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Modern slavery and child labor statement

Fanatics Modern Slavery and Child Labor Statement

For the Fiscal Year ended December 31, 2024

Fanatics, LLC (including its subsidiaries, “Fanatics”) is committed to improving fair labor practices throughout its business and supply chain by ensuring that it complies with all applicable laws related to forced labor, slavery, and human trafficking (collectively referred to herein as “modern slavery”) and child labor. We have published this statement pursuant to California’s Transparency in Supply Chains Act, the UK Modern Slavery Act, and the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (together as, the “Acts”). Not all of the entities in our consolidated group are subject to each of the Acts. However, we have prepared this statement on a consolidated basis due to the global nature of Fanatics’ business practices and policies to address modern slavery and child labor.

Fanatics’ business lines include apparel, specialty brands, and hardgoods, which produce Fanatics goods on behalf of licensing partners, including universities, major sports leagues, and other apparel companies. Our sustainability team mentioned throughout this statement reports directly to the Office of the CEO and is responsible for developing and deploying programming related to modern slavery and child labor. The sustainability team engages with each of Fanatics’ consolidated businesses at different levels. While our sustainability efforts currently focus on our core apparel business (“Fanatics Brands”), we continue to expand our work to other Fanatics’ businesses. 

 

Fanatics’ Business and Supply Chain

Fanatics possesses an innovative vertical commerce business model that allows the company to design, manufacture, and distribute high quality fan gear, jerseys, lifestyle and streetwear products, headwear, and hardgoods. Through this model, Fanatics better serves the real-time expectations of leagues, teams, and fans living in today’s on-demand culture. Fanatics offers the broadest assortment of first and third-party fan merchandise and memorabilia worldwide, whether manufactured in-house, sourced from preeminent fan apparel brands, or available via drop-ship. Fanatics also purchases apparel, headwear, accessories, and other products from third parties, which Fanatics sells through its online, direct-to-consumer business.

Fanatics produces goods for our core apparel business at approximately 140 “tier 1” cut, sew, and embellishment contract facilities as of December 31, 2024.  Fanatics also owns and operates manufacturing facilities in the U.S. 

Governance and Accountability

Fanatics, LLC, as a subsidiary of Fanatics Holdings, Inc., (“FHI”), is ultimately governed by the FHI Board of Directors (Board) and its standing Audit and Compensation Committees, FHI senior leadership, the Corporate Responsibility Executive Committee and Working Group, and the Information Security Governance Committee.  Fanatics is committed to maintaining a strong focus on governance, including corporate responsibility and accountability. Our Corporate Responsibility Executive Committee and Working Group have the mandate to further develop our corporate responsibility priorities. The Executive Committee meets quarterly and includes the FHI Chief Financial Officer, Chief People Officer, Chief Legal Officer, Chief Sustainability Officer, and Chief of Corporate and Governance Affairs. The Working Group meets monthly and includes representatives from our sustainability team, human resources, legal, communications, global impact and inclusion, philanthropy and community engagement, and internal audit. Our Board and Audit Committee are updated by key executives on the Executive Committee and Working Group on our initiatives and progress.  

Fanatics employs an internal sustainability team of over 20 individuals globally, which reports into Fanatics’ senior leadership. Thesustainability team develops labor, environment, and traceability goals and targets in alignment with guidance from industry multi-stakeholder initiatives, as well as Fanatics’ key partners and suppliers. On a regular cadence, Fanatics’ leadership reviews progress toward key sustainability goals and targets (See Measuring Effectiveness for details). In addition, the sustainability team providesupdates on risks related to modern slavery and child labor to internal sourcing and compliance stakeholders through multiple cross-functional forums. These stakeholders are consulted on risk mitigation strategies and escalations requiring executive decision-making.

All Fanatics employees are expected to comply with Fanatics’ Code of Conduct and Business Ethics and to conduct business in a legal and ethical manner. Employees and management who support Fanatics’ manufacturing functions are expected to follow procedures regarding notification of suspected modern slavery or child labor. Failure to comply with these requirements may result in disciplinary action.

