California Transparency in Supply Chains Act of 2010 Disclosure

Introduction

This statement is made pursuant to the California Transparency in Supply Chains Act of 2010 which requires retail sellers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking in their direct supply chain. This statement sets out of the steps taken by RIMOWA Distribution, Inc. (“RIMOWA”) to ensure that slavery, servitude, forced or compulsory labour and human trafficking (collectively, “Modern Slavery”) is not taking place in any part of its business or in its supply chains.

Business

RIMOWA manufactures and distributes premium luggage to clients in the United States including the State of California. RIMOWA is an iconic worldwide brand.

Policies and Practices

RIMOWA’s commitment is to act with integrity in all its business dealings and to promote ethical conduct to enhance compliance with applicable law and to provide guidance with respect to business conduct. RIMOWA has a number of policies that are relevant to this commitment, which set out what RIMOWA expects from its employees, internal business and its external suppliers. Key policies are:

• RIMOWA’s Suppliers’ Code of Conduct (copy available upon request)
  RIMOWA expects its suppliers to share its commitments and to act in full compliance with all applicable laws, including all national, local and international laws relating to the management of their businesses.
  RIMOWA requires its suppliers to seek approval before subcontracting any part of their supply chain process and RIMOWA’s approval is subject to acceptance by the subcontractor of the Suppliers’ Code of Conduct and such other conditions that RIMOWA determines.
  
  
• RIMOWA Code of Conduct (copy available upon request)
  Our anti-Modern Slavery policy reflects our commitment to act ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.
  RIMOWA expects its employees and suppliers to engage in and promote honest and ethical conduct, comply with all applicable laws, rules and regulations in their own area and act responsibly, with due care, competence and diligence when dealing with colleagues, customers, suppliers, agents and intermediaries.
  The RIMOWA Code of Conduct reiterates the LVMH Code of Conduct and commitment to act with the highest standards of integrity, respect and engagement in our behaviours and in the way that we conduct business every day, everywhere.
  This Code of Conduct further states that the LVMH group companies will inform all of their commercial partners of these ethical principles and expectations and will ask its suppliers to comply with the principles set out in the Suppliers’ Code of Conduct.
  In particular, this code specifies compliance with social issues to abide, respect and adhere to the company moral and ethical values in the management of the company concerning human rights, working conditions and environmental issues.
  
  

Supplier and Contractor Due Diligence

RIMOWA has been carefully reviewing its suppliers and many of its suppliers are carefully chosen for the entire group by LVMH.

RIMOWA reserves the right to check adherence of its suppliers and contractors to the principles set out in the Suppliers’ Code of Conduct and to conduct compliance audits at any time without notice.
Upon reasonable request, RIMOWA suppliers and contractors shall supply the necessary information and grant access to RIMOWA representatives to verify compliance with the requirements of the Suppliers’ Code of Conduct.
Suppliers and contractors shall further keep proper records to provide compliance with this Code and provide access to complete, original and accurate files to RIMOWA representatives.

Upon reasonable request, RIMOWA suppliers and contractors must improve and correct any deficiency discovered during any such audits.

RIMOWA shall use its reasonable endeavours to ensure that all RIMOWA supplier and contractor template contracts contain clauses requiring RIMOWA’s suppliers and contractors to adopt similar anti-modern slavery standards and practices.