Report on fighting against forced labour and child labour in Canada
Introduction
At MillerKnoll, we are guided by our shared purpose—design for the good of humankind. This purpose reflects the desire of all our brands to leverage the power of design to improve lives, whether that is the lives of our customers, our employees, or the people in the communities where we live and work. Our conduct matters. We have a responsibility to ourselves, our customers, and our community to do the right thing.
MillerKnoll Group (as defined below) is committed to conducting its business in an ethical, legal, environmentally sustainable, and socially responsible manner. We strive to maintain an ethical work environment that promotes dignity and respect and is committed to positive labour and environmental practices in its own facilities and at the facilities of its suppliers.
This is MillerKnoll Group’s first report pursuant to Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act, and it will be reviewed annually. Our reporting outlines the measures we have in place and the efforts we have commenced to assess and eradicate forced labour and child labour from our business and supply chain.
Our organisational structure and business operations
The MillerKnoll collective comprises a number of business entities, with MillerKnoll, Inc. (“MillerKnoll”) as the ultimate parent company. This joint report is prepared on behalf of the following entities, including MillerKnoll, Herman Miller Canada, Inc., Knoll North America Corp., Design Within Reach, Inc., Maharam Fabric Corporation, Edelman Leather, LLC, Geiger International, Inc., Holly Hunt Enterprises, Inc., Knoll, Inc., and Spinneybeck Enterprises, Inc. (referred to as MillerKnoll Group in this report). All policies and procedures referenced in this report are applicable throughout the MillerKnoll Group.
Herman Miller Canada, Inc. is a designer and manufacturer in the furniture sector. Our company produces office furniture, equipment, and home furnishings.
Knoll North America Corp. is a designer and manufacturer in the furniture sector. Its activities include office systems, including office furniture, modular workspaces with integrated panels, work surfaces, storage and lighting, seating, textiles, desks and tables within Canada and the United States.
Design Within Reach, Inc. operates as an integrated multi-channel provider of modern design furnishings and accessories in the furniture sector. Design Within Reach markets and sells its products to both residential and commercial customers through its catalogue, studios, website, and direct sales force in Canada and the United States.
Maharam Fabric Corporation is North America's leading creator of textiles for commercial and residential interiors in the textile manufacturing and furniture sectors. Maharam operates primarily in Canada and the United States.
Edelman Leather, LLC is a provider of leathers for interiors, and caters to residential, aircraft, hospitality, and transportation sectors. Edelman offers installation services, as well as rugs and tiles in Canada and the United States.
Geiger International, Inc. is a manufacturer of business office furniture, desks, casegoods, conference tables, storage, and seating in the furniture sector. Geiger operates in a range of industries, and supplies interiors, furniture, textiles, and more within North America.
Holly Hunt Enterprises, Inc. designs, produces, and showcases home furnishings in the furniture sector. Holly Hunt offers custom made products such as indoor and outdoor furniture, lighting, rugs, textiles, and leathers, and serves customers primarily in the United States and Canada.
Knoll, Inc. is an American company that manufactures office systems, seating, storage systems, tables, desks, textiles, and accessories for the home, office, and higher education in the furniture sector. Knoll is headquartered in Pennsylvania and has manufacturing sites in East Greenville, Muskegon, and Toronto in North America. Knoll also manufactures products in Foligno and Graffignana in Italy, but primarily serves North America.
Spinneybeck Enterprises, Inc. is the world’s leading supplier of full grain, aniline dyed Italian upholstery leather and architectural products and operates in the furniture sector. Spinneybeck provides upholstery leather and architectural products, and offers belting leather, floor tiles, rugs, pulls, and other related products while serving clients in Canada and the United States.
To learn more about our business, please see https://www.millerknoll.com/.
Our supply chain
The majority of our workers are employed in the United States, United Kingdom, Italy, and Canada, where we have fair and responsible employment practices in place to protect and promote workers’ rights. We do not engage child, compulsory, slave or forced labour in any part of our business. We continue to ensure, through our dedicated human resources teams, that we:
treat our workforce with respect and dignity;
provide a safe working environment; and
pay more than the minimum wage.
