PG1AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT2018/19MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENTPG2FOREWORD FROM OUR CEOintegrity.
AT DR. MARTENS, WE BELIEVE IN INTEGRITY.
fair, WE DO THINGS THE RIGHT WAY,WE ARE FAIR,values
AND WE DO NOT CUT CORNERS. THESE VALUESMEAN WE DO NOT ACCEPT MODERN SLAVERYIN ANY FORM. NO ONE SHOULD BE FORCED TO
WORK AGAINST THEIR WILL OR HAVE TO PAYFOR A JOB, BUT TODAY MILLIONS OF PEOPLEGLOBALLY ARE VICTIMS OF MODERN SLAVERY.
AS A BUSINESS, WE ARE committed
COMMITTED TORESPECTING HUMAN RIGHTS AND IDENTIFYING,INVESTIGATING, ENGAGING AND REMEDIATINGANY ISSUES UNCOVERED.
We are pleased to share our third modern slavery
statement, which gives an update on our previous
achievements and details of further action wewant to take in 2019.

DURING THE PAST YEAR WE:+ Updated our policies to strengthen ourexpectations from our employees andour suppliers+ Established a confidential employee hotline

suppliers in our supply chain+ Became signatory of Better Retail Better
World, an initiative supporting global efforts
to achieve the UN Sustainable Goals+ Extended our CSR audits to the lower tiers ofour supply chain

NEXT YEAR, WE WILL CONTINUE TO:+ Map risks in our supply chain andown operations+ C ollaborate further with others inthe industry+ P rovide more training to our own employees
This document builds on last year’s statement (you can find it here) and explains the steps
we are taking at Dr. Martens to prevent, detect and respond to slavery in our business andsupply chain. This statement covers Dr. Martens Airwair Group Ltd. and other group companies.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and California
Transparency in Supply Chains Act of 2010 (SB 657) and covers the activities between
October 2017 and January 2019.

KENNY WILSONCEO, Dr. Martens

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT+ Expanded our modern slavery training to key

CONTENTS
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ABOUT USOUR SUPPLY CHAINOUR COMMITMENTS AND POLICIESOUR FOCUS AREAS
COLLABORATIONPROGRESS AT A GLANCEWHAT IS NEXT?

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

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WHAT IS ‘MODERN SLAVERY’?

HIGHLIGHTS OF 2018:

The Ethical Trade Initiative refers to modern slavery as an umbrella term thatincludes: forced labour, bonded labour, human trafficking and slavery. Theterm “modern” is used to distinguish the complexity of today’s slavery fromhistorical slavery associated with the legal possession of one person by another.

+ Strengthened our policies by introducing

ABOUT USDr. Martens is a footwear brand that was established in Wollaston, UK in 1960,
and has had a manufacturing unit there ever since. Our global head office isin Camden, London.
Our products are sold in 243 Dr. Martens branded stores located all around the world, of which 108 of them are owned
by us. We also sell through wholesale and via our website, which ships internationally. In 2018, our group revenue was£348.6m. We employ over 2000 people directly who are based in our stores,offices and warehouses.
Location of employees
10.79%UK Head office London
UK Factory & Office Wollaston 7.14%
2.85%
UK DC
0.60%
EMEA office40.76%EMEA & UK Stores

StoresUSA office
USA DCUSA Stores
Asia Office
Asia stores

5.29%
2.95%
14.84%
7.29%
7.49%

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | ABOUT US

Owned stores 108
135Franchises
Concessions 57
11Pop-Upa new Migrant Worker Policy and updated
our Supplier Code of Conduct.

+ Incorporated human rights and ethicaltrade into our business Code of Conduct(DOC-trine).

+ Conducted compliance audits furtherupstream in our supply chain.

+ Extended our contractual requirementswith service contractors to include
compliance with modernslavery commitment.

+ Expanded modern slavery training toour key finished goods and raw material
suppliers in China.

