HUMAN RIGHTS POLICY

At Ralph Lauren Corporation (“RLC” or the “Company”) we believe that business has a critical role to play in creating an equitable and sustainable future. Our mission to inspire the dream of a better life through authenticity and timeless style is grounded in a commitment to support the dignity, well-being and human rights of all those who are affected by our global operations. We are dedicated to respecting the rights of our employees, value chain workers, customers, and the communities in which RLC operates.

Beyond our commitment to respect human rights, we aim to promote diversity and inclusion across our business and in society. We want to create a culture of belonging where everyone can be their best selves and succeed, and we expect that all our business partners, factories, subcontractors, distributors, manufacturers, service providers, suppliers, and agents, as well as Company employees uphold this commitment and treat each other and anyone they interact with in their workplace with respect and dignity.

COMMITMENT TO RESPECT HUMAN RIGHTS

We are participants in the United Nations Global Compact. We fully recognize and restate our commitment to all of its principles. We are further committed to respecting the UN Guiding Principles on Business and Human Rights (“UNGP”) and the OECD Guidelines for Multinational Enterprises.

We developed our human rights policy to align with principles set forth in the UNGP and the OECD Guidelines. A cross-functional team at RLC contributed to the policy’s development, in addition to external human rights professionals whose input and expert guidance we sought.

We acknowledge our responsibility as a company and commit to respect all internationally recognized human rights as articulated in the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the International Labor Organization’s (“ILO”) Declaration on Fundamental Principles and Rights at Work. The ILO Declaration articulates five fundamental principles to which we are committed, including respect for freedom of association and the effective recognition of the right to collective bargaining, the right not to be subject to forced labor, child labor, or discrimination in respect of employment and occupation, and the right to a safe and healthy working environment.

We recognize the importance of collaboration in identifying, preventing, and remedying adverse human rights impacts in our global operations, and we work with a wide range of stakeholders to attempt to achieve positive impact for those who may be directly or indirectly impacted. We further recognize the interdependence between human rights and environmental protection. More information on our initiatives and general approach to human rights can be found on our Global Citizenship and Sustainability webpage.

IMPLEMENTATION OF OUR COMMITMENT

Our human rights policy applies to all those affected by our operations: employees, individual independent contractors, value chain workers, the communities in which we operate, and the customers we serve. We implement this policy through human rights due diligence. We regularly conduct risk assessments to identify where and how risk is evolving in our own operations and value chain. We leverage the outcomes of our risk assessment to identify salient risks and prioritize the most severe risks to people based on the scale, scope and remediablity of the harm. The most severe risks are prioritized, and mitigation measures are tailored to the specific risks and set forth through a strategic action plan. Such measures may include on-site assessments or deep dive investigations.

Employees

We are dedicated to respecting the rights of our employees by providing a safe, comfortable and consciously inclusive work environment. We established the Global People Practices (“GPP”) department to ensure the Company implements policies and practices that respect human rights and that employees have a safe and impartial place to bring their concerns regarding workplace policies or practices. Our Fair Treatment Policy requires that employees be able to work in an inclusive environment free from harassment, discrimination, and retaliation. We conduct mandatory training for employees on this policy. Our Fair Treatment Policy extends to everyone who intersects with our brand, including third parties and customers. Furthermore, our Code of Business Conduct and Ethics sets forth our expectation that all employees, officers, and directors of RLC or any of its subsidiaries treat others with respect and dignity consistent with our core values.

Providing and maintaining a safe work environment for employees is a top priority for us. Our Global Health and Safety team ensures a safe and healthy work environment for all RLC employees, customers, contractors, and visitors. This is done by implementing health and safety management systems designed to identify, mitigate, and minimize risks, ensure compliance, and drive continuous improvement. 

The diversity of our people and our culture of inclusivity—from our retail employees to our executives to our business partners— is a core part of who we are. It is embedded in our brand and how we approach recruitment, work with key business partners, and present the dream of a better life to our customers. We are committed to uniting and inspiring the people within our Company as well as those communities in which we serve by amplifying voices and perspectives to create a culture of belonging and ensure inclusion, equality, and fairness for all.

Value Chain Workers and Communities

We are committed to conducting our global operations ethically and with respect for the dignity of all people who make our products. All our business partners (e.g., suppliers, licensees, and agents) are expected to uphold this commitment to respect human rights and follow all applicable policies, including our Operating Standards. These standards require business partners to foster a safe, sustainable, inclusive, and ethical workplace through continuous improvement. Further, our Vendor Compliance Packet (“VCP”), an agreement which suppliers must sign to conduct business with RLC, requires that in the event of any termination, the vendor shall consider potential human rights impacts and employ commercially reasonable efforts to avoid or mitigate such impacts.