Each member of the MillerKnoll Group operates in support of the collective MillerKnoll portfolio of products and services. Our supply chains include design, development, sourcing, and fulfilment execution elements which leverage both in-house manufacturing and supplier production (i.e. outsourced) capabilities.
The MillerKnoll Group supply chain encompasses a high concentration of suppliers near our core United States, United Kingdom, and Canadian manufacturing locations, but also engages supply partners and materials from multiple geographic locations around the world. Our comprehensive supply chain includes commodity supply partners (e.g. steel manufacturers), mid-stream value-added suppliers (e.g. textile, leather manufacturers), and finished goods suppliers that allow us to deliver furniture solutions across channels and many end customers and industries. Our supply chain also includes ancillary services that contribute to our main production operations, such as transporters and carriers. As of the date of this report, the majority of our suppliers are based in the following regions/countries: Americas (U.S., Canada, Mexico, Argentina), Asia Pacific (China, India, Japan, Hong Kong, Malaysia, Indonesia, Thailand, Taiwan, Vietnam, Turkey), European Union (Italy, France, Spain, Portugal, Germany, Poland, Austria, Sweden, Belgium, Finland, Netherlands, Norway, Latvia, Slovenia, Czechia, Lithuania), Australia and New Zealand.
However, we recognise that risks of modern slavery may be present further in our supply chain, in areas such as raw mineral extraction and manufacturing. MillerKnoll Group anticipates that its supply chain may be susceptible to risks of forced labour, particularly in China due to the issue of forced labour in Uyghur. We are also aware of parts of the supply chain where potential unskilled, temporary, or outsourced labour could potentially be used by vendors in the extraction manufacturing process. We are also aware of other sectors that may contain risk, such as textiles, electronics, furniture from certain regions, and rugs.
We continue our efforts to classify supplier risks and map key parts of our supply chain to identify and improve our understanding of forced labour risks.
MillerKnoll Group assesses and manages risks by maintaining consistent and high standards of due diligence and risk mitigation processes to monitor for and avoid forced labour in all environments in which MillerKnoll Group operates, including developing and implementing those policies, processes and actions discussed in this report. For certain higher risk commodities, MillerKnoll Group suppliers must establish and maintain a due diligence program, carefully assess supply chain risk, conduct supply chain tracing, audit existing and new supply chains regularly, and communicate results of these audits to MillerKnoll Supply Management.
Our policies
MillerKnoll Group has a Code of Business Conduct and Ethics that sets out our core values and standards applicable to all directors, officers, and individuals employed by controlled subsidiaries of the MillerKnoll Group. We have a responsibility to ourselves, our customers, and our community to do the right thing, and to be successful in this endeavour, we have established our Code of Business Conduct and Ethics to shape our decision-making and how we solve problems in the course of our work. Our Code of Business Ethics and Conduct requires our employees to comply with the laws applicable to our business and to maintain the highest standards of ethical conduct. MillerKnoll’s Code of Business Conduct and Ethics can be found on our website at: https://www.millerknoll.com/legal/code-of-business-conduct-and-ethics.
Our Discrimination and Harassment Policy reflects our commitment reflects our commitment to dignity and respect in the workplace. A copy of MillerKnoll’s Discrimination and Harassment Policy can be found on our website at: https://www.millerknoll.com/legal/discrimination-and-harassment-policy.
MillerKnoll Group has established an Equal Employment Opportunity and Affirmative Action Policy prohibiting discrimination against any applicant or associate based of MillerKnoll Group on legally protected characteristics. Our commitment to equal employment opportunity applies to all persons involved in our operations and prohibits unlawful discrimination by any employee, including supervisors and coworkers. MillerKnoll’s Equal Employment Opportunity and Affirmative Action can be found on our website at: https://www.millerknoll.com/legal/eeo-and-affirmative-action.
We make sure our suppliers are aware of our policies and adhere to the same high standards. Our Supplier Code of Conduct sets forth our expectations of all suppliers of materials to the MillerKnoll Group related to human rights and ethical business practices. MillerKnoll’s Supplier Code of Conduct can be found on our website at: https://www.millerknoll.com/legal/supplier-code-of-conduct.
