Osprey Europe Limited
Modern Slavery Statement

Anti‐human Trafficking and Modern Slavery Statement 

For Fiscal Year 2022 (March 1, 2021 – February 28, 2022)

About Helen of Troy

Helen of Troy is a global consumer products company offering creative solutions for our customers in three business segments: Housewares, Health & Home, and Beauty.  Helen of Troy was incorporated as Helen of Troy Corporation in Texas in 1968 and reorganized as Helen of Troy Limited in Bermuda in 1994.  Helen of Troy purchases its products from unaffiliated manufacturers, most of which are in China, Mexico and the United States. Details of our business performance and organizational structure is in our most recent 10K filing here.

Our values and own operations

At a minimum, we expect our Company, our associates, our suppliers and our partners globally to comply with relevant and applicable legal and professional requirements and regulations. In addition, our Environmental, Social and Governance (ESG) Guiding Principles also outline our policies and commitments on human rights, specifically to address slavery and human trafficking risks in our operations and supply chain ‐such as our policies on freely chosen labor, protecting migrant workers, minority groups and women’s rights, no tolerance for child labor,. Detailed employee expectations are in our Code of Conduct, while supplier expectations our outlined in our Supplier Code of Conduct.

Our Board of Directors, through the Corporate Governance Committee, oversees ESG‐related matters and its implementation, including anti‐human trafficking and modern slavery. Our ESG Director, who reports to the General Counsel, leads our ESG program, works closely with our corporate‐wide ESG Task Force, and reports regularly to the Board on these matters. In fiscal 2022, we formally launched our ESG strategy, which included strengthening our human rights program particularly in our supply chain. We provide updates on our progress in our ESG Report.

Our supply chain

All of Helen of Troy suppliers must comply with local legislation and regulations and must conduct their activities in line with our Supplier Code of Conduct.  We provide human rights training and awareness (including on human trafficking and slavery) to associates with direct responsibility for supply chain management, with the intent to effectively implement this statement.

Each of our suppliers has its own supply chain and we recognize that each level in the supply chain is responsible for ensuring compliance with all applicable laws and regulations and for respecting human rights. Our focus, for the purpose of this declaration, is on our own direct suppliers, however, we encourage suppliers to share our expectations throughout their own supply chains.

In policies or agreements with third parties, Helen of Troy requires suppliers and contractors to contribute to sustainable development and to be economically, environmentally and socially responsible. Helen of Troy expects suppliers to comply with applicable laws, regulations and international standards that require them to treat workers fairly and to provide a safe and healthy work environment. All new suppliers must undergo a social compliance audit, which includes an assessment of its practices to avoid modern slavery and human trafficking.

Our Supplier Code of Conduct addresses business practices of our third‐party suppliers. It contains specific provisions addressing human rights, labor, and business conduct, including verification of our product supply chain to evaluate and address risks of human trafficking and slavery aligned with our ESG Guiding Principles.  Suppliers are expected to designate management staff to monitor their factories, production facilities and compliance with our Supplier Code of Conduct. Helen of Troy may conduct announced or unannounced visits and/or have third‐parties audit to ensure compliance with the Supplier Code of Conduct, including compliance with prohibitions on slavery and human trafficking.

The number of assessments follows our risk‐based approach and is dependent on the level of project activity awarded throughout the year. If gaps are identified, we may work with suppliers to help them understand how to close those gaps or we may ultimately consider terminating the contract. Suppliers that are required to develop a corrective action plan may be subject to additional audits, which may be announced or unannounced, as part of Helen of Troy’s monitoring efforts. In addition, contracts may be terminated with immediate effect if suppliers breach, or we suspect they are in breach, of Helen of Troy’s Supplier Code of Conduct.

Disclosures

Helen of Troy is working on implementing an environmental, social and governance (ESG) reporting plan, including information related to key performance indicators on the effectiveness of the steps we have taken on these topics.

This is Helen of Troy’s group statement on anti‐trafficking and modern slavery for Fiscal Year 2022 (March 1, 2021‐ February 28, 2022) and is made pursuant to The California Transparency in Supply Chain Act of 2010 (SB 657) and section 54(1) of the UK’s Modern Slavery Act of 2015.

Signature

Osprey Europe LimitedModern Slavery Statement

This statement applies to Osprey Europe Limited (referred to in this statement as ‘the Company’).

Company Structure

The Company’s offices comprise of the Headquarters in Dorset, UK and there is an additional satellite showroom in Munich, Germany.  The parent company of Osprey Europe Limited is Osprey Packs, Inc. of Colorado, USA, (referred to in this statement as ‘Parent Company’). Osprey’s products are produced and manufactured by our Parent Company in Vietnam.

The main activity carried out the by the Company is the distribution of specialist packs and accessories to European wholesalers and retailers.  The Company also performs the sale of the aforementioned goods via its website.  Demand for our products is consistently high throughout the year and is, therefore, not seasonal.

Commitment

The Company acknowledges its responsibilities in relation to tackling modern slavery and human trafficking and commits to complying with the provisions in the Modern Slavery Act 2015.  The Company and Parent Company understands that this requires an ongoing review of both its internal policies and practices in relation to its workforce and, additionally, its supply chains.

Our Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

The Company does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory work and human trafficking.

No labour provided to the Company in the undertaking of the provision of its own services is obtained by means of slavery or human trafficking.  The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom and Germany.

Supply Chains

In order to fulfil its activities, the main supply chains of the Company include those related to the distribution and shipping of products from Vietnam to Europe and throughout Europe.  The Company considers its main exposure to the risk of slavery and human trafficking to exist within its supply chains in Vietnam, where protection against breaches of human rights may be limited.  In general, the Company considers its exposure to slavery/human trafficking to be relatively limited. The Company and Parent Company have taken steps to ensure that such practices do not take place in its business nor the business of any company that supplies goods and/or services to it.

Due Diligence Processes

As part of our initiative to identify and mitigate risk we have in place systems to:

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.

The Company has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery and/or human trafficking.

Steps

In accordance with section 54(4) of the Modern Slavery Act 2015, the Parent Company has taken the following steps during the financial year to ensure that modern slavery is not taking place:

  • Raised awareness of the Modern Slavery Act 2015 amongst our supply chain teams based in Vietnam.
    • Code of Conduct displayed in three languages at HQ Vietnam and all tier one partners (factories).
    • Code of Conduct was acknowledged in writing by all material suppliers
    • Communicated face to face with each of the factory’s leadership teams.
    • Corporate Social Responsibility (CSR) Standard communicated at HQ Vietnam and with tier one partners (factories).
    • Internal audits carried out at Tier One Parent Company factories yearly.
    • 3rd Party CSR Audits conducted by WETHICA for all Tier One factories on a bi-yearly basis.

Where appropriate, Company and Parent Company intend to take the following steps to combat slavery and human trafficking:

  • Continue to be vigilant when assessing areas of potential risk within Parent Company’s supply chain.
  • Put in place appropriately targeted training on the risks the business faces from modern slavery and human trafficking in its business and in its supply chains.
  • Parent Company will continue to audit their tier one suppliers going forward and improvement plans are managed.

The Company and Parent Company remain focused on maintaining the highest standards of ethical and business integrity across its business and supply chain and is committed to ensuring that its policies and processes are fit for purpose to address the risk of modern slavery and/or human trafficking occurring in our business and supply chains.

Board Approval and Signature

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 (UK) and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2020.  It has been approved by the Board of Directors and is signed below.  The statement will be reviewed for each financial year.

Signed on behalf of Osprey Europe Ltd.

Name: Jonathan Petty

Job Title: Vice President and Managing Director

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