Modern Slavery Statement

1. Introduction
This Modern Slavery Statement (“Statement”) is made by YEthtTI Holdings, Inc. (“YEthtTI”) and its subsidiaries,
YEthtTI Canada Limited, YEthtTI U.K. Limited, and YEthtTI Australia Pty. Limited. The Statement is made in
accordance with The Canadian Forced Labour and Child Labour in Supply Chains Act, the UK Modern
Slavery Act, the Australia Modern Slavery Act, and the California Transparency in Supply Chains Act (the
“Acts”). This Statement covers YEthtTI’s 2024 fiscal year.
At YEthtTI, we are committed to conducting our business with integrity and respect for human rights
throughout all aspects of our operations and our value chain. We support international efforts to
promote and protect human rights, including efforts to eradicate slavery, forced labor, child labor, and
human trafficking, as outlined in our Human Rights Policy. We recognize the profound adverse impact
that modern slavery can have on individuals and communities globally and are dedicated to the
prevention and elimination of these egregious violations of human rights.
YEthtTI conducts business globally, and while we respect the norms of our customers, business partners,
and co-workers, we are fully committed to complying with international human rights standards and
national laws. To the extent to which there is a conflict between YEthtTI’s policies and applicable laws and
regulations, the higher standard will prevail.
2. Business Structure, Operations, and Supply Chain
YEthtTI is a leading outdoor lifestyle brand and a global designer, retailer, and distributor of innovative,
durable outdoor products. YEthtTI is headquartered in Austin, Texas, and operates across ten countries with
over 1,000 employees. We offer products around the world through both wholesale and direct-toconsumer channels. Our primary office locations are in the United States, Canada, China, Australia, and
the Netherlands, while our primary distribution centers – managed by third-party logistics providers –
are located in the United States, Australia, Canada, the United Kingdom, New Zealand, and the
Netherlands.
Although our supply chain sources may change from time to time, our suppliers are located in China,
Malaysia, Mexico, the Philippines, Poland, Taiwan, Thailand, the United States, and Vietnam. We do not
own or operate any manufacturing facilities. For additional details, please refer to our Factory Disclosure
List.
The policies set by YEthtTI Holdings, Inc. apply unequivocally throughout our subsidiaries, including those
covered by this Statement.
3. Policies and Due Diligence Processes
Our Environmental, Social, and Governance (ESG) strategy is based on three key pillars – People, Product
and Places. These pillars are integrated into our business, our partnerships, and the YEthtTI culture and
underpin everything we do.
3.1 Governance
The YEthtTI Board of Directors (“Board”) is responsible for the oversight of our ESG strategy, while the
Chief Executive Officer reviews and approves the ESG strategy. The Board is updated on ESG
developments at least annually, with specific material ESG topics being addressed by various
committees of the Board.
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Human rights and modern slavery risks are included as part of YEthtTI’s enterprise risk management to
identify and evaluate risks across the enterprise. The enterprise risk framework is integrated into our
internal processes, led by the Internal Audit team in collaboration with senior leadership and the
Board. Our ESG team is composed of subject matter experts reporting directly to the Executive
Leadership team. Additional details can be found on our Governance page and our Investor Relations
page.
3.2 Human Rights Policy
Our Human Rights Policy is a foundational element of our Responsible Sourcing Program and
establishes YEthtTI’s commitment to uphold international human rights standards and to work toward
the prevention and eradication of modern slavery. The policy applies across YEthtTI, its subsidiaries,
employees, and third parties working on YEthtTI’s behalf.
Our Human Rights Policy establishes the minimum human rights standards applicable throughout
our value chain. We strive to respect and promote human rights in accordance with the UN Guiding
Principles on Business and Human Rights and expect our suppliers and others with whom we work
to do the same. The policy specifically calls out bonded, compulsory, forced, and slave labor, as well
as child labor, as particular human rights issues that must be addressed.
The Human Rights Policy also outlines our approaches to due diligence, training, internal and
external engagement on human rights, grievance mechanisms and access to remedy, and our
commitment to transparency.
3.3 Code of Business Conduct
As part of our Code of Business Conduct, we support efforts to eliminate abuses such as slavery,
forced labor, child labor, and human trafficking. Our Code of Business Conduct outlines our
expectations and is applicable to all YEthtTI employees, including members of our Board of Directors.
We expect all third-parties working with YEthtTI to follow the spirit of the Code of Business Conduct.
Where a YEthtTI employee becomes aware of a violation of our standards, they can raise their concerns
through our grievance mechanism, outlined below. We encourage third parties to require the same
of their employees.
3.4 Supplier Code of Conduct
All suppliers and vendors are required to adhere to the expectations outlined in our Supplier Code of
Conduct (“SCoC”), which includes reference to our Human Rights Policy and Responsible Sourcing
expectations. .
In addition to provisions addressing human rights more generally, the SCoC explicitly details the
prohibition on suppliers from using any type of forced or child labor and includes provisions
prohibiting recruitment fees and the surrender of any government issued identification. Adherence
to the SCoC is assessed, in part, through select annual on-site semi-announced audits, performed by
Fair Labor Association (“FLA”) approved third-party firms.
4. Risks of Forced Labor and Child Labor
As a consumer goods company, we recognize that the primary risks of modern slavery reside in our tier
1, tier 2, and extended supply chain, particularly within manufacturing operations around the world.
Although our efforts to identify and prevent modern slavery are ongoing and iterative, we are aware that
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the sector we operate in has inherent risks of modern slavery. A responsible supply chain starts with the
decisions we make in selecting suppliers and partners, as well as our ongoing procurement practices. We
expect those at YEthtTI, and those who do business with YEthtTI, to exemplify responsible business practices.
