Structure

Founded in 1910, RAA is a leading men’s and women’s apparel and accessories business. We operate in the apparel and accessories wholesale and retail trade industries through our group of companies, which include Randa, Haggar Canada, and Tribal.

Randa

Randa was formed on April 9, 2001, under the laws of the State of Delaware and is headquartered in New York, New York, USA. Randa exercises direct control over its wholly owned subsidiaries, each of which is organized under the laws of the respective jurisdictions where those entities are formed or incorporated, including Haggar Canada and its Tribal division.

Haggar Canada and Tribal

Haggar Canada was incorporated on August 17, 1999, under the laws of the Province of Nova Scotia and is headquartered in Toronto, Ontario, Canada. Tribal is a division of Haggar Canada as the result of the
amalgamation of Haggar Canada, Tribal Sportswear Holdings Inc. and Tribal Group Holdings Inc., under Haggar Canada Co. and registered on November 27, 2013, under the Corporations Registration Act of Nova Scotia.

Activities and Supply Chains

RAA sources raw materials and trim for our apparel and accessories products, which include belts, small leather goods, neckwear, tops, bottoms, dresses, suits and tailored clothing, swimwear, and seasonal accessories including footwear, hats, gloves, and gift, from suppliers in Guatemala, Taiwan, China, India, Dominican Republic, Bangladesh, Vietnam, and Cambodia. We engage factories in Guatemala, Taiwan, China, India, Bangladesh, Philippines, Vietnam, and Cambodia to manufacture and produce finished goods from the sourced materials.

Our supply chain process includes: PLANNING (plan is developed to manage resources, meet customer demand, reduce costs, and minimize waste); SOURCING (raw materials and components are sourced from suppliers to create our products); MANUFACTURING (factories are engaged to develop finished products from the sourced raw materials); TESTING (products are tested to applicable industry and regulatory standards); PACKAGING (product is packaged for shipment or storage in inventory); SHIPPING (finished, packaged products are shipped to our locations in Canada and the US); DELIVERY/DISTRIBUTION (finished, packaged products are moved from storage, transported, and delivered to our US and Canadian customers, which include retailers, distributors, and consumers).

Steps Taken to Prevent and Reduce Risks of Forced Labour and Child Labour

We are committed to treating people with dignity, fairness, and respect. Our policies for associates and suppliers, including codes of social responsibility, reflect these principles and prohibit forced and child labour. We act to prevent and reduce the risk of forced labour and child labour through proactive internal compliance systems developed to manage a large, global supply base and proactively identify and mitigate against forced labour and child labour in its supply chains. RAA works closely with key brands, wholesalers, and retailers to weave and enforce social compliance efforts throughout its supply chain. In 2023, RAA took the following steps to prevent and reduce the risk that forced labour or child labour is used in its supply chains:

  • Mapping, monitoring, and auditing manufacturing and supply chain activities and supply chains.
  • Conducting an internal assessment of risks of forced and child labour in activities and supply chains, including gathering information on worker recruitment, and maintaining internal controls to ensure that all workers are recruited voluntarily.
  • Addressing practices in activities and supply chains that increase the risk of forced and child labour.
  • Contracting with auditors for an external assessment of risks of forced labour and child labour in our activities and supply chains.
  • Developing and implementing due diligence policies and processes for identifying, addressing, and prohibiting the use of forced labour and child labour in our activities and supply chains and implementing our action plan for addressing forced and child labour risks.
  • Carrying out prioritization exercises to focus due diligence efforts on the most severe risks of forced and child labour.
  • Requiring our suppliers to adopt and follow policies and procedures to identify and prohibit the use of forced labour and child labour in RAA activities and supply chains.
  • Developing and implementing child protection policies and processes, anti-forced labour and antichild labour contractual clauses, and standards, codes of conduct, and compliance checklists.
  • Enacting measures to provide for, or cooperate in, remediation of forced labour and child labour.
  • Developing and implementing grievance mechanisms, training and awareness materials, and procedures to track performance in addressing forced labour and/or child labour.
  • Engaging with supply chain partners, civil society groups, experts, and other stakeholders on the issue of addressing forced labour and child labour and with workers and families potentially affected by forced labour and child labour to assess and address risks.

Policies and Due Diligence Processes

For the 2023 reporting year, we sought to understand and identify forced and child labour risks in the apparel and accessories industry and in the supply chains and manufacturers RAA utilizes. We will continue to strive to identify emerging risks. To address these risks, we have embedded responsible business conduct into our due diligence, policies and procedures, and our management system. We continually strive to identify adverse impacts in operations, supply chains, and business relationships and act to prevent or mitigate adverse impacts, track implementation of our policies and procedures and related results and communicate how any matters of forced or child labour are addressed. Our policies and procedures provide for cooperating in remediation when appropriate.

