Ethical commitment

At HUBLOT, including our Canadian subsidiary, we are firmly committed to conducting all our business activities and relationships with the highest standards of ethics and integrity. We strive to ensure full compliance with applicable laws and to uphold the dignity and fundamental rights of every individual involved in or impacted by our operations.

We place particular importance on collaborating closely with our suppliers to guarantee that their employees — and those within their broader supply chains — are treated fairly, with respect and dignity. Our mission is deeply rooted in the promotion of inclusive workplaces and responsible sourcing practices.

This report marks HUBLOT’s first submission under Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9). We acknowledge that eradicating modern slavery — including forced labour and child labour — is an ongoing effort that requires vigilance, time, and continuous improvement. This document outlines the actions we have already taken and those underway to identify, assess, and mitigate the risks of modern slavery within our business operations and supply chain.

HUBLOT operates as part of an international corporate structure under the ownership of LVMH Moët Hennessy Louis Vuitton SE, our ultimate parent company. Our group includes several subsidiaries, among which HUBLOT Canada plays a key role in our North American operations.

HUBLOT is a globally recognized manufacturer and distributor in the luxury watch sector. We employ approximately 1,050 people worldwide and operate in numerous countries, including Australia, Austria, Canada, China, Germany, Hong Kong SAR, Italy, Japan, South Korea, Mexico, Macau SAR, Singapore, Spain, Switzerland, Taiwan, Thailand, the United Arab Emirates, the United Kingdom, and the United States.

Our business activities encompass the production and international distribution of timepieces, including the export of goods to Canada and the importation and retail sale of those goods through HUBLOT Canada.

HUBLOT Canada, a wholly owned subsidiary of HUBLOT SA, is primarily engaged in the retail sale of watches. It employs 8 individuals in Canada and operates two company-owned boutiques. After-sales services are provided by an independent authorized service center. The Canadian subsidiary receives its inventory directly from HUBLOT SA.

The components and raw materials used in the production of our watches are sourced from a diverse network of suppliers located in various countries. Our supply chain also relies on supporting service providers, including logistics companies and carriers, which are essential to the execution of our manufacturing and distribution operations. To learn more about HUBLOT and our global operations, please visit our website.

Within our operations, we assess our risk exposure based on both the countries where our suppliers are located and the specific risks associated with their industries. Our evaluation framework is built on three key pillars: Human Rights, Environmental Impact, and Anti-Corruption. Each pillar is assessed on a scale from 0 to 10, allowing us to measure and compare risk levels consistently.

Our employees are based across multiple regions around the world — with the exception of Africa — and we maintain fair and responsible employment practices globally to uphold and protect workers’ rights.

However, we recognize that certain risks related to modern slavery may still exist within our supply chain, particularly due to the geographic locations of some of our suppliers. To address these risks, we apply a comprehensive due diligence process, which includes:

• Written commitments from suppliers to uphold ethical standards
• Verification of relevant certifications
• Onsite audits to evaluate working conditions and compliance

HUBLOT is committed to act with integrity in all its business dealings and to promote ethical conduct, to enhance compliance with applicable laws and to provide guidance with respect to business conduct. It has several policies that are relevant to this commitment, which set out what HUBLOT expects from its employees, internal business, and its external suppliers.

1. LVMH Code of Conduct

   LVMH's Code of Conduct reflects our commitments in terms of ethics, social responsibility, and respect for the environment for the Group and its Maisons, outlining the rules to be followed by all employees as they go about their work.

    

   The Code is specifically aimed at employees to foster accountability for the rules each individual is required to adhere to in performing their duties. It is signed by the members of the LVMH Executive Committee and endorsed by the Presidents of the Group's Maisons. It includes references to Group internal charters and policies on ethics, environment, and corporate social responsibility, which together form the framework that governs all actions taken by LVMH and its employees.

    

   The LVMH Code of Conduct is available in 25 languages and is widely disseminated across the Group, in particular as part of the onboarding training for new hires. A copy of the LVMH Code of Conduct can be found on the LVMH website at: https://www.lvmh.com/en/ethics-and-compliance/the-lvmh-code-of-conduct.

    

2. LVMH Supplier and Business Partner Code of Conduct

   The LVMH Supplier and Business Partner Code of Conduct sets out the Group's expectations of its partners (suppliers, service providers, distributors, specialist trades, lessors and any third parties in a business relationship with a Group entity) and their subcontractors in various areas, including corporate social responsibility and human rights protection (banning forced labor and child labor, banning illegal or undeclared work, harassment, discrimination, measures relating to wages, working hours, freedom of association, health and safety, protecting local communities), respecting the environment and integrity in business conduct (combating corruption and influence-peddling, combating money laundering, fair competition, preventing insider trading, customs legislation, protecting assets and personal information).

