Supply Chain Ethics

With 650 material suppliers in 32 countries – own manufacturing at nine facilities in seven countries, and sales to more than 35,000 stores in 138 markets, a sustainable supply chain and cost-effective, climate-smart distribution are high on our agenda. As we grow and form partnerships with new suppliers, we see an increasing importance in ensuring that our suppliers meet national, international, and Thule Group Code of Conduct regulations and guidelines.

Policies and principles

The Thule Group Code of Conduct applies to all our suppliers, sub-suppliers, and business partners, in addition to our Board of Directors, Group Management, employees, and contractors.

The Code of Conduct contains the principles and guidelines we require throughout our supply chain, concerning human rights, health and safety, work conditions, environmental responsibility, and business ethics. The Code of Conduct is based on guidelines and principles from the United Nations Global Compact, ILO (International Labour Organisation), and OECD (Organisation for Economic Cooperation and Development).

Monitoring and assessment

The Thule Group supply chain is continuously monitored through written supplier self-assessments, on-site audits by our own auditors, and external audits by independent auditors.

Each new supplier is scrutinized and undergoes a self-assessment based on Thule Group’s Code of Conduct, the Thule Group Restricted Substances List (RSL) national laws and regulations with respect to labor law, health and safety, human rights and climate and environmental aspects. 

This is supplemented by our annual follow-up on a number of selected suppliers, using either third-party Intertek auditors or our own internal auditors to ensure that our requirements are complied with and to identify opportunities for improvement. We continuously evaluate our suppliers, with a special focus on high-risk categories such as dyeing fabric, handling PVC and surface treatments, as well as high-risk countries. These audits contribute to both our own and suppliers’ improvements and ensure a better and safer work environment for their employees.

The process consists of in-depth meetings, document verifications, questionnaires, site inspections, and group and individual employee interviews. These on-site audits ensure that suppliers are following the Thule Group Code of Conduct by assessing over 100 criteria from seven different topic areas, including but not limited to human rights, labor, wages, work hours, health and safety, and environmental responsibility.

Corrective actions

If problems are identified in the audits, a clear procedure is followed involving a corrective action request from Thule Group to the supplier. A corrective action plan that the supplier creates is required within two weeks of the request.
A follow-up review is performed by Thule Group internal auditors, to ensure that suppliers implement the necessary corrective actions within specified timelines.

If a supplier scores below 50 percent, we limit further purchases from the supplier and conduct a new audit within the next six months.

If problems are identified via the Thule Group whistleblowing tool, another process is followed which involves Thule Group Compliance Committee and legal support, along with objective third party advising from Intertek.

Corporate social responsibility audits

Every new supplier is scrutinized and undergoes a self-assessment based on Thule Group’s Code of Conduct, the P&R substances list, national laws and regulations with respect to labor law, health & safety, human rights and climate and environmental aspects. This is followed by our annual follow-up on a selection of suppliers, using either third-party auditors or our own internal auditors, to ensure that our requirements are complied with and to identify opportunities for improvement. We continuously evaluate our suppliers, with a special focus on high-risk categories such as dying fabric, handling PVC and surface treatments as well as high-risk countries.  

In 2022, we carried out 41 social audits, of which 35 were first-tier suppliers and six were second-tier suppliers.
Nine of the audits were first-time audits and 32 were follow-up audits.

Out of the 41 supplier audits, 33 suppliers had a result of over 85 percent, which is considered the highest level. Six suppliers had a result between 71 and 85 percent, which is a good result with only minor remarks. Two of the audited suppliers had a result between 51 and 70 percent, which is below the desired level. Both of these had significant comments, primarily within health and safety but also salaries. Thule Group requires that corrections and improvements be carried out in the first quarter of 2023, otherwise the professional relationship with the supplier will be terminated. No suppliers were in the lowest category, with a score of less than 50 percent.