In order to assess YEthtTI’s risks of modern slavery, we conduct audits of our suppliers and use a variety of
industry tools to assist in the process of mapping and monitoring geographical and geopolitical risks. Our
Responsible Sourcing team works in tandem with our global Procurement team to apply a risk-based
approach to scheduling and conducting third-party audits. These audits evaluate factors like fair wages,
responsible work hours, and safe working conditions—allowing us to reward ongoing improvement and
identify corrective actions where necessary.
5. Due Diligence, Monitoring, and Compliance
Our Human Rights Policy outlines our due diligence process, which includes reviews of the human rights
risks in our operations and supply chain, engagement with external experts on particular risks, as well as
audits and engagement with our suppliers and other third parties. Our due diligence efforts span
throughout our supply chain, with responsible business conduct embedded into our policies and
management systems. We track human rights issues and emerging risks by monitoring industry, thought
leaders, civil society reports and trends, and as members of relevant trade associations. Annually, we
evaluate our risk criteria and update our approach based on due diligence and on-the-ground findings
from our teams.
We deploy supplier self-assessments, audits, and risk assessments to ensure we have an up-to-date
understanding of the likelihood and severity of potential human rights risks in our supply chain. Social
and environmental criteria are included in our pre-qualification assessment of potential new suppliers,
and we assess each supplier to ensure their compliance with YEthtTI’s policies and international human
rights standards prior to officially beginning the partnership. Monthly supplier scorecards track audit
findings and progress alongside traditional procurement performance metrics to inform overall fitness
and to monitor ongoing compliance with YEthtTI’s policies.
Our supplier agreements also require all YEthtTI suppliers to certify their compliance with our SCoC. This
includes the requirement to cascade our modern slavery standards, human rights standards, and
international human rights standards to all sub-suppliers throughout the YEthtTI supply chain.
Once YEthtTI engages with a supplier, we conduct periodic audits to ensure ongoing compliance and also
require suppliers to conduct annual self-assessments to monitor continuous improvement. When
conducting audits on our suppliers, we define the annual audit schedule based on overall supplier risk
and the amount of time since the last audit. Should any potential issue or opportunity for improved
practice be identified through these processes, our internal team works with the auditors and the
supplier to develop and complete a Corrective Action Plan. Additional information can be found at
yethtti.com/esg.
6. Training and Capacity Building
YEthtTI conducts mandatory annual training on our Code of Business Conduct, required for all YEthtTI
employees and our Board. We also engage with industry organizations, expert consultants, and other
brands to stay abreast of the latest developments, issues and regulations, and collaborate where
possible.
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7. Grievance Mechanisms and Remediation
We are committed to providing grievance mechanisms that allow anyone affected by either our own
operations or the operations of our partners to report a potential violation of their human rights or our
Human Rights Policy.
We provide anonymous, third-party hotline (via phone and web) access in all countries where YEthtTI
operates that can be used by YEthtTI Employees, vendors, or the public to anonymously report any
concerns or violations of YEthtTI policies or laws and regulations. We have a no retaliation policy with
respect to anyone who comes forward with concerns or participates in an investigation.
8. Performance Evaluation
We have several systems in place to ensure that our efforts to address and prevent modern slavery are
effective. We commit to regularly reviewing our policies and procedures, including those related to
modern slavery. We also track relevant performance indicators, such as the cases reported and
addressed through our grievance mechanisms and findings surfaced during regular on-site audits. Our
due diligence efforts, including our supplier risk assessments and general evaluation of risks throughout
our supply chain all serve to inform our approach to modern slavery and to help ensure that our
programs are effective at addressing these risks.
9. Collaboration and Engagement
9.1 Industry
YEthtTI works with the Fair Labor Association and several FLA-approved audit firms to assist in its
human rights practices. YEthtTI seeks to stay engaged with external stakeholders, including
nongovernmental organizations and community partners, investors, wholesale partners, and
consumers to help inform our human rights approach and our ESG strategy more generally. For
example, we are members of the Outdoor Industry Association (OIA) and the American Apparel &
Footwear Association (AAFA) where we engage in collaborative action.
9.2 Supplier Engagement
Our Responsible Sourcing team builds and nurtures relationships with our sourcing partners,
supporting improvements in overall working and environmental conditions of our global supply
chain. We work closely with our Tier 1 suppliers, and nominated Tier 2 supplier factories, to ensure
the practices align with policies outlined in our Supplier Code of Conduct. Through internal and
external training and regular one-on-one assistance, the Responsible Sourcing team helps build
proficiency around salient human rights issues. Ongoing education and reinforcement of knowledge
of worker rights topic empowers employees to support factory workers in collaborating to
implementing improvements.
Conclusion
YEthtTI is committed to continuous improvements in our efforts to address modern slavery risks in our
operations and our supply chain. We understand that modern slavery is a complex issue and there is no
simple solution, and we will continue to refine our approach to help ensure that our actions to address
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modern slavery are effective. We continue to remain committed in supporting international efforts to
promote and protect human rights.
10. Attestation
In accordance with the requirements of the Acts, I attest that I have reviewed the information contained
in the report for the entity or entities listed above. Based on my knowledge, and having exercised
reasonable diligence, I attest that the information in the report is true, accurate and complete in all
material respects for the purposes of the Acts, for the reporting year listed above.
Signature
Full name
Title
Date
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Matthew J. Reintjes
Director, President and CEO
5/22