RAA is aware that third-party offshore apparel and accessories suppliers and manufacturers in our industry present risk of forced and child labour. We’ve mitigated against this risk through a proactive social compliance management approach that includes:

  • Establishing a compliance culture in the US and abroad. RAA educates its associates and teams to understand that compliance is part of the production process. Compliance is integrated into onboarding, education and training, quarterly reporting, choosing of suppliers, and purchase order approvals.
  • Vetting potential suppliers for social and labour compliance before production begins and then regularly auditing suppliers. All RAA suppliers are subject to internal auditing and, when necessary, compliance coaching.
  • Training to reinforce compliant behaviors with suppliers. RAA addresses industry issues and labour risks through proactive training (compliance, health and safety, chemical management, wage, labour, and working hours, and implementation of corrective actions when necessary) across the supplier base.
  • Capturing and monitoring supplier performance data. By harnessing data, RAA can foresee trends and patterns in advance and take proactive steps towards correcting and resolving for potential issues.

RAA believes that building a socially responsible supplier base begins with a pre-audit of prospective suppliers before they are engaged to make or produce goods for RAA. The RAA pre-audit consists of inquiry into 12 performance areas: Ethical Standards, Legal Standards, Environmental Standards, Community Involvement, Employment Standards, Wages and Benefits, Working Hours, Child Labor, Prison/Forced Labor, Health and Safety, Discrimination, and Disciplinary Practices. RAA’s team focuses on pre-audit results, remediation, and compliance tutelage/capacity building based on the SLCP Audit Standards. Using pre-audit scores and tracking results of suppliers over time, RAA can monitor performance to standards and identify areas of labour and social risk.

Risk of Forced Labour and Child Labour in Activities and/or Supply Chains

RAA proactively mitigates against risk and encourages improved supplier social performance. RAA teams in the United States, Guatemala, China, India, Bangladesh, and Cambodia lead compliance and are responsible for day-to-day interaction with brands, wholesalers, retailers, suppliers, and RAA teams incountry. RAA’s in-country teams maintain close, on-site relationships with the supplier base, and are responsible for internal audits, compliance program education and execution, supplier corrective actions, and coaching RAA’s suppliers through the compliance process.

RAA is a signatory of the Social Labour Convergence Project (SLCP). SLCP seeks to implement the first industry-wide framework to assess social and labour conditions. This framework includes tools and methodologies that collect objective data that can be used to identify opportunities for social and labour improvement and track progress. All RAA suppliers are required to complete the SLCP assessment.

Remediation of Forced Labour and Child Labour in Activities and/or Supply Chains

RAA was not required to take Remediation Measures, so we were not required to remediate any loss of income to the most vulnerable families as a result of any Remediation Measures.It is our policy to act in support of victims of forced labour or child labour and their families through workforce reintegration, psychosocial support, measures to prevent reoccurrence of labour issues, and grievance mechanisms. We continue to monitor and assess our practices for any gaps in responding to identified labour risks.

Remediation of Loss of Income in Most Vulnerable Families

RAA was not required to take Remediation Measures, so we were not required to remediate any loss of income to the most vulnerable families as a result of any Remediation Measures.

Training on Forced Labour and Child Labour

RAA trains its associates and management on social responsibility, including forced labour and child labour issues. The training is mandatory for RAA compliance teams and is available to other RAA associates and managers, including those who develop products and those who select and work with factories, mills, and other suppliers in our supply chains.

Assessing Effectiveness of Forced Labour and Child Labour Prevention Mechanisms

RAA employs policies and procedures to assess its effectiveness in ensuring that forced labour and child labour are not used in its activities and supply chains. We also regularly review our policies and procedures related to forced labour and child labour, partner with an external organization to conduct an independent review of our policies and actions, and work with our suppliers to measure the effectiveness of their actions and track relevant performance indicators.

Attestation

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have
reviewed the information contained in the Report for Randa Accessories Leather Goods LLC, Haggar
Canada Co., and Tribal Sportswear. Based on my knowledge, and having exercised reasonable diligence,
I attest that the information in the Reportt is true, accurate, and complete in all material respects for the purposes of the Act, for the Reporting Year.

Jay K. Patel

Chief Financial Officer

May 31, 2024

I have the authority to bind Randa Accessories Leather Goods LLC and its subsidiaries.

Approved by Randa Accessories Leather Goods LLC this 31st day of May, 2024.