Introduction

At Fitbit, we are passionate about health and wellness, including the health and wellness of those who are helping to build our wearable devices. We believe all workers in our supply chain deserve a fair and ethical work environment and certain minimum standards of human rights as described further in Human Rights Policy. To that end, we undertake a due diligence process aimed at ensuring our supply chain meets our standards. This statement covers the calendar year identified above and is intended to comply with the applicable requirements, including, without limitation, those set forth in: (i) the UK Modern Slavery Act; (ii) the California Transparency in Supply Chains Act; and (iii) the Australia Modern Slavery Act.

Background on Fitbit’s value chain

Fitbit is a technology company focused on delivering health and wellness products and services that have a positive impact on health outcomes. We combine wearable devices with software and services to give our users tools to help them reach their health and fitness goals. The core of our platform is our wearable devices.

Fitbit outsources the manufacturing of these wearable devices to several contract manufacturers. These contract manufacturers produce our devices in their facilities, which are primarily located in Asia. The components used in our devices are sourced either directly by us or on our behalf by our contract manufacturers from a variety of component suppliers selected by us and our contract manufacturers, and are located worldwide. Our operations employees coordinate our relationships with our contract manufacturers and component suppliers.

Our approach to eliminating modern slavery in our value chain

Policy, code and management system

• As it relates to our value chain, we have adopted a Supplier Code of Conduct that reflects our commitment to protect human rights throughout our value chain. In 2019, all our existing tier 1 and 2 value chain suppliers, who are the contract manufacturers and the suppliers of the components and commodities used in manufacturing our devices and our logistics partners, received and acknowledged their compliance with our Supplier Code of Conduct. We intend to integrate education on the requirements set forth in our Supplier Code of Conduct into our value chain supplier on-boarding processes, including through the use of a supplier handbook, by the end of 2020.

• We have established a steering committee made up of senior representatives from our legal, sourcing, quality and manufacturing teams that is responsible for making decisions in regards to the company’s responsible sourcing programme efforts, including due diligence and planned improvements. The committee met two times in 2019 to review the programme. We intend to continue with the same approach in 2020.

• We have established a compliance hotline that provides for a confidential and anonymous means of reporting violations of our Supplier Code of Conduct and any other applicable laws (http://www.fitbit.ethicspoint.com/). We have further established a process by which any such reports are reviewed and properly investigated. We intend to continue with the same approach in 2020.

Value chain risk assessments

• These assessments are designed to identify and mitigate modern slavery risks in our value chain. The 2019 assessment scope was focused on our tier 1 and 2 value chain suppliers. The assessment started with regional and country level social and political risk mapping. To understand risks at a site level, we deployed self-assessment questionnaires and on-site assessment to evaluate our supplier’s maturity level in identifying and mitigating human rights risks. For the on-site assessments, we typically review the supplier’s internal policy, certifications and process control documents, as well as perform a facility and dormitory walkthrough, and worker and management interviews.

• The assessment result was used for developing corrective and preventive action plans and also guided our capacity building focus areas. Our continuous improvement activities were built with the principle of collaboration, because we believe it is the best way to drive sustainable changes.

• The surveys, on-site assessments, and continuous engagement we executed in 2019 showed no obvious signs of slavery, bonded or forced labour in our value chain.

• In 2020, we plan to align our surveys and on-site assessments with the Responsible Business Alliance (RBA) programmes. Our goal is to replace our surveys with RBA’s Self-Assessment Questionnaire (SAQ) and onboard our critical suppliers for RBA’s assessment programmes or other industry level programmes to reduce audit fatigue.  

Risk monitoring and management

• Even though the use of slavery, bonded or forced labour was not identified, we observed some issues relating to the proper implementation of workplace health and safety requirements. Dedicated resources, including Fitbit local team members, were assigned to help our suppliers remediate these issues. We also made available, at no cost to our suppliers, subject matter experts that our value chain suppliers can contact and consult in regards to their questions or concerns related to labour rights and environmental health and safety.

• Our value chain suppliers performance and maturity in managing human rights risks are included in our quarterly business review with each such supplier. We are committed to work with our value chain suppliers to establish proper management systems and controls necessary to guard against any use of slavery, bonded, or forced labour. Our goal in doing so is to ensure that we do not do business with any supplier promoting, engaging in or tolerating such practices. 

Education and training

• During September 2019, we held a “Value Chain Supplier Appreciation Day”. 100 representatives from over 40 of our value chain suppliers attended a full day event to learn about our business, our commitments, and requirements relating to sustainability and responsible sourcing. 

• We took action to understand how much and how frequently our value chain suppliers receive human rights training. Our goal in doing so is to ensure that our programme is delivering resources to our value chain suppliers that help and not contribute to training fatigue. In 2019, we confirmed that all our tier 1 value chain suppliers received training courses about modern slavery and forced labour at their facilities. During 2020, we intend to work to determine which of our tier 2 value chain suppliers require additional training on these topics.

• In addition to training our value chain suppliers, we've also made training available to our employees. We held a workshop in August 2019 that covered the “nuts and bolts” of responsible sourcing, and also held an ongoing series of trainings where we dove deeper into specific topics relating to responsible sourcing. 

Reporting and continuous improvement

• Beginning with 2019, we annually publish on our website this statement of our efforts in combating modern slavery.

• As a member of the RBA, we also undertake all activities necessary to maintain our member status.

• The result of our annual due diligence efforts and this statement were reviewed and approved by the steering committee.