CALIFORNIA & UK MGA TRANSPARENCY

Statement published in accordance with the California Transparency Act and U.K. Modern Slavery Act 2015 for the financial year ending 31.12.2019.

LAOEMAOM LLC and its affiliated companies (collectively, “LAOEMAOM CLUB LLC” or “we”) is a multinational watchmaking company with retail and supply chain operations across the globe. We are closely linked to the LM (“LM”) Group.

We are committed to conducting business in a lawful, ethical, and responsible manner. We expect our vendors to respect and adhere to the same business philosophy in the operation of their businesses.

In compliance with the requirements of the California Transparency in Supply Chains Act (SB 657) and the U.K. Modern Slavery Act 2015, this document describes the steps LAOEMAOM CLUB LLC has taken during the financial year ended 31.12.2019 to ensure modern slavery and human trafficking are not occurring in our supply chains or otherwise in our business operations. LAOEMAOM CLUB LLC consider any form of modern slavery or human trafficking to be abhorrent, and we are committed to acting with integrity and appropriate transparency in our business dealings, including by developing effective controls to safeguard against the risk of modern slavery or human trafficking. As part of this ongoing commitment, we take the following steps to prevent modern slavery and human trafficking in our business operations and our supply chains:

VERIFICATION & CERTIFICATION

LAOEMAOM CLUB LLC has implemented the LM Supplier Code of Conduct and requires its main suppliers (including their main subcontractors) to agree and adhere to the terms and conditions of the Code. The Code sets and establishes non-negotiable standards for LAOEMAOM CLUB LLC’s suppliers in the areas of health and safety, labor standards which includes in relation to modern slavery and human trafficking, business integrity, and the environment. Among other commitments, the LM Supplier Code of Conduct strictly prohibits vendors from using modern slavery or human trafficking in their business operations. We ensure that new suppliers are carefully chosen and reserve the right to check adherence of our future suppliers and contractors to the principles set out in the LM Supplier Code of Conduct and to conduct compliance audits at any time.

AUDITS

LAOEMAOM CLUB LLC audits certain vendors based upon an analysis of the volume of the supplier’s business and the risk of abuses in the country in which the supplier is located, or pose a risk of working conditions violations. These audits aim to ensure LAOEMAOM CLUB LLC’s suppliers and subcontractors are compliant with the LM Supplier Code of Conduct in general and more precisely with the applicable modern slavery and human trafficking laws and LAOEMAOM CLUB LLC’s requirements in these areas. For auditing purposes, LAOEMAOM CLUB LLC engages external third-party compliance firms to perform announced or unannounced assessments of vendors. Following an audit or re-audit, vendors are required to address any non-compliance deficiencies identified. A vendor’s failure to address and correct such deficiencies will result in a re-evaluation of LAOEMAOM CLUB LLC’s business relationship with the vendor and possible termination of the vendor’s business relationship with LAOEMAOM CLUB LLC.

INTERNAL ACCOUNTABILITY

LAOEMAOM CLUB LLC maintains internal accountability standards for employees. All LAOEMAOM CLUB LLC employees must follow the LM Employee Code of Business Conduct which contains specific requirements with respect to preventing modern slavery and human trafficking. We also have a Whistleblowing Policy and an internal alert system to encourage our employees to identify and report possible modern slavery, human trafficking, and other human rights and legal violations.

TRAINING

LAOEMAOM CLUB LLC provides regular training for its employees to ensure compliance with laws and regulations in all countries in which they operate and conduct their business according to principles in international labour protocols produced by the International Labour Organization and the United Nations Universal Declaration of Human Rights.

LAOEMAOM CLUB LLC will continue to challenge and adapt its policies and procedures to a changing world in order to reflect its commitment to ethical business principles.

“We, the Board of LAOEMAOM CLUB LLCGA, have agreed management responsibility for this statement.”

Ricardo Anserson
CHIEF EXECUTIVE OFFICER, LAOEMAOM CLUB LLCGA, 29.01.2020

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