+ Became a signatory of Better Retail
Better World to support global efforts
to deliver UN SDG 8.7 calling for theeradication of forced labour andmodern slavery.

PG5OUR SUPPLY CHAIN
WHERE WE PRODUCE AND SOURCE OUR PRODUCTS(1ST TIER SUPPLIERS)COMPONENT SUPPLIERS(2ND TIER SUPPLIERS)SERVICE CONTRACTORS

We are a footwear brand, which manufactures andsources footwear, clothing and accessories. Our
owned and operated footwear factory is located in
Wollaston, UK.

We also work directly with alarge number of our materialand component suppliers,
including leather and textiles,
which are located acrossAsia, Europe andSouth America.

We also purchase services,
consumables and marketing
materials from various
contractors. These
include labour agents in
our warehouses, logistic
operators and not-for-saleproduct suppliers.

We source the majority of our finished footwear, clothing and accessories
from factories in China, Thailand, Vietnam, Lao, Portugal and the UK.
There are more than 25,000 workers in our 1st Tier factories.

Where possible, these suppliers arenominated by us, which allows us tohave better oversight and controls of thematerials used in our products and theworking conditions.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR SUPPLY CHAIN

We are in the process of mapping andassessing the risk of the supply chain of
our operations in our headquarters andregions. While we continue mapping, wehave introduced a modern slavery clausein our new contract agreements. Where
contracting on supplier’s terms, we will
negotiate compliance with modern
slavery commitments.

PG6OUR COMMITMENTS AND POLICIESSUPPLIER CODE OF CONDUCT
EXISTING POLICIES:+ Updated our Supplier Code of Conduct(to include Subcontractor andHomeworker Policy)+ Anti-Slavery and Human Trafficking Policy

NEW IN 2018:
Migrant Worker Policy
Doc-trine (business Code of Conduct)

Our suppliers must adhere
to and are audited upon ourSupplier Code of Conduct(you can find it here), which
has been in place since 2006.
It has been updated annually to reflect
best practices. In 2018, we further updated
our Supplier Code of Conduct to include
our Subcontractor and Homeworker Policy,
which was originally developed as a standalone policy. We also included greater detailto help suppliers better understand what
constitutes modern slavery/forced labour.
Our Supplier Code of Conduct is based on
the Ethical Trading Initiative’s Base Code,international norms and industry standards.
This year, in addition to sharing ourpolicies with all of our first tier suppliers,
we extended this to our key material andcomponent suppliers, such as tanneries andoutsole suppliers.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR COMMITMENTS AND POLICIESANTI-SLAVERY AND HUMAN
TRAFFICKING POLICYAs stated in our previous
report, to ensure that our own
employees are aware of their
obligations under the Modern
Slavery Act, we introduced
an Anti-Slavery and Human
Trafficking Policy in 2016.
We conduct modern slavery awarenesstraining on a regular basis for our relevant
employees, including those at our sourcingoffices in Asia. Alongside this, we wanted
our employees to have the opportunity andability to speak up. In 2018, we introduced aconfidential hotline as an additional meansfor employees to raise concerns relating
to human rights, modern slavery, or any
other area covered in our business Code ofConduct (DOC-trine).

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MIGRANT WORKER POLICY

THE DOC-trine

Migrant workers in supply
chains are more vulnerable
to modern slavery because
they are unlikely to raisegrievances with theiremployers or the authorities –
especially if theyare undocumented.

In addition to updating our Supplier Code of Conduct, we have also introduced aglobal code of business conduct called The DOC-trine which raises awareness andexpectations amongst our employees regarding human rights and modern slavery.

This is a shared concern within the industry
and requires a collective and collaborative
approach to tackle this issue. This year we
introduced a Migrant Worker Policy andimplementation guidelines (which you canfind here). These are based on the Dhaka
Principles, which were developed by theInstitute of Human Rights in Business(IHBR) and are based on international
best practices, which address the issues
migrant workers may face. We introduced
these specific policy requirements acrossall our key suppliers, focussing first on thesuppliers who are based in countries where
there is a higher risk of migrant workers.

