RAPHA’S HUMAN RIGHTS COMMITMENT
Rapha relies on people. From the workers who make our kit to the communities we ride with, people have always been at the heart of our sport. That is why we are committed to respecting and promoting internationally-recognised labour rights across our operations and supply chain, including those contained in the ILO conventions and the ETI Base Code. This commitment applies not only to Rapha itself, but also to our suppliers and business partners, regardless of where they are in the world.
Governance and accountability
Board / Executive oversight: Rapha’s Board of Directors has ultimate accountability for our human rights and labour standards.
Day-to-day responsibility: The Senior ESG Manager, Sam Wrest, is responsible for implementing our human rights due diligence processes, reporting to the Executive Leadership Team.
Cross-functional governance: The Product, Supply Chain and Sustainability teams operate a cross-functional human-rights committee that meets at least quarterly to review risks to people and remediation plans.
Escalation & decision-making: Where risks to people are found, this is escalated firstly to the Chief Product Officer and Supply Chain Director, and then, if they deem it appropriate, to the CEO and the Board. Actions are then identified to ensure these risks are addressed.
How we identify and prioritise risks to human rights
We use a combination of tools to identify and assess actual and potential risks to people and labour rights. This includes the Global Slavery Index, country risk profiling, and supplier assessments conducted through the Higg FSLM. With these, we map risks across both tier 1 (product assembly) and tier 2 (material production) of our supply chain.
Our assessment process includes:
Country-level risk screening
Supplier-level assessments (Higg FSLM and verified audits)
Worker and stakeholder engagement input where available
Salient risks are prioritised where the potential harm to people is severe and there is either evidence or a high likelihood of it occurring in Rapha’s value chain. We endeavour to leverage our relationship with the supplier or stakeholder implicated to effect change. However, where we are unable to do so effectively, we collaborate with other brands and organisations like the Ethical Trading Initiative.
Transparency in our supply chain
Rapha produces apparel, footwear and accessories. We create our products in close collaboration with our supply chain partners.
Product assembly (tier 1) is concentrated mostly in Vietnam, China and Portugal. Material production (tier 2) is mainly in Taiwan, China and Italy (full table available below). Rapha publishes a tier 1 supplier list on the Open Supply Hub at the end of each year.
In 2024, Rapha worked with 27 tier 1 suppliers globally, including 33 supplier-owned facilities, in 15 countries: Cambodia, China, Germany, Hong Kong, Indonesia, Italy, Philippines, Portugal, Romania, South Korea, Spain, Taiwan, UK, USA, and Vietnam.
In the same period we worked with 129 tier 2 suppliers across the globe in 19 Countries: Australia, Canada, China, Denmark, France, Germany, Hong Kong, Italy, Japan, Poland, Portugal, South Korea, Spain, Switzerland, Taiwan, Thailand, UK, USA, and Vietnam.
Production Country | Tier 1 Volume % Spend | Tier 2 Volume % KG material | Sourcing Risk | Prevalence & Number (100 worse)
| Vulnerability (100 worse) | Government Response (0 worse) |
|---|---|---|---|---|---|---|
Vietnam | 46.42% | 0.8% | Medium | 4.1 | 43.9 | 47.4 |
Taiwan | 36.7% | Medium/Low | 1.7 | 21.3 | 47.3 | |
China | 22.68% | 24.1% | Medium | 4 | 45.5 | 39.7 |
Portugal | 16.85% | Low | 3.8 | 6.2 | 66.7 | |
Italy | 2.8% | 17.3% | Low | 3.3 | 21.7 | 59 |
Indonesia | 8.23% | Medium | 6.7 | 48.65 | 50 | |
Philippines | 1.47% | Medium | 7.8 | 66.4 | 59 | |
Cambodia | 0.57% | Medium | 5 | 57.6 | 42.3 | |
Spain | 0.19% | 7.4% | Low | 2.3 | 10.4 | 62.8 |
Japan | 4.2% | Medium/Low | 1.1 | 11.4 | 43.6 | |
Poland | 3.1% | Medium/Low | 5.5 | 19 | 55.1 | |
Thailand | 3% | Medium | 5.7 | 46.5 | 55.1 | |
Canada | 1.8% | Low | 1.8 | 10.7 | 60.3 | |
South Korea | 1.3% | Medium/Low | 5.7 | 28.6 | 38.5 | |
USA | 0.41% | Low | 3.3 | 24.5 | 66.7 | |
United Kingdom | 0.26% | Low | 1.8 | 14.3 | 67.9 | |
Switzerland | 0.3% | Low | 0.5 | 13.6 | 50 | |
Romania | 0.02% | Medium/Low | 7.5 | 25.9 | 57.7 |
Trade union rights, freedom of association & collective bargaining
To help safeguard the rights of the people in our supply chain, we have committed to ensuring that by 2030, 100% of workers involved in producing Rapha products (tier 1 finished assembly) have access to either a form of representation or an effective worker voice mechanism. This will ensure workers understand their rights and have trusted channels to be heard.