Grievance Mechanisms and Reporting

Employees of Fanatics may raise questions, concerns, or suspected violations regarding ethics, compliance, and working conditions via our company-wide Global Compliance Helpline (the “Helpline”), which includes a toll-free number that is available 24 hours a day, seven days a week, 365 days a year, and is staffed by live operators who can connect to translators to accommodate multiple languages. The Helpline is operated by a third-party provider, which allocates responsibility for handling the concerns to the appropriate function within Fanatics. As a general matter, our FHI Chief of Corporate and Governance Affairs and our FHI SVP, Audit & Risk Management share responsibility for reviewing concerns expressed through the Helpline and are responsible for ensuring that such concerns are handled appropriately. Fanatics direct employees may also report concerns through managers, the FHI Chief of Corporate and Governance Affairs, the FHI Chief People Officer or to any member of the Fanatics legal or human resources teams.    

Suppliers are expected to maintain their own effective internal grievance mechanisms for their workforce. In addition, the sustainability team also provides Fanatics’ production employees and supplier partner production workers with a grievance channel e-mail address for reporting of any violations of Fanatics’ policies and applicable law, including any instances of modern slavery or child labor. Any reports submitted via this grievance channel are received and appropriately addressed directly by the sustainability team.

In addition to the above, we continued our partnership with an independent, third-party grievance mechanism platform that allows supplier employees to confidentially report an issue of concern. This grievance management system aligns with best practices and regulations as defined by the United Nations Guiding Principles. Certain strategic finished goods suppliers (“tier 1”) are required to participate in this program. Through this partnership, Fanatics has provided this communication option to roughly 40,000 workers at various strategic suppliers globally.

Policies and Commitments

Fanatics is committed to supporting the aims of the Acts and sets high standards in acting ethically and with integrity in its business and commercial relationships. Fanatics Brands, our core apparel business, is affiliated with the Fair Labor Association (“FLA”), an organization that brings together brands, suppliers, civil society organizations, and universities dedicated to advancing responsible labor practices throughout supply chains. In June 2021, Fanatics Brands became a fully accredited FLA participating company.Accreditation is the FLA’s highest level of program evaluation and recognition, signifying that Fanatics Brands has corporate systems in place to identify and remediate unfair labor practices in its global supply chain.  Fanatics’ Brands accreditation evaluation included headquarter-level visits, regional office evaluations, shadowing of nominated auditors, and FLA assessments within supplier factories. Certain Fanatics subsidiaries are also affiliated with the FLA.

Fanatics suppliers are obligated to comply with Fanatics’ Workplace Code of Conduct (our “Supplier Code”), which aligns with the FLA Workplace Code of Conduct, a set of global factory working condition standards developed by the International Labor Organization (ILO). Our Supplier Code and our detailed set of Compliance Benchmarks can be found on our corporate website. These standards are designed to protect workers’ rights and prohibit, amongst other things, all forms of modern slavery and the employment of anyone under the age of 15 or the age for completion of compulsory education, whichever is higher. Our Compliance Benchmarks also stipulate protections for workers under the age of 18 and compliance with all laws and regulations applicable in the jurisdictions in which workers are employed. We require every tier 1 Fanatics facility to post our Supplier Code, along with our brand-level grievance channel, in the local language and in a conspicuous location that is visible to all workers.

Since 2018, Fanatics has been a signatory to the American Apparel and Footwear Association (“AAFA”)/FLA Apparel and Footwear Industry Commitment to Responsible Recruitment. We are committed to working with our partners to create conditions where no worker pays for their job, workers retain control of their travel documents and have full freedom of movement, and where workers are informed of the basic terms of their employment before joining the workforce. In 2024, along with 50 other brands, we signed on to a letter from the AAFA and FLA to Taiwan authorities urging action to ensure responsible recruitment practices for migrant workers in the Taiwan apparel sector.

Supply chain traceability is an essential part of how we monitor modern slavery and child labor risks. Since 2018, Fanatics has been a signatory to the Apparel and Footwear Supply Chain Transparency Pledge, a multi-stakeholder initiative by human and labor rights organizations to improve transparency in garment and footwear supply chains. In alignment with the requirements of the Pledge, we have continued to publish a list of Fanatics Brands supplier facilities on our website.

We train tier 1 finished goods and main body fabric suppliers (“tier 2”) on our Supply Chain Traceability Policy. This policy applies directly to contracted manufacturers of Fanatics’ finished products and the parties that supply materials and components to those directly contracted manufacturers. It outlines our expectations regarding responsible management of upstream supply chains, raw materials, and product traceability. Specifically, suppliers are required to:

  • Maintain an accurate list of the facilities in their source base.

  • Actively participate in training and due diligence activities.

  • Cascade traceability requirements to their upstream suppliers.

