ii. OECD Guidance Step Two: Identify and Assess Risk in the Supply Chain
The Covered Suppliers were asked by email to complete a questionnaire to determine whether they were
in-scope. The Service Provider then requested by email that the in-scope Covered Suppliers provide us with a completed CMRT. The Service Provider followed up by email or
phone with Covered Suppliers that did not respond to the request within a specified time frame. If, after the foregoing efforts, a Covered Supplier did not provide the information requested, an escalation process was initiated. The escalation
process consisted of direct outreach by our personnel to the Covered Supplier. Responses were received from 100% of the Covered Suppliers.
The Service Provider reviewed the responses received from the Covered Suppliers based on its internally-developed written review criteria for
plausibility, consistency, and gaps. As part of that review, if a Covered Supplier indicated that there were no 3TG in the products or materials that it supplied to us, the Service Provider reviewed those responses for plausibility and Covered
Suppliers were also given an opportunity to provide a certification of that determination. If any of seven different quality control flags were raised by the response, the Covered Suppliers were contacted by the Service Provider.
In addition to the Service Providers review, VFs internal sourcing group performed an internal quality check for plausibility of
responses. The internal sourcing group also evaluated the level of risk presented by each Covered Supplier, based on the amounts purchased from and the nature of the relationship with the supplier. Further outreach efforts were then prioritized
according to the level of risk, to better ensure that we appropriately allocated our internal resources to focus on the most relevant Covered Suppliers. An additional verification step was added to validate responses from the top 10% of Covered
Suppliers, based on product value and volume, that responded that their products or materials did not contain 3TG. This was in addition to the response validation performed by the Service Provider.
The Service Provider reviewed the smelters and refiners identified by the Covered Suppliers against those contained in its internal database.
To the extent not in that database, it requested that the Covered Supplier provide further clarification.
With respect to a completed
response that identified a smelter or refiner, the Service Provider also compared that information against the lists of Conformant and Active (as defined below), or the equivalent, smelters and refiners published by the RMI, the London Bullion
Market Association (LBMA) and the Responsible Jewellery Council (RJC). The smelters and refiners identified by the Covered Suppliers as potentially having processed 3TG contained in our
in-scope products were listed as Conformant.
If a Covered Supplier does not provide information
concerning the processors of 3TG in their supply chain, the Service Provider requests information on the Covered Suppliers suppliers. These suppliers, and subsequent tiers of suppliers as identified to the Service Provider, are then contacted
by the Service Provider.
iii. OECD Guidance Step Three: Design and Implement a Strategy to Respond to Identified Risks
VFs implementation team provides bi-weekly updates to senior management and other key internal
stakeholders on the progress of due diligence, supplier responsiveness and any identified risks. We address any identified risks on a case-by-case basis. This flexible
approach enables us to tailor the response to the risks identified. Depending upon the identified risk, we may cease doing business with the supplier, suspend business or require the supplier to commit to a corrective action plan.
To ensure suppliers understand and meet our expectations, we regularly communicate information and guidance regarding our Program through a
number of channels, including an online supplier education portal and direct communication from our sourcing hubs in Asia, Europe and North America.
We also took the measures identified elsewhere in this report to mitigate the risk that 3TG in our products benefit armed groups in the Covered
Countries.
iv. OECD Guidance Step Four: Carry out Independent Third-party Audit of Supply Chain Due Diligence at Identified
Points in the Supply Chain
We do not have a direct relationship with 3TG smelters or refiners and, therefore, do not perform direct
audits of these entities within our supply chain. Instead, in connection with our due diligence, for the identified smelters and refiners, the Service Provider consulted information concerning independent third-party audits of smelters and refiners
made available by the RMI, the LBMA and the RJC. We utilize and rely on this information to assess smelter and refiner due diligence and to determine whether the smelter or refiner is Conformant with an applicable third-party conflict free
certification.
v. OECD Guidance Step Five: Report on Supply Chain Due Diligence
VFs Form SD and Conflict Minerals Report are annually filed and are publicly available on our website. We also publish a sustainability
report, which contains information on responsible sourcing, and other responsible sourcing information, on our website. In addition, we regularly publish a list of our Tier-1 and nominated Tier-2 factories on our website.