Section 54 Statement

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Modern Slavery Act Transparency Statement

Modern Slavery Act Transparency Statement

The following statement is made in response to Section 54 of the Modern Slavery Act in order to highlight the steps the Triumph Group is taking to prevent modern slavery and human trafficking in its business and supply chain.

About Triumph Group

Triumph Group, one of the world´s leading intimate apparel companies, has been founded in Germany 130 years ago. Today, it is headquartered in Bad Zurzach (Switzerland) and continues to be a fully privately owned company. Triumph possesses subsidiaries around the world and covers all activities of its value chain from design to selling. Such a long period of success is only possible with a keen sense for fashion and excellent insights into the desires and needs of our consumers as well as with caring and engaging approach to its employees and stakeholders. Beautiful designs, advanced textile engineering and unparalleled innovative power have always been achieved with an experienced and motivated community of employees around the world. For over a century, Triumph continuously strived to recruit new talent, offering them one of the textile industry’s most international working environments, excellent conditions and great development opportunities in an ever evolving company.

We manufacture in socially compliant and high tech production facilities, many of them owned and operated directly by us, using environmentally friendly and energy-saving production methods and the most modern and skin-friendly material. We are also a member of the Business Social Compliance Initiative (BSCI).

Triumph’s Commitment to its Social Responsibility

We firmly believe that as a corporation we have a responsibility towards what we affect with our actions that goes beyond delivering business goals. In everything we do, we act according to our corporate values of passion, respect, trust, openness and consistency.

In our endeavor for sustainable and profitable growth we are committed to conduct our global business legally compliant and in a responsible and sustainable manner that is ethically sound and focused on the welfare of our people, our communities, our stakeholders and the natural environment.
 
In the pursuit of this commitment, our actions are led by

·  Responsibility to include stakeholder interests in the decision-making and to ensure that good and ethical practices are observed.

·  Sustainability for future generations by creating economic and social opportunities for all employees and communities while preserving the natural environment.

Through solid governance and compliance standards we ensure that we apply this commitment and manage risks.

Our Business and Supply Chain

Many of our products are manufactured in our own manufacturing facilities and the rest is being produced by trusted and reliable partners with whom we’ve typically collaborated for several years. Our third party finished goods are continuously evaluated on various criteria including compliance. We expect our suppliers to comply with legal requirements as well as environmental and social standards and our Code of Conduct.

Triumph’s Policies

We at Triumph are committed to conduct our business in a legal, responsible and sustainable manner that is ethically sound and concerned with the welfare of our people, communities, our stakeholder and the natural environment. Our Policy Framework sets the context within which we wish to sustain our successful business. It contains the principles and rules of corporate conduct to guide behavior both within and outside of our company.

Social Compliance Policy:

Our Social Compliance Policy policy was rolled out in April 2012 in order to increase visibility, transparency and risk manageability for Finished Good Suppliers by providing a single and structured approach to identify, evaluate and if necessary disqualify suppliers.

We have implemented governance and compliance standards to uphold our commitment accordingly. Simultaneously, Triumph joined BSCI in 2012 in order to drive sustainable improvement of labor and workplace conditions by adhering to both our own Code of Conduct as well as BSCI’s Code of Conduct, which includes prevention of servitude, forced, bonded, indentured, trafficked or non-voluntary labor.

Business Ethics Guidelines:

Our values, principles and codes of conduct ensure that expectations around ethical behaviors are clear, monitored and that specific corrective actions are implemented in case of any violations.

For more detailed information please visit: http://www.triumph.com/uk/en/7753.html

We have set up an integrity hotline (integrity@triumph.com), which is an independent and confidential channel for receiving information relating to improper business conduct and open to both Triumph employees as well as third parties. Moreover, a solid partnership with our social partners as well as regular mutual feedback further reinforces this as well.

Due Diligence and Monitoring of our Suppliers

As specified in our Social Compliance Policy, every single finished good factory producing for the Triumph Group needs to be evaluated and approved by the Social Compliance Department before any orders can be placed. The decision on whether or not to engage with a new factory depends on a preliminary independent compliance audit based on BSCI principles and if necessary some additional verification based on the perceived risk. If critical issues are identified, no orders can be placed.

Once on-boarded, all our factories, including our own manufacturing facilities are being audited on a regular basis according to BSCI.

Risk Assessment

When entering new sourcing channels, we will follow an even more stringent due diligence process. In addition to our independent social compliance audits we will consult with local stakeholders and conduct preliminary assessment visits in order to evaluate their compliance. Only if we deem them compliant we will begin placing orders. Moreover, we will continue to visit these factories in these countries more frequently in order to promote ethical business practices and policies ensuring that workers are not being abused or exploited. Based on our assessment, we identified unauthorized sub-contracting as a potential risk area. Hence, we strictly prohibit unauthorized sub-contracting and require that any subcontracted finished good factory needs to be approved before orders can be placed or moved.

Performance Indicator

Every finished good factory receives a rating indicating their level of compliance. While our focus lies on continuous improvement we will downgrade and/or disengage from factories that don’t comply or don’t improve their compliance within a given timeframe.

Training

At Triumph, our employees are introduced to our Codes of Conduct and trained on our values and principles and asked to familiarize themselves with our corporate policies. The way we behave and work is also integrated into our annual appraisal process for all white collars and managers.

On the other hand, every finished good factory is introduced to our Codes of Conduct. Factories that are in the BSCI system are further expected to cascade BSCI’s Code of Conduct down their supply chain to further drive awareness beyond the first tier. We also encourage our factories to partake in one of the many BSCI workshops to further reinforce BSCI’s Code of Conduct.

Markus Spiesshofer

Oliver Spiesshofer

Roman Braun