Human Rights Policy and Responsible Supply Chain Disclosure

Business Overview

TOMS is a global footwear and lifestyle brand sold in over 30 countries. As of the end of Fiscal 2025, we employed approximately 130 people, primarily in the Americas, with additional employees in Europe and Asia.

Since our founding, TOMS has given more than $200M USD in the form of shoe donations and monetary grants to nonprofits across the globe, impacting over 105 million lives along the way. As a Certified B Corporation, TOMS continues to use business as a true force for good, building a legacy of Better Tomorrows with every pair.

 

Our Commitment

TOMS’ mission is to use business to improve lives. We recognize that achieving this mission requires not only creating positive impact but also actively identifying, preventing, mitigating, and remediating negative impacts within our operations and value chain.

We acknowledge that global footwear and apparel supply chains inherently carry risks of harm, including forced labor, unsafe working conditions, environmental degradation, and inequitable economic outcomes. As such, TOMS commits to a responsibility-first approach, aligned with the evolving standards, which require companies to:

  • Identify and address material negative impacts, not just positive contributions
  • Demonstrate measurable improvements over time
  • Ensure accountability across the full value chain, including suppliers

This statement relates to Fiscal Year 2025 and applies to TOMS SHOES, LLC and all consolidated subsidiaries.

 

Expanding Scope: From Supplier Compliance to Value Chain Responsibility

TOMS does not own manufacturing facilities and relies on third-party suppliers.

We recognize that:

  • Responsibility extends beyond Tier 1 suppliers
  • Environmental and social impacts must be quantified and managed
  • Accountability includes business model decisions (pricing, sourcing, timelines)

We are transitioning from a compliance-based model to a performance-based ESG system that evaluates both:

  • Supplier practices
  • TOMS’ own purchasing practices and influence

 

Identification of Negative Impacts

We conduct ongoing risk assessments to identify potential and actual adverse impacts, including:

Human Rights Risks

  • Forced labor and recruitment abuses
  • Excessive working hours
  • Wage gaps vs. living wage benchmarks
  • Suppression of worker voice

Environmental Risks

  • Carbon emissions across the supply chain (Scope 1–3)
  • Water overuse and pollution
  • Waste generation and material impacts

Systemic Risks

  • Purchasing practices that may contribute to labor violations
  • Production timelines that create excessive overtime
  • Supplier financial pressure is affecting wages and safety

 

Measurement & Disclosure

TOMS is aiming to implement quantitative environmental and social performance tracking, including:

  • Scope 1, 2, and 3 greenhouse gas emissions
  • Supplier ESG scorecards (Environment, Social/labor, Governance)
  • Living wage coverage across the supply chain
  • Worker grievance resolution rates
  • Corrective Action Plan (CAP) closure rates

We commit to:

  • Annual public disclosure of ESG performance
  • Continuous improvement targets are reviewed at least every 3 years

 

Supply Chain Transparency

TOMS publicly discloses Tier 1 suppliers and is working toward:

  • Tier 2 and key material supplier mapping
  • Supplier ESG performance transparency
  • Increased traceability of raw materials

Transparency is not only a disclosure exercise; it is a tool for accountability and stakeholder engagement.

(List of Suppliers here)

 

Due Diligence & Prevention

Our due diligence framework includes:

  • Third-party audits (announced and unannounced)
  • Risk-based supplier segmentation
  • Data-driven risk intelligence tools
  • Supplier onboarding requirements and contractual enforcement
  • Annual employee and supplier training to support and identify potential risks in the supply chain

We recognize that audits alone are insufficient, and we are expanding toward:

  • Continuous monitoring
  • Worker voice integration
  • Supplier capability-building programs

 

Remediation & Corrective Action

Where negative impacts are identified, TOMS commits to:

  • Timely remediation for affected workers
  • Root cause analysis (not just issue correction)
  • Supplier improvement plans with defined timelines
  • Escalation protocols for repeated or severe violations

Examples of remediation actions include:

  • Wage reimbursement
  • Policy changes
  • Supplier training and operational improvements

Termination of suppliers is a last resort and is only used when remediation fails or violations are severe.

 

Accountability & Governance

TOMS is strengthening internal accountability through:

  • Executive-level oversight of ESG performance
  • Integration of ESG metrics into business decision-making
  • Cross-functional responsibility (sourcing, compliance, leadership)

We recognize that our own decisions influence supplier conditions, and we are working to align sourcing practices with responsible production standards.

 

Worker Voice & Grievance Mechanisms

We provide accessible grievance channels for workers and stakeholders, including anonymous reporting options.

  • We are expanding direct worker engagement tools
  • Tracking grievance resolution metrics
  • Ensuring non-retaliation and transparency

 

Continuous Improvement Commitment

TOMS commits to:

  • Regular reassessment of risks and impacts
  • Measurable year-over-year improvement
  • Alignment with evolving B Corp standards

We acknowledge that responsible supply chains require ongoing effort, transparency, and accountability, and we remain committed to continuous progress.

 

Looking Forward

TOMS will continue to evolve its practices to meet and exceed standards by:

  • Expanding supply chain traceability
  • Strengthening climate and environmental performance
  • Enhancing worker voice systems
  • Embedding ESG into core business strategy

We recognize that transparency is not an endpoint but a foundation for accountability and improvement.

 

Legal Statements

This statement is made pursuant to:

  • Section 54(1) of the UK Modern Slavery Act 2015
  • California Transparency in Supply Chains Act
  • Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211)

It constitutes the slavery and human trafficking statement for TOMS Shoes UK Limited for the financial year ending December 31, 2025.