SPEAK UPWe have introduced a confidential hotline as an additional means for Dr. Martens employees to raise concerns relating tohuman rights, modern slavery, or any other area covered in our business Code of Conduct.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR COMMITMENTS AND POLICIESPG8OUR FOCUS AREAS

Non-footwear suppliers, which represent around 3%of our total production value, include manufacturers
producing our leather and textile accessories, bags
and garments.

1.SUPPLY CHAINRISK ASSESSMENT

As a result of our efforts, we have seen:+1st Tier: Compliance audits extended tonon-footwear suppliers.

Suppliers in China strengthen their own control
mechanisms around recruitment of agency workers
in order to verify employment conditions, as wellas to ensure required wages are paid.

+ 2nd Tier: Fully mapped component
and material suppliers and extended
compliance audits to key component andmaterial suppliers such as tanneries andoutsole manufacturers.

Suppliers in Thailand are now either employing
local staff or directly recruiting migrant workers
instead of using recruitment agencies, which has
resulted in greater protection of worker rights.

2.CAPACITY BUILDING:
Modern slavery training to Chinese
footwear and key component suppliers aswell as our sourcing team who are basedin China.

3.INTERNAL ENGAGEMENT
AND AWARENESS BUILDING.

SUPPLY CHAIN RISK ASSESSMENT
In addition to the compliance audit risk
assessments at our 1st Tier suppliers
explained in the previous report,
we have now extended these audits
to cover our non-footwear suppliers.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR FOCUS AREAS

Increased transparency from suppliers regarding
workers’ wages, supporting the elimination ofunauthorised monetary deductions.
In 2017 we carried out a 2nd Tier material andcomponent supplier mapping survey, covering all ourfinished good suppliers. Following this work, this year
we mapped all of our 2nd Tier suppliers, including
those that are nominated by our suppliers. This has led
us to consolidate and assess the compliance of these
suppliers against our standards.

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SUPPLY CHAIN CAPACITY BUILDINGSUPPLIER MAPPING STATUS
1st Tier Suppliers

2nd Tier Suppliers

MAPPPINGSTATUS

Fully mapped

Fully mapped

Partially mapped

AUDIT
STATUSAll footwear
audited, most
non-footwear
auditedPartially audited

Not yet audited

Audit against
Supplier Code ofConduct and Modernslavery criteria

Service Contractors

In 2018, we collaborated with Ethical Trading Initiative (ETI) to provide modern slavery
training to our key footwear and material suppliers in China. The training provided an
opportunity for our key suppliers to engage in the topic and get an overview of what
modern slavery is, the global legislative work around it, and how it links to our Supplier
Code of Conduct. During the training, suppliers looked at real examples of modern
slavery in China, learning how to identify these risks in their daily operations and what
an acceptable remediation process looks like.
After attending this training, our suppliers committed to further enhance their controls
over their own supply chains as well as providing modern slavery training to theiremployees. We plan to follow up on these commitments and will continue to provide
support to our suppliers on this topic.
In 2019, we will extend the modern slavery training to our key suppliers and employees
from our other sourcing countries.

Manufacturing
Tanneries,
outsole, fabric mills,
process suppliers, andother structural materials
Labour agents, contractors, marketing material suppliers*Audits conducted in 2018/19 at 1st and 2nd Tier: 102

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR FOCUS AREAS

INTERNAL ENGAGEMENT AND AWARENESS BUILDING
We continue to raise awareness andunderstanding of modern slavery
within other business areas, especiallythose directly involved in our sourcing
operations and recruitment. As partof this engagement, we extended ourpartnership with Ethical Trade Initiative,
to provide training to our team basedin China who manage relationships
with our suppliers. This was a separate
training session from the one held forsuppliers, as it was intended to give abroader understanding on modern slavery
to our team, as well as to underline thedue diligence mechanisms to identify
potential risks in our supply chain. Most
importantly, the training focused on
the impact sourcing practices have on
a supplier’s ability to operate ethically.
In the year ahead, we will look foropportunities to extend this training toother areas of our business.

