UK MODERN SLAVERY ACT - SPECIALIZED DISCLOSURE

This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, sets out the approach taken by Specialized Bicycle Components (SBC) and Specialized UK Ltd. (SBC UK) to understand all potential modern slavery risks related to its business, and the actions undertaken to mitigate any such risks during the financial year ended 31 March 2017.

Specialized Bicycle Components (SBC) and Specialized UK Ltd. (SBC UK) is committed to upholding human and labour rights, ensuring that every worker has safe and fair working conditions and that there is 'zero tolerance' for human trafficking and slavery in our supply chain.

The policies, procedures and operations outlined in our Sustainable Innovation Program incorporate explicit prohibition of human trafficking and slavery and addresses issues of human trafficking and slavery required under the UK Modern Slavery Act, as well as addressing other issues of social and environmental sustainability. Standards for workplace conditions for our supply chain partners are outlined in our Code of Conduct and the code element Forced Labour specifically calls out our commitment to prohibiting human trafficking and slavery anywhere in our direct and indirect supply chain.

SBC is a founding member of the Responsible Sports Initiative (RSI) under the World Federation of Sporting Goods Industries (WFSGI). The goal of this collaboration is to address labour and environmental standards throughout our shared supply chains, and promote the adoption of these principles more broadly throughout the bicycle industry. The RSI has adopted labour standards, auditing protocol and a shared database of audit results via the Fair Factories Clearinghouse (FFC). Our Code of Conduct is based on the International Labour Organization (ILO) code and states that any form of forced labour, which includes human trafficking, slavery and child labour are prohibited in our supply chain.

The processes in place to prevent human trafficking within SBC’s supply chain consist of the following key steps:



  1. Evaluation of prospective suppliers.

    SBC's Corporate Social Responsibility (CSR) staff evaluates potential suppliers on a variety of criteria, including their willingness and ability to comply with our Code of Conduct, including its provisions against human trafficking. Prospective suppliers who do not meet our standards, including the requirement to ensure compliance in their own supply chains, are not approved.



  2. Monitoring of approved suppliers.

    Approved suppliers are evaluated for risk, including risk of human trafficking. Depending on the risk, a vendor may receive further scrutiny, including an evaluation by SBC staff or a third-party auditor.
    Human trafficking is a zero-tolerance finding in SBC’s CSR protocol. Any zero-tolerance finding requires immediate corrective action and a follow up verification audit.

    Specialized’s Corporate Social Responsibility team engages directly with all suppliers who are nominated by Specialized or with whom we make direct investments in tooling and development. Our Code of Conduct specifies that these suppliers are responsible for ensuring compliance with our Code at subsequent tiers of the supply chain. To help accomplish this, specialized provides training and resources to assist suppliers in developing the capacity to identify and address issues of non-compliance in their supply chains. Our goal is to build capacity with our suppliers so that they may monitor their own suppliers and work to eliminate instances of human trafficking and slavery in their supply chains.



  3. Training Specialized staff

    In order to advance the elements of our Code of Conduct, Specialized relies on an extensive network of Quality and Engineering staff who work closely with our suppliers. To assist these staff in this task, Specialized conducts training on CSR principles, including human trafficking. Furthermore, SBC has procedures in place for internal staff to report CSR concerns for further investigation.

    SBC’s CSR staff engages in continuous education on the topic of modern slavery in order to inform the continuous improvement of policies and procedures intended to end human trafficking in our supply chains.



  4. This statement is made on behalf of the board of directors of Specialized Bicycle Corporation