MillerKnoll Group has established a Code of Business Ethics and Conduct to ensure our employees comply with the law and regulations applicable to our business and to maintain the highest standards of ethical conduct. As part of our Global Policy Whistleblower and Non-Retaliation Policy, we expect and encourage employees of suppliers to report any suspected violations or concerns as to compliance with laws, regulations, our Supplier Code of Conduct, or other Company policies to their supervisor or to our “Whistleblower” hotline or website. MillerKnoll’s Global Policy Whistleblower and Non-Retaliation Policy can be found at: https://www.millerknoll.com/legal/whistleblower-and-non-retaliation-policy.
Measures to remediate forced labour
We are constantly reviewing and improving our approach to supplier due diligence with the aim to enhance our action plan to address forced labour and child labour risks. As part of our initiative to identify forced labour risks in our supply chain, we are currently in the process of completing a supplier risk-mapping assessment, starting with our key suppliers.
As part of our initiative to identify forced labour and mitigate associated risks in our business and supply chain, we have introduced a Supplier Compliance & Review Procedure and adopted the following due diligence procedures.
Supplier Certification of materials in their products to ensure compliance with the laws and regulations of the countries where they are sold, including those related to the prohibition of forced labour and human trafficking.
MillerKnoll Group suppliers of certain higher risk commodities must establish and maintain a due diligence program, carefully assess supply chain risks, conduct supply chain tracing, audit existing and new supply chains regularly, and communicate results of these audits to MillerKnoll Group Supply Management.
Suppliers are required to certify that they comply with MillerKnoll’s policies and standards dictating that its suppliers refrain from the direct or indirect use of forced labour and any form of human trafficking.
Suppliers are required to demonstrate adherence to MillerKnoll Group’s policies and standards prohibiting the use of forced labour and human trafficking by permitting social and environmental audits.
MillerKnoll Group requires that its suppliers to comply with all applicable laws and regulations, provide a safe and sanitary workplace free from harassment and discrimination, and certify that materials incorporated into the products they supply to MillerKnoll do not come from, and that they do not and will not knowingly engage in, any forced labour, slavery or human trafficking.
MillerKnoll Group seeks to create and maintain internal accountability standards and procedures for employees and suppliers regarding slavery and human trafficking and to make it clear that MillerKnoll Group does not engage in and does not intend to do business with suppliers that are engaged in slavery and human trafficking.
As part of these standards and procedures, MillerKnoll advises its employees and suppliers to bring any suspected issues involving slavery and human trafficking to the attention of MillerKnoll Group management.
MillerKnoll Group requires suppliers to provide periodic training for its employees and others who have responsibility for fulfilment of supplier’s obligations to MillerKnoll. This training will provide information concerning human trafficking and forced labour, familiarize them with identifying slavery and human trafficking issues and address mitigating the risk of such issues within its supply chain of products.
MillerKnoll Group expects its suppliers to share its commitment to creating a better world with the goals of reducing waste, using resources responsibly, supporting workers’ rights and advancing the welfare of its workers and the community; and
MillerKnoll Group is continuing to develop processes to verify, evaluate and address supply chain issues related to human trafficking and forced labour.
Supplier adherence to our values
The MillerKnoll Group seeks to do business with suppliers that have similar values, ethics, and moral business practices, including those related to human rights. MillerKnoll Group will not tolerate any form of forced labour or child labour within its supply chain.
To ensure all those in our supply chain and comply with MillerKnoll values, we have in place a supply chain compliance program that we are implementing across the MillerKnoll Group. At the core of this compliance program is the Supplier Code of Conduct, Failure to comply with the terms of this Code may jeopardize a supplier’s relationship with the MillerKnoll Group. Key terms include:
Compliance with Laws, Regulations, and Published Standards: MillerKnoll suppliers must comply with all applicable laws, codes, or regulations of the countries, states, and localities in which they operate, and MillerKnoll Group suppliers must require their suppliers (including temporary labour agencies) and all suppliers’ suppliers to do the same.