    

   More specifically, the LVMH Supplier and Business Partner Code of Conduct states the following:

   "PROHIBITION OF CHILD LABOR
    

   Work by children under the age of 16 is strictly prohibited. In countries where local laws set a higher age for child labor or set an age for completion of compulsory education higher than 16, the highest age is applicable. Workers under the age of 18 shall not perform any overtime or hazardous work or work a night shift. Suppliers may use lawful, legitimate, properly managed workplace apprenticeship programs, such as student internships.

   
   PROHIBITION OF FORCED LABOR AND HUMAN TRAFFICKING
    

   The LVMH Group does not tolerate any form of abusive or illegal labor in its supply chain such as forced labor or human trafficking. All forms of forced labor, slavery, servitude, or trafficking in human beings by Suppliers, as well as withholding identity papers or work permits or requiring workers to deposit a bond or the use of any other constraint, is strictly prohibited. All workers are entitled to accept or leave their employment freely. Suppliers must respect workers freedom of movement. Suppliers cannot require workers to work to repay a debt to them or to a third party."

    

    

   The Group's partners are required to respect the principles of this Code and must also ensure that their own subcontractors and suppliers do the same when performing their activities for the Group. The Code, which has been translated into 18 languages, has been rolled out to all the Group's Maisons.

    

   HUBLOT makes sure its suppliers are aware of its policies and adhere to the same high standards. The LVMH Supplier and Business Partner Code of Conduct sets forth our expectations of our suppliers of goods and services related to human rights and ethical business practices. A copy of the LVMH Supplier and Business Partner Code of Conduct can be found on the LVMH website at: https://www.lvmh.com/en/ethics-and-compliance/lvmh-supplier-code-of-conduct.

    

3. LVMH Internal Alert System - Whistleblowing

   LVMH encourages a culture of dialogue and communication within the Group. Any employees and external stakeholders who have questions about how to interpret internal regulations or have any ethical concerns are invited to make this known or ask for advice.

    

   In addition to the existing warning channels within the Group's Maison's, LVMH has set up the "LVMH Alert Line", a secure centralized whistleblowing system that guarantees confidentiality, available in 14 languages. This online platform, which can be accessed from the Group's website https://alertline.lvmh.com serves to collect and process reports submitted by employees or external stakeholders concerning situations liable to constitute infringements of laws, regulations, the LVMH Code of Conduct or charters and policies put in place by the Group or HUBLOT.

    

   The system includes coverage of the following behaviours:
   corruption and influence-peddling;
   conflicts of interest;
   money laundering;
   fraud and falsification of accounting records, embezzlement;
   anti-competitive practices;
   data protection breaches;
   discrimination;
   harassment;
   infringements of workers' rights and labour law;
   violation of health and safety standards;
   violation of environmental protection laws;
   human rights violations;
   reprisals connected with a previous whistleblowing report;
   other violations of the LVMH Code of Conduct.

    

   HUBLOT issues regular communications about this whistleblowing system, notably when welcoming new employees. Employees are informed in particular about how they can access the system and the fact that we strictly prohibit any retaliation against whistleblowers (and anyone who helps them or is connected to them) using the system in good faith.

    

4. Human Rights Policy:

   HUBLOT ensures that its business activities are conducted with full respect for individual rights and supports the ongoing improvement of social and public health conditions, which are essential to safeguarding and advancing those rights.

    

   We are committed to maintaining vigilance in identifying any potential direct or indirect negative impacts our operations may have on individuals or communities. Where such impacts are identified, we are determined to take the necessary steps to prevent them or, if needed, to remedy them appropriately.

    

   Our Human Rights Policies is available here

    

5. Supply Chain Policies

   These policies concerning especially precious materials confirm our commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions, and laws. A copy of our Supply Chain Policies (under our watch brand names) can be found here.

    

   HUBLOT is a certified member of the Responsible Jewellery Council (RJC), the world's leading standard-setting organization for sustainability in the jewelry and watch industry. This membership ensures on one hand that all diamonds purchased for HUBLOT originate from legitimate sources, comply with United Nations resolutions, and do not contribute to conflict financing. On the other hand, The RJC promotes responsible practices and ethical standards throughout the whole supply chain, addressing a wide range of environmental, social, and governance (ESG) issues, and contributing to the United Nations Sustainable Development Goals (SDGs). Through standards such as the Code of Practices (COP), HUBLOT, has integrated responsible business practices into their operations, with a particular focus on respecting human rights, ensuring fair labor practices (including the fight against child labor and forced labor in accordance with RJC COP No. 19 and 20 respectively), promoting health and safety, and maintaining product integrity. HUBLOT’s adherence to RJC standards reflects a strong commitment to responsible business practices, human rights, and the prevention of forced and child labour within their supply chain. By adhering to the RJC, HUBLOT demonstrates a comprehensive commitment to ethical values, social responsibility, and a sustainable future, placing the well-being and dignity of individuals at the heart of their concerns.