  • Commit to maintaining their own robust traceability management systems.

  • Disclose traceability-related information with Fanatics in a timely and transparent manner.

Risk Assessment

Fanatics performs an annual enterprise risk assessment to identify and rank risks that may impact our ability to achieve our strategic objectives. This assessment incorporates external industry data, internal operating data including historical issues, and input from approximately 90 leaders across each of our businesses to highlight key risk themes. As part of the enterprise risk assessment activities for Fanatics, our enterprise risk management team consults with the sustainability team on environmental, social, and governance risks, including but not limited to modern slavery and child labor, and related supply chain and regulatory risks. In addition, the framework evaluates our control environment and aligns with our risk appetite to support the company’s strategic objectives.     

In 2024, we launched a double materiality assessment in partnership with a third-party sustainability consultancy. Our work to identify and prioritize impacts, risks and opportunities related to labor, human rights, environment, and ethical behavior is ongoing.

We stay informed of global modern slavery and child labor risks in the apparel supply chains through our participation in multistakeholder initiatives and industry forums, including through our membership in the AAFA, the FLA, Cascale (formerly the Sustainable Apparel Coalition), and the Better Work Programme. We also review data from the US Department of State and U.S. Department of Labor, including their annual Trafficking in Persons Report and List of Goods Produced by Child Labor or Forced Labor, as well as NGO, academic, and media reports.

Through our risk assessment, in-depth factory audits, and our traceability efforts, we have identified the following areas of our supply chain which may carry risks of modern slavery or child labor:

  • Risk of modern slavery indicators in apparel manufacturing (all supply chain tiers)

  • Unfair recruitment practices and fees, and other indicators of modern slavery affecting foreign migrant workers (tier 1, tier 2, and tier 3 suppliers)

  • Risk of hazardous working conditions for young workers between the ages of 16 and 18 (all supply chain tiers)

  • Risk of forced and child labor in cotton production (tier 4)

We believe that the risk of modern slavery and child labor in our own facilities is minimal due to the strength of our internal employment policies and procedures. Fanatics maintains recruitment policies that stipulate minimum legal working age requirements in each of the jurisdictions where we have operations, which minimizes the risk of child labor entering our workforce.

Supplier Certification and Contractual Requirements

Tier 1 Fanatics suppliers are required to adhere to all our standards, which includes anti-slavery and anti-human trafficking language. Tier 1 Fanatics suppliers are also required to sign a Compliance Commitment Certification, in which they:

  • Acknowledge compliance with all Fanatics sustainability standards and policies (including our prohibition against forced labor), as well as all applicable laws;

  • Agree to participate in our sustainability program covering labor, environment, and traceability due diligence;

  • Commit to maintain and disclose records to substantiate compliance with applicable modern slavery and child labor laws.

Fanatics will not conduct business with a new tier 1 supplier until they confirm in writing they are willing and able to meet our labor standards. Fanatics retains the right to terminate relationships with suppliers if Fanatics believes such suppliers are in violation of our Supplier Code or applicable law.

Due Diligence and Monitoring

Tier 1 Suppliers

Fanatics’ Trade Controls Compliance Policy sets forth the components of our compliance program, which aims to evaluate any new or additional Trade Controls obligations and risks and implements appropriate policies and/or procedures to meet these obligations and risks. This includes screening against sanctions lists as part of the Know-Your-Supplier (“KYC”) process.

An important part of our FLA Accreditation is our commitment to properly vet suppliers before placing orders. FLA’s Principles of Fair Labor and Responsible Sourcing (“FLA Principles”) requires that FLA affiliates conduct pre-sourcing assessments of tier 1 contract facilities to review compliance with our Supplier Code (described above).  Onsite assessments are conducted by third-party auditors who have been trained and accredited by Fanatics on our audit methodology and include document reviews, facility walkthroughs, and management and worker interviews. As a Better Work Partner and Social & Labor Convergence Program (“SLCP”) Brand Signatory, we also accept Better Work assessments and SLCP verified assessments in lieu of deploying our own Fanatics audits.

The results from audits are presented and documented during a regular meeting with representatives from our product development, sourcing, and sustainability teams. Only after a new tier 1 factory is audited and shown to comply with our standards is the factory conditionally approved for production. Once engaged, Fanatics tier 1 factories are assessed at least annually against our SupplierCode through announced and/or unannounced audits by both the sustainability team and independent third-party monitors. The supplier's future business with Fanatics is conditioned on, among other factors, sustainability performance and a commitment to upholding working conditions that align with our Supplier Code. 

