1.

obtain those minerals from socially and environmentally responsible sources that do not directly or indirectly contribute to conflict or human rights abuses, including sourcing 3TG only from sources that do not directly or indirectly finance or benefit armed groups in a Covered Country;

2.

implement and communicate to their employees practices and policies that are consistent with the Policy;

3.

familiarize themselves with the Rule and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “Guidance”);

4.

put in place procedures for the traceability of 3TG, working with their suppliers as appropriate;

5.

where possible, source 3TG from smelters and refiners validated as being conflict-free by independent third parties;

6.

maintain reviewable business records on the source of 3TG;

7.

provide us, upon request, with written certifications and other information concerning the origin of 3TG included in products, components and parts supplied to us, and the supplier’s compliance with the Policy generally;

8.

adopt a risk management strategy, with respect to identified risks in the supply chain, that is consistent with the Policy;

9.

otherwise establish policies, due diligence procedures and management systems that are consistent with the Guidance; and

10.

require their direct and indirect suppliers to adopt policies and procedures that are consistent with those contained in the Policy.

1.

Step One: Establish strong company management systems

a.

We maintain the Policy. We communicate the Policy internally and externally by posting it on our corporate website, PVH.com, and by distributing it to all of our suppliers and licensees.

b.

We have a Conflict Minerals working group of senior associates, led by our Vice President & Associate General Counsel, Global Compliance, who work on our Conflict Minerals compliance strategy. This working group includes representatives from Legal and Sourcing. Working group members are educated on the Rule, the Guidance, our compliance plan and the procedures for reviewing and validating supplier responses to our inquiries. We have in prior compliance periods provided training to our supply chain leads, to enable them to better explain our requirements to Covered Suppliers. We also use outside counsel with expertise on compliance and reporting under the Rule to assist us with our compliance efforts.

c.

We use the CMRT developed by the RMI to gather supply chain information. We maintain business records relating to our 3TG due diligence, including responses to the CMRT, findings and resulting decisions, for at least five years.

d.

Our standard supplier and licensee agreements contain provisions that explain the Company’s expectations and our suppliers’ obligations under the Rule. The Policy is also attached to these agreements.

e.

Associates, suppliers and other interested third parties can report potential misconduct, including violations of the Policy, through internal and external channels, including our Tell PVH ethics hotline and website. Reports may be made anonymously (except as prohibited by law) online or via the telephone in any of 14 languages, and are kept confidential to the extent possible.

2.

Step Two: Identify and assess risk in the supply chain

a.

Covered Suppliers were asked to provide us with information, through the completion of the CMRT, concerning the usage and source of 3TG in the products that they manufacture for us. For 2020, we sent emails to each of our 609 Covered Suppliers explaining our obligations under the Rule and the Policy, and requesting that they complete the CMRT. We followed up by email with all Covered Suppliers that did not respond within a specified timeframe.

b.

We reviewed the Covered Suppliers’ completed CMRTs and followed up on any response that appeared to be inaccurate or incomplete. In each case, we requested a revised or more detailed response and continued to follow up as appropriate.

c.

We and our outside counsel with expertise in supply chain compliance separately reviewed the smelter and refiner information provided by the Covered Suppliers against the CMRT’s Smelter Look-up tab list. Smelter and refiner information was also reviewed against the lists of “conformant” and “active” smelters and refiners published by the RMI.

d.

To the extent that a smelter or refiner identified by a Covered Supplier was not listed as “active” or “conformant” by the RMI, we followed up with the Covered Supplier regarding whether the smelter or refiner was in our supply chain.  Based on the information received from the Covered Suppliers, it is inconclusive whether any of the identified smelters and refiners not listed as “active” or “conformant” processed Necessary 3TG contained in our In-scope Products. For 2020, approximately 77% of the smelters and refiners identified by our Covered Suppliers as a source of Necessary 3TG were listed as “conformant.” The remaining 23% have not to our knowledge been determined to directly or indirectly finance armed groups in a covered country.

3.

Step Three: Design and implement a strategy to respond to identified risks

a.

Our Vice President & Associate General Counsel, Global Compliance, reported the findings of our Conflict Minerals supply chain risk assessment to our General Counsel, our Chief Supply Chain Officer and our Chief Sustainability Officer.

b.

We address identified risks on a case-by-case basis. This flexible approach enables us to tailor the response to the risks identified.

4.

Step Four: Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain

5.

Step 5: Report on supply chain due diligence

1.

In certain cases request the completion of a CMRT as part of the exiting process of Covered Suppliers, to ensure that we receive 3TG origin information from inactive, as well as active, suppliers;

2.

Offer training on the Rule and our Policy for all Covered Suppliers that reported using 3TG in products manufactured for us in 2020, and provide training to any other supplier that requests additional instruction;

3.

Provide additional training to select PVH supply chain personnel; and

4.

Require all PVH suppliers to annually sign the Company’s new Global Supplier Agreement, which is in the process of being rolled-out, that will include a representation that the supplier (a) will not use any 3TG in any products manufactured for the Company that are derived from sources that directly or indirectly finance or benefit armed groups in the Covered Countries and (b) will adhere to our Conflict Minerals Policy and will, upon our request, annually provide us with a CMRT.