In order to identify and manage risks of modern slavery and human trafficking in our own business, we carry out background checks and periodically reassess our employment practices to ensure we meet or surpass employment standards in all jurisdictions in which we operate.

We are actively reviewing and strengthening our supplier due diligence procedures with the aim of ensuring a more robust action plan to address modern slavery risks. As part of our initiative to identify modern slavery risks in our supply chain, we are currently in the process of completing a supplier risk-mapping assessment, starting with our key suppliers.

Most key suppliers have been asked to complete a comprehensive supplier-due diligence questionnaire and lower-risk suppliers will be asked to do the same during the course of the next reporting period. As we receive responses from our suppliers, we reserve the right to undertake additional verifications and audits.

Building on the policies and procedures we currently have in place, HUBLOT is in the process of developing and implementing strategies in order to:

1. Assess and better understand areas of potential risk in our business and supply chain;
2. Monitor potential risk areas in our business and supply chain; and
3. Reduce or mitigate the risk of slavery and human trafficking occurring in our business and supply chain.

HUBLOT seeks to do business with suppliers that have similar values, ethics, and moral business practices, including those related to human rights. HUBLOT will not tolerate any form of modern slavery and human trafficking within its supply chain.

We have a dedicated compliance team, which consists of involvement from the following departments:

1. Legal.
2. Internal Control.
3. Purchasing

To ensure all suppliers and contractors in our supply chain comply with our values, we ask our suppliers to conform to the LVMH Supplier and Business Partner Code of Conduct. We require our Suppliers and Business Partners to demonstrate exemplary behavior in social responsibility, including the prohibition of child labor, the prohibition of forced labor and human trafficking, and the prohibition of illegal, undeclared, and clandestine labor. We reserve the right to terminate our relationship with any supplier that engages in modern slavery. "

In cases where compliance failures are identified within our supply chain, whether with a direct supplier or with a lower tier supplier, HUBLOT always works with the relevant stakeholders to draw up a corrective action plan, implementation of which is monitored by the buyer responsible for the relationship within the Maison.

We recognize that any forced labour or child labour found in an organization’s business or supply chain should be addressed on a first-priority basis. To date, we have not identified any instances of modern slavery or human trafficking in our business and supply chains, therefore, no remediation measures have been necessary.

It is of utmost importance to HUBLOT that no worker be negatively impacted by remediation efforts. Where concerns of impact to vulnerable families are identified, HUBLOT endeavours to work with relevant stakeholders to support the communities in which its supply chain operates.

We also recognize that any remediation measures potentially have the unintended consequence of inflicting loss of income on vulnerable persons, such as migrant labourers, unskilled labourers, women, and children. As we have not discovered any instances of modern slavery in our business and supply chain, we have not had to take any remediation measures over the course of the reporting period that would have led to loss of income to the most vulnerable families.

We invest in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programs, employees are encouraged to identify and report any potential breaches of LVMH's Code of Conduct. Employees are taught the benefits of integrating human rights principles into our operations, as well as the consequences of failing to ensure ethical and responsible practices throughout our operations. Examples of training courses we have administered over the past year include:

1. 2024 Business Ethics training (mandatory for all employees)
2. LVMH Code of Conduct training (mandatory for all employees)
3. LVMH Preventing and fighting corruption training (mandatory for all employees)

In order to assess the effectiveness of our actions, each year, HUBLOT evaluates the following key performance indicators (KPIs), namely:

1. 90% of our suppliers have signed the Supplier and Business Partner Code of Conduct.
2. 5% of our suppliers are at risk according to our risk assessment.
3. 30% of our component suppliers are certified among the at-risk component suppliers.
4. 100% of our staff trained on our mandatory trainings in 2024 (Business Ethics, LVMH Code of Conduct and Anticorruption Charter).

HUBLOT SA has acted in consultation with its Canadian subsidiary, HUBLOT Canada (entities we own) 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 HUBLOT modern slavery report for the financial year commencing on January 1st, 2024, and ending on December 31st, 2024.

This report was approved by the Board of Directors of HUBLOT pursuant to Paragraph 11(4)(b)(ii) of the Fighting Against Forced Labour and Child Labour in Supply Chains Act on 23.05.2025

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 the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.