Our approach prioritises freedom of association and collective bargaining. In countries where collective bargaining is restricted by law, we ensure that alternative worker voice mechanisms are in place. These may include grievance channels or worker hotlines, and must be accessible, effective, and trusted by workers.
We use several supplier engagement methods to ensure we can meet this target. This includes our Higg FSLM questionnaires and audits to gauge freedom of association in suppliers’ operations; direct collaboration with our suppliers to improve FOA/worker voice mechanisms; and direct dialogue with workers during site visits. We also engage with local or global trade unions, and coordinate with other brands sourcing from the same facilities to help ensure consistency.
Salient human rights risks & mitigation plans
Salient human rights risks are those that are common in our industry, have a high likelihood of occurring in Rapha’s value chain, and pose a significant risk to people. There are several such risks that we have identified and monitor across our operations and supply chain:
Risk | Location | Reason for Risk | Actions by Rapha |
|---|---|---|---|
Working Hours | APAC | Through assessing verified audit data, we have found that excessive overtime is more likely to occur within our Asia supply chain, specifically working 60+ hour weeks or seven days consecutively without a day off. With a large portion of both our tier 1 and tier 2 supply chain located in this region, this presents a salient risk. | We use our verified auditing data to identify suppliers where excessive overtime occurs. The supply chain manager responsible for the relationship with that supplier then contacts them to understand why working hours are excessive. We will then work collaboratively to ensure these issues are remedied. |
Health & Safety | Fabric Production | Our ethical audits show that health and safety issues are more likely to exist in tier 2 of our supply chain (during fabric production). This is mainly related to the handling of chemicals and hazardous substances. We have therefore classified this as a salient risk and are focusing our efforts on this part of our supply chain to ensure health and safety processes are as robust as possible. | We use Higg FSLM audits to identify instances where health and safety processes are insufficient.
Where gaps are found, we support our suppliers and provide guidance where necessary to improve health and safety systems. |
Recruitment Fees | Taiwan | There have been instances of workers being charged recruitment fees for their employment in the Taiwan supply chain, including within our sector. This is strictly against Rapha’s labour standards, as well as the ILO conventions and ETI Base Code. Because a large portion of our tier 2 supply chain is located in Taiwan, we have classified it as a salient risk. | Recruitment fees are prohibited in our Code of Conduct and periodically checked for in our annual supplier audit and due diligence process. In the event that recruitment fees are found, Rapha will issue a corrective action plan to implicated suppliers. This would include working collaboratively with them to remedy the issue, ensuring workers are reimbursed, and installing new processes to prevent recruitment fees in the future.
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Freedom of Association | China | With independent unions illegal in China, and with roughly a quarter of both our tier 1 and tier 2 suppliers located there, this presents a salient risk towards workers’ rights to unionize and have their voices heard. | We have set a target that all of our tier 1 suppliers have either collective bargaining or effective worker voice mechanisms in place by 2030. This is supported by our audit process to gauge freedom of association in suppliers’ operations. Where collective bargaining or worker voice mechanisms are not in place, we directly collaborate with our suppliers to introduce and improve FOA/worker voice mechanisms. |
Indentured labour in cotton | Fabric production | The global cotton supply chain has been linked to temporary and migrant labour, resulting in a higher risk of indentured or child labour in certain countries. Although accounting for a smaller portion of our fabric sourcing (11% of our total fabric in 2024), this nevertheless presents a salient risk to our labour and human rights standards. | We require that all of our cotton be certified organic or in-conversion. The certification process helps ensure that supplier labour rights are held to the highest standard. Additionally, the certifications that we use (such as GOTS and OCS) use the segregation chain of custody model - which ensures that cotton is segregated at each stage of the supply chain and guarantees traceability after farm level. Rapha also requires that no cotton is sourced from regions with human rights abuse within their cotton supply chains and / or lack of visibility to ensure the human rights are being upheld. This currently includes the Xinjiang Uyghur Autonomous Region of China, Turkmenistan, Uzbekistan, and Syria |
Approval
This human rights commitment has been reviewed and approved by Rapha’s Board of Directors and signed off by our CEO, Fran Millar.
Fran Millar, CEO