Additionally, Fanatics’ grievance mechanisms (as discussed above) provide access for workers at our tier 1 factories to seek remedy for workplace violations of our Supplier Code and enable Fanatics to identify and assess tier 1 supply chain risks on an ongoing basis.

Beyond Tier 1

Through Fanatics’ traceability program, we strive to gain visibility to the entities and materials in our upstream supply chain so that we can partner with our suppliers to assess and mitigate regulatory, labor, environmental, and business continuity risks. We regularly require our Fanatics suppliers to disclose information on their upstream business partners, which enables us to conduct desktop due diligence to identify labor, regulatory, and sustainability risks, including those related to modern slavery and child labor. We leverage a third-party software platform for Fanatics tier 1 and tier 2 main body fabric suppliers to disclose their upstream supply chain mapping for cotton and polyester products up to the tier 4 raw material supplier level and fiber country of origin. We conduct chain of custody training and due diligence exercises with Fanatics’ tier 1 suppliers and nominated tier 2 main body fabric suppliers. This includes collecting and evaluating procurement documentation of product inputs – such as transaction, shipment, and production-related documents.

In addition, we conduct regular screening of our Fanatics source base to identify potential upstream connections to entities associated with modern slavery. If risks are identified, we follow our internal procedures for escalating upstream supply chain risks with cross-functional teams so that we can act quickly to mitigate risks as they are identified.

Remediation and Verification

The sustainability team works with tier 1 Fanatics suppliers to remediate issues identified in audits. If we identify violations of our Supplier Code or local law, we require the supplier to conduct a root cause analysis for each finding, along with identifying immediate and sustainable measures to prevent finding recurrence. Our sustainability team escalates any facility with one or more Critical risk-rated violations to leadership. If such issues cannot be remediated in a satisfactory and/or timely manner or if the supplier fails to submit to the audit, then Fanatics may take action, up to and including termination of the relationship with the supplier. In the event divestment is required, procedures are in place to ensure responsible divestment of the relationship in a manner that aims to minimize negative impacts on workers and vulnerable families connected to such work.  

In the event a labor violation in our supply chain is identified outside of the standard audit process, such as by an external organization or third-party complaint, the sustainability team engages with industry groups, civil society, suppliers, and business stakeholders to understand the issue and align on a remediation plan. Over the course of 2024, Fanatics engaged in regular dialogue with AAFA and other apparel brands and retailers to support the investigation and remediation of allegations of forced labor at certain shared tier 2 supplier facilities, including development of CAPs for the repayment of recruitment fees.

Training

Internal Training

The sustainability team is trained on modern slavery and child labor laws and related matters. In addition, selected associates and management directly involved in the Fanatics supply chain and procurement functions receive training on our Supplier Code, which includes a review of our prohibition against the use of modern slavery and child labor, indicators of and risk factors for modern slavery and child labor, and what actions Fanatics takes to communicate expectations to Fanatics suppliers and monitor for related risks. The training includes an e-mail channel for employees to report suspected violations to the sustainability team for further investigation. Fanatics conducts this training on an annual basis and tracks employee completion. In addition, selected management receive ad-hoc training on risks related to modern slavery in upstream supply chains and related escalation procedures as it relates to their job function.

Supplier Training

Fanatics conducts training on our Supplier Code during the supplier onboarding process, as well as annually in conjunction with our auditing process. The sustainability team deploys additional training to third-party agents and other partners along our supply chain as needed. On an annual basis, tier 1 Fanatics suppliers are required to deliver training for their facility production workers on their rights under our Supplier Code and on how to use Fanatics’ grievance channels. The suppliers are required to certify to us that they have delivered this training to all relevant facilities, which is verified through the auditors’ evaluation. If it is determined that workers have not been trained on their rights, according to local law and our Supplier Code, development and deployment of such training will be included as part of a CAP. 

As discussed in the Due Diligence section above, we also train suppliers on our Traceability Policy and traceability management systems. In 2024, we conducted on-site visits to several tier 1 and tier 2 facilities to conduct traceability checklist walkthroughs and provide guidance to suppliers on chain custody for product and material origins.