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COLLABORATION:
We are proud that in 2018 we becamea signatory of the British RetailConsortiums industry initiative,Better Retail Better World.

We also joined, along with other major
UK retailers’, a CEO forum on modernslavery, organised by ASOS, one of ourkey customers.

This is a voluntary scheme, which aims to mobilise theretail industry to tackle some of the biggest global
challenges of the coming decades, highlighted by the UN
Sustainable Development Goals. These include respecting
human rights, supporting sustainable markets anddeveloping skills, which are fundamental to businesses.

The aim was to identify and address the risks of forcedlabour and human trafficking in collective supply chains
Discussion points included the modern slavery challenges,
risks companies face and ideas for addressing them.
All participants agreed to greater transparency, improved
reporting, increased collaboration and training fordifferent stakeholders.

committed TO ERADICATING FORCED LABOUR
HERE AT DR. MARTENS, WE ARE COMMITTED
AND MODERN SLAVERY BY WORKING WITH OTHERS AND PROMOTING GOOD
PRACTICES IN OUR OWN OPERATIONS AND SUPPLY CHAIN.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | COLLABORATIONPG11PROGRESS AT A GLANCE
As a business, we are committed to the continuous improvement in our approach to tackle modern slavery, forced labour and human trafficking.
We have achieved good progress against the commitments we set last year. Here is a summary of what we have accomplished so far:2017/18
COMMITMENT
Extend our CSR assessments
in all non-footwear factories
to get a better understandingof the labour standards andworking conditions.

We are creating a structure toenable our regional sales and storesteams to recognise modern slavery
risks in their own operations. This
includes services, consumables,
and the marketing materials theyreceive from contractors.

Modern slavery training
will be provided at all
our finished productsuppliers and our own
regional offices.

Developing a Migrant Worker
Policy that will cover principles
and requirements to guide ourinternal teams and suppliers
towards best practices whenemploying migrant workers.

We are increasing ourresources in Asia to startassessing our second tiersuppliers to understand theconditions in those factories.

Working with internal teams to map
our service, marketing materials andconsumables contractors, startingwith those in the UK, followed bythose in Asia and the Americas.

We have recruited an Asia CSR
officer who is responsible forassessing 2nd Tier suppliers
and supporting our 1stTier suppliers.

2018/19
PROGRESSCSR audits extended in
non-footwear suppliers in Asia,
as well as European suppliers
including UK.

Updated our requirements for
Gift with Purchase suppliers
to incorporate ethical trading
standards, including their own
statement on modern slavery.

Partnered with ETI toconduct modern slavery
training to key suppliersin China.

Migrant Worker Policy and implementation
guidelines are developed and shared withall finished good suppliers and key
raw material suppliers.
MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | PROGRESS AT A GLANCEPG12WHAT IS NEXT?
NEXT YEAR, WE WILL:+ Continue the previous years objectives.
Further map the risks deeper in our supply
chain and operations.

+ Provide more training to our own
employees and our suppliers in sourcing
countries beyond China.

+ Tackle the root causes of modern slaveryby implementing responsible recruitment
best practices and using more in-depth/
stringent assessment techniques during
the audits.

+ Identify and partner with key external
stakeholders and seek furthercollaboration with other industry
members and NGOs.
Additional information can be found on
the social responsibility section ofour website:www.drmartens.com/uk/social-responsibility

This statement was approved by the Board of Directors of Dr Martens AirWair Group Limited.

KENNY WILSONCEO, Dr. Martens

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | WHAT IS NEXT?