SUSTAINABILITY AT AND

BROWN THOMAS ARNOTTS MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR ENDING JANUARY 2021 1.0 INTRODUCTION FROM BROWN THOMAS ARNOTTS MANAGING DIRECTOR

I am pleased to share our second Modern Slavery statement for Brown Thomas Arnotts for the financial year ending January 31st 2021. The world is a different place since we prepared our first CONTENTS statement last year. This past year, the pandemic has brought unimaginable challenges to all of us, as individuals and businesses alike. Amidst this ever changing landscape we continue to prioritise the safety and well-being of our people and communities, and to review, improve and strengthen our processes, procedures and commitments as business. We remain committed to conducting 1.0 Page 2 INTRODUCTION FROM BROWN THOMAS business in a way that respects and upholds the rights of all of the people working across our ARNOTTS MANAGING DIRECTOR business and within our supply chain.

2.0 Page 3 WHO WE ARE This year we have began alignment on our due diligence processes and policies with our sister retailers at Group, provided training and capacity building forums for our teams and 3.0 Page 4 KEY DEVELOPMENTS IN 2020/2021 suppliers, and set out ambitious materials commitments for 2025 which will have a positive impact on the transparency and sustainability of the products we buy and sell. 4.0 Page 5 OUR APPROACH: POLICIES We have zero tolerance for modern slavery, and this forms part of the Terms and Conditions of doing business with us. We understand that this is our legal obligation for our business 5.0 Page 6 OUR APPROACH: RISK ASSESSMENT AND DUE DILIGENCE under Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013. The Company acknowledges responsibility tothe Modern Slavery Act 2015 and will ensure transparency within our organisation and with our 6.0 Page 11 OUR APPROACH: TRAINING AND suppliers of goods and services. COMMUNICATIONS

7.0 Page 12 STAYING ON TRACK

8.0 Page 13 MONITORING EFFECTIVENESS Managing Director, Brown Thomas Arnotts, 30/06/2021 9.0 Page 14 COLLABORATIONS SUSTAINABILITY AT BROWN THOMAS AND ARNOTTS

2.0 WHO WE ARE

Brown Thomas & Co Limited changed it’s name to Brown Thomas Arnotts Limited on the 10th