Measuring Effectiveness

Internal Evaluation

We hold meetings with the leadership of Fanatics’ businesses several times each year to review the progress of sustainability initiatives and highlight trends and risks from our factory monitoring program. The Fanatics Brands vendor scorecard includes a section on sustainability that assigns a grade based on the vendors’ latest audit rating. This enables the sustainability team to influence our sourcing strategy by identifying those suppliers with a demonstrated track record of strong audit performance, as well as those suppliers who have room for improvement. This information is also used by our cross-functional team when creating a growth strategy for suppliers.

As per the FLA’s requirements, we carry out an annual analysis of audit findings in order to identify and track noncompliance trends and ensure that our monitoring program focuses on those trends. This exercise is documented and submitted to the FLA as part of our annual evaluation, and we have found it effective in setting and meeting performance metrics around risk reduction. 

We monitor global risks in apparel manufacturing and commodity supply chains and emerging regulations to adapt our due diligence activities in preparation for future expectations. We continue to evaluate areas for improvement in our internal traceability-related procedures, data management systems, and supplier training tools and effectiveness. The sustainability team actively monitors partner contractual due diligence and reporting requirements related to traceability, modern slavery, and child labor risks in upstream supply chains and executes supplier training and data collection activities in order to comply with these requirements.

External Evaluation

On an annual basis, the FLA conducts a comprehensive, programmatic evaluation, including an evaluation of Fanatics’ supplier monitoring program, and provides feedback to Fanatics on areas for improvement. Fanatics strives to incorporate the FLA’s feedback into our sustainability team’s work.

As a member of Cascale, Fanatics Brands completes the Higg Brand and Retailer Module (BRM). This is an annual sustainability assessment which establishes the global standard for the Apparel, Footwear and Textile Industry to measure and report on their sustainability impacts and benchmarks their performance with clarity and transparency. The BRM covers the sustainability issues that are distinct to the apparel, footwear and textile industry, providing an accurate assessment to measure, report and benchmark progress on sustainability. As the Higg BRM framework helps to standardize progress and reporting against leading frameworks and regulation, it reinforces the need for policies, procedures, and targets associated with topics related to mitigating risk in the supply chain, including child labor, modern slavery, and responsible purchasing practices.

Since 2019, Fanatics has partnered with The Better Buying Institute (“Better Buying”) an organization that fosters “the industry-wide transformation of buyer purchasing practices so that business relationships support buyers and suppliers in achieving their financial, environmental, and social sustainability goals.” Better Buying allows Fanatics’ suppliers to anonymously rate purchasing practices across key areas, focusing on areas known to cause downward pressure on labor and environmental conditions if not executed properly. For example, poor purchasing practices can result in last-minute decisions or short lead times that can have adverse impacts on the supplier and increase the risk of excessive overtime, unauthorized sub-contracting, forced and child labor.

In 2024, Fanatics continued to assess our performance on the Better Buying Purchasing Practices Index (“BBPPI”) across its seven categories, and we continue to leverage the BPPI insights to inform internal business stakeholder engagement on strengthening brand-level management systems that minimize unnecessary pressures placed upon suppliers and formalize accountability mechanisms for upholding responsible purchasing practices.

Approvals and Attestations

Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act

Fanatics Retail Group Canada, Ltd. (“Fanatics Canada”) is required to submit a report pursuant to the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Canadian Act”). Fanatics Canada comes within Fanatics’ compliance framework and practices to address forced and child labor, which is discussed throughout this statement. Fanatics Canada is ultimately a subsidiary of Fanatics, LLC.

Fanatics Canada has approximately 100 employees in Canada and sells, distributes, imports and manufactures sports licensed apparel merchandise for the retail and ecommerce landscape across the Canadian market. Fanatics Canada does not have any owned manufacturing facilities located in Canada. Fanatics Canada’s business is supported by sales, operations, and retail service teams which are located in both Montreal and Toronto. Fanatics Canada has two subsidiary entities that perform operations similar to that of Fanatics Canada.

Fanatics’, including Fanatics Canada’s, supply chain is discussed earlier in this statement. The risks of forced and child labor applicable to Fanatics Canada mirror that of Fanatics and are discussed earlier in this statement.

Solely for purposes of compliance with the Canadian Act, in accordance with section 11(4)(b)(i), this statement was approved by the Board of Directors of Fanatics Canada on May 28, 2025.

In accordance with the requirements of the Canadian Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in this statement for the entity listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in this statement is true, accurate, and complete in all material respects for the purposes of the Canadian Act, for the reporting year listed above.