Our Global Citizenship team monitors the compliance of our business partners as part of our due diligence processes of identification, mitigation, and remediation. We carry out due diligence on salient human rights risks in our sector, such as child labor, forced labor, sexual harassment and gender-based violence, occupational health and safety, wages, and freedom of association and collective bargaining. If we find that any facility, anywhere in the world, is not acting in accordance with our Operating Standards, we take appropriate remedial and disciplinary action or, where appropriate, we cease our business relationship.

We are further aware that human rights risks may disproportionately impact vulnerable groups, such as migrant workers, women, homeworkers, contract workers, subcontractors, and various marginalized groups who are more likely to be subject to discriminatory treatment. We have therefore developed tailored policies to address their particular needs, such as our Foreign Migrant Worker Standards. 

We recognize our responsibility to consider the impacts of our purchasing practices. Our commitment is embodied in our approach to responsible purchasing, which is embedded in our practices and procedures. Part of this approach includes our commitment to responsible exit from suppliers who make RLC products, as outlined in our Responsible Exit Process.

Customers

We aim to ensure that our customers have an inclusionary shopping experience free from harassment or discrimination, including the practice of profiling. As expressed in our Fair Treatment Policy, we are committed to providing welcoming spaces for everyone and maintaining a safe environment for all people. Our employees receive respect and inclusion training. If anyone believes that there has been a violation of our policies, the Fair Treatment Policy provides mechanisms to report such concerns. 

HUMAN RIGHTS DEFENDERS

Human rights defenders (“HRDs”) play a crucial role in providing information that helps bring human rights risks to the forefront. We recognize the threats that HRDs face around the world in their efforts to promote and protect human rights. We strongly condemn any attacks (both physical and legal), threats, intimidation, retaliation or harassment of HRDs, and expect our suppliers and business partners to likewise not contribute to or tolerate any such actions. We welcome engagement with HRDs to create safe and enabling environments for social dialogue and human rights.

Commitment to Effective Remedy

We are committed to hearing and addressing all complaints related to our global operations. We developed the RL Hotline, a confidential reporting system that is available to anyone inside or outside our Company, to facilitate the receipt and handling of complaints regarding suspected violations of Company policy or applicable laws and regulations. Complaints can be filed anonymously, and we have a strict non-retaliation policy in place.  

In addition, our employees can address concerns about a safe and comfortable work environment through our open communication policy. This policy provides an employee who wishes to express their concerns, opinions, or suggestions, with an open door and an attentive listener. Moreover, an employee can use our formal complaint procedure to report discrimination, harassment, and/or retaliation. The Company will follow up on the complaint by conducting a prompt, thorough, and objective investigation, appropriate to the circumstances. Upon completion of the investigation, if necessary and supported by the facts, remedial action will be taken against the individual who is the subject of a complaint.

Our suppliers are required to have their own effective grievance mechanisms in place to support their workers’ rights to raise grievances anonymously, confidentially, and without fear of retaliation. We also provide a process of escalation for workers to file grievances with us directly and track appropriate follow-up. Suppliers must maintain policies, processes, and training for grievance procedures and ensure a timely response for complainants. We monitor compliance through on-going review by the Company and our third-party auditors and provide training on effective grievance mechanisms to both management and workers. 

WWhen breaches to our policies are identified, we are committed to addressing them within our own internal procedures, or to working with our business partners to support their efforts to provide a remedy and improve working conditions at their own facilities. This support may involve contributing relevant resources or capabilities, including training, one-on-one coaching, and consultation, where appropriate.

GOVERNANCE STRUCTURE

Our CEO and Board of Directors endorse this human rights policy. While respect for human rights is the responsibility of all of us at RLC, executive oversight and accountability for the implementation of this policy rests with our Chief People Officer and Chief Global Impact and Communications Officer. They are supported in the implementation of our human rights’ due diligence by our internal teams including the Global People Practices, Global Health and Safety, Diversity and Inclusion, and Global Citizenship teams. The Nominating, Governance, Citizenship and Sustainability Committee of the Company’s Board of Directors oversees implementation of this policy at the board level. The committee meets at least four times a year to review aspects of the programs, policies and practices relating to corporate citizenship, sustainability, and social and environmental risks and impacts.

ONGOING REVIEW AND COMMUNICATION

Our human rights policy is regularly reviewed by internal and external experts and then updated as necessary, as we learn more about the actual and potential adverse impacts in our operations and extended value chains.

This policy is publicly available on our corporate website, on our NAVEX hotline site, and is included in our Employee Handbooks.

It is electronically disseminated to our employees and direct value chain partners, as are any updates.

Disclaimer

This policy is effective as of March 26, 2021. RLC policies comply with applicable national and international laws, which supplement and may take precedence on such policies. We reserve the right to update this policy at any time. 

Last updated: February 6, 2024