus on the top suppliers byvolume. For more information on our CSR monitoring
programme can be found in our FY22 Annual Report.

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 vendor 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. The level of due diligence depends on
factors such as the supplier’s location, activities to be
performed and the size 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. We follow athorough risk assessment process which is aligned tointernational standards. If critical risks are identified,such as previous unlawful practices, we may notproceed with the contract.

TRAINING AND AWARENESS BUILDING:

PG11FORCED LABOUR E-LEARNING:
Education is one of the key elements in our approach to tackling modern slavery. Over the past year, we havebeen developing a bespoke forced labour and ethical trade e-learning module which will be available to all Dr.
Martens employees. This short course will be mandatory for relevant departments, providing an introduction
to the issue of modern slavery, the different forms of modern slavery and forced labour, how to spot the signs,
and what to do if there is a suspected case. It is due to be rolled out in FY23.
In our previous statement we outlined how we hosted a human rights awareness video on our internal training
hub. This was intended as an introduction to the tailored modern slavery e-learning module due to be rolled
out in FY23 (see above). To date, 602 employees have completed the training video.

MODERN SLAVERY TRAINING
FOR THE DISTRIBUTIONMANAGEMENT TEAM:
Conducting regular awareness training for our
employees is one of the key areas of focus acrossour modern slavery programme. We continued
with this commitment and delivered bespoke
modern slavery training for our UK distribution
management team in October 2021. Distribution
is a priority function to receive modern slavery
training, due to the growth in ecommerce and useof temporary workers. The training was delivered
across two sessions to all Team Managers andSenior Operatives and introduced the issue ofmodern slavery, how to spot the signs, and what
to do if there is a suspected case. The training
pack was updated to include additional advice onreporting suspected victims through a new mobile
app which is tackling modern slavery through theuse of big data.
MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTEMPLOYEE ONBOARDING:
Human rights and modern slavery awarenessis included in the onboarding process for new
employees. The one-day onboarding workshop
includes a segment on modern slavery and an
overview of our due diligence process across the
supply chain. New employees are pointed to themodern slavery statement on our website for more
information and the training available on the hub.

We have developed a bespoke Forced Labour and Ethical Trade e-learning module for our
employees which is due to be rolled out in FY23. its behalf by [x].

COLLABORATION:
MATERIALITY ANALYSIS WITH PWC:
In March 2021, the materiality assessment outlined in ourprevious statement concluded. This process identified
the environmental and social issues which are mostsignificant to Dr. Martens. You can find out more about
this on pages 60-61 of our FY22 Annual Report.
The issues identified formed the basis for thedevelopment of our new sustainability strategy; Planet,
Product, People. ‘Human rights, modern slavery andlabour rights’ was identified as one of the key issues
for the business and as such, is one of the focus areas
within the ‘People’ pillar of our strategy.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTPG12ALIGNMENT WITH THE SUSTAINABLE
DEVELOPMENT GOALS:WORKING IN PARTNERSHIPWITH CUSTOMERS:Alignment with the global sustainability agenda is
key to driving progress. In early 2022, an external
consultant carried out an assessment to better
understand which UN Sustainable Development Goals(SDGs) and related Targets matter most to Dr. Martensand our stakeholders. The structured, score-based
assessment identified that UN Target 8.7 calling for theeradication of forced labour and modern slavery is oneof our most relevant targets. This is why developing
and progressing with our approach of knowing our
supply chain, education and collaboration is key. Moreon the assessment methodology and relevant Goals
and Targets can be found on page 64 of the
FY22 Annual Report.

House of Lords pledge: Since March 2019 we have beena signatory of the House of Lords and ASOS Modern
Slavery pledge. We continued to engage and attend
workshops and events throughout the year, sharing
valuable updates and learnings.

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PROGRESS:This is a summary of the actions we have taken since the last statement and what we want to focus on next.
For more information on each of these points, please see the detailed sections on page 14:
Key area

Progress since last statement

Next steps+ MAPPING THE RISKS INOUR SUPPLY CHAIN AND
OPERATIONSStarted tender process for a supply chain mapping tool to enable
traceability and greater transparency across our supply chain.

Identify and implement a mapping tool to monitor
risks and opportunities.

+ EDUCATION AND
TRAINING

Developed bespoke modern slavery awareness training module.

Roll out training module to employees globally andtrack completion rates.

+ EXPAND AND IMPLEMENTBEST PRACTICE DUEDILIGENCE

100% of Tier 1 suppliers audited achieved the highest rating in the
Workplace Conditions Assessment (WCA) audits.

Delivered tailored in-depth training to distribution management.

Continued to expand the WCA assessment across key Tier 2 suppliers.
Third party due diligence process developed to monitor risks across
new vendors.

+ COLLABORATION
AND PARTNERSHIPS

Concluded a formalised gap and materiality analysis with PwC.
Continued to engage with the House of Lords pledge and engaged in
the working group.

Continue to expand audit programme across key
Tier 2 suppliers.
Review how human rights can be further integrated
into the Third Party Due diligence process.

Tender for a partner to conduct a Human Rights
Impact Assessment.

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 21st September 2022 and signed on its behalf by Kenny Wilson, CEO (21st September 2022).

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT