RAPHA RACING LTD

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Human resources Procurement staff Your suppliers

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation Workers within your supply chain Businesses in your industry or sector

Social audits

Audit conducted by your staff Third party audit arranged by your organisation

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Demonstrated progress

Last year, we set a target to meet all of the Ethical Trading Initiative's Corporate Transparency Framework requirements, which we achieved. In our latest statement, we committed to ensure key tier 1 suppliers pay their workers a living wage and have effective worker voice mechanisms in place. In doing so, our intention is to strengthen workers’ rights and further protect against the possibility of modern slavery.

Reported risks and mitigations

• Risk: There have been instances of workers being charged recruitment fees for their employment in the Taiwan supply chain, including within our sector.
• Area: Within your supply chains
• Tier: Tier 2 suppliers
• Group: Migrants
• Location: Taiwan
• Mitigation: Recruitment fees are prohibited in our Code of Conduct and periodically checked for in our annual supplier audit and due diligence process. In the event that recruitment fees are found, Rapha will issue a corrective action plan to implicated suppliers. This would include working collaboratively with them to remedy the issue, ensuring workers are reimbursed, and installing new processes to prevent recruitment fees in the future.
• Risk: The global cotton supply chain has been linked to temporary and migrant labour, resulting in a higher risk of indentured or child labour in certain countries.
• Group: Women Migrants Refugees Children
• Location: China
• Mitigation: We require that all of our cotton be certified organic or in-conversion. The certification process helps ensure that supplier labour rights are held to the highest standard. Additionally, the certifications that we use (such as GOTS and OCS) use the segregation chain of custody model - which ensures that cotton is segregated at each stage of the supply chain and guarantees traceability after farm level.
• Risk: With independent unions illegal in China, and with roughly a quarter of both our tier 1 and tier 2 suppliers located there, this could present a risk to forced labour conditions.
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Women Migrants Refugees
• Mitigation: We have set a target that all of our tier 1 suppliers have either collective bargaining or effective worker voice mechanisms in place by 2030. This is supported by our audit process to gauge freedom of association in suppliers’ operations. Where collective bargaining or worker voice mechanisms are not in place, we directly collaborate with our suppliers to introduce and improve FOA/worker voice mechanisms.