Occupational Health and Safety Practices: MillerKnoll Group suppliers must provide their employees with a safe and healthy working environment to prevent accidents and injury, to health arising out of, linked with, or occurring in the course of work or as a result of the operation of the supplier.
Labour Practices: MillerKnoll expects its suppliers to adopt sound labour practices and treat their workers fairly in accordance with local laws and regulations, particularly standards related to Freely Chosen Employment, No Child Labour, Minimum Wages, Working Hours, No Harsh, Inhumane Treatment or Abuse, and No Discrimination.
Ethical Business Practices: MillerKnoll expects its suppliers to conduct their businesses in accordance with the highest standards of ethical behaviour and in accordance with applicable laws and regulations, including Fair Trade Practices, Bribery, Kickbacks and Fraud, Foreign Corrupt Practices Act, and MillerKnoll Policies and Procedures.
Export Sanctions/Terrorism Activities: MillerKnoll suppliers must abide by all economic sanctions or trade embargoes adopted by the United States, the European Union and/or the United Kingdom, whether they apply to foreign countries, political organizations, or particular foreign individuals and entities.
Monitoring and Compliance: Suppliers shall conduct audits and inspections to ensure their compliance with this Supplier Code of Conduct and applicable legal requirements. If a supplier identifies areas of non-compliance, the supplier agrees to notify the MillerKnoll Supply Management Department as to its plans to remedy any such non-compliance.
We have included anti-forced labour provisions in our standard terms and conditions that are used with our suppliers and ensure that such provisions are included in all contracts as appropriate. To confirm all suppliers in our supply chain comply with our values, we ask our suppliers to conform to our Supplier Code of Conduct and will take action to remediate potential non-compliance.
We have dedicated compliance resources committed to help ensure compliance with supplier adherence.
Training
We provide training to our workforce so that they understand the rules around preventing modern slavery and are able to spot signs that it is taking place. MillerKnoll Group provides periodic Supply Chain Management training to raise awareness of issues within the organisation.
Through our training programs, employees are encouraged to identify and report any potential breaches of MillerKnoll’s Supplier Code of Conduct, Code of Business Conduct and Ethics and Discrimination and Harassment Policy. Employees also learn about MillerKnoll’s Whistleblower and Non-Retaliation Policy and are informed that suppliers are obligated to provide an anonymous complaint mechanism for their employees to report any grievances. Employees are taught the benefits of stringent measures to tackle forced labour and human trafficking, as well as the consequences of failing to eradicate forced labour, child labour and human trafficking from our business and supply chains. Training is mandatory for strategically targeted employees. To date, approximately 2,700 employees have been provided training.
Remediation measures
To date, we have not identified any instances of forced labour or child labour in our business and supply chains, therefore, we have not taken remedial measures.
Remediation measures relating to loss of income to vulnerable persons
To date, we have not discovered instances of forced labour or child labour in our business and supply chain, therefore, we have not taken measures to remediate the would-be loss of income to vulnerable families.
Effectiveness in combatting forced labour risks
We work with suppliers to measure the effectiveness of their actions to address forced labour and human trafficking. The MillerKnoll Group uses inherent risk screening to identify and address the highest social compliance risks within our supply chain. Key indicators within the screening tool relate to Country, Products, Governance, Human Development, Corruption, Human Trafficking, and Sustainable Development Goals. Inherent Risk Screening results are considered, along with other factors, when determining which supplier factories to audit each year.
We conduct third-party social compliance audits at supplier factories to verify compliance with our Supplier Code of Conduct. These audits cover five main areas: Labour, Wages & Hours, Health & Safety, Management Systems, and Environment.
Approval of the Report
MillerKnoll Inc. has acted in consultation with the MillerKnoll Group in preparing this report.
This report is made in accordance with Section 11 of the Fighting Against Forced Labour and Child Labour in Supply Chains Act and constitutes MillerKnoll Group’s joint report for the 2023 financial year commencing on June 1, 2022, and ending on May 31, 2023.
This report was approved by the Board of Directors of MillerKnoll, Inc. pursuant to Paragraph 11(4)(b)(i) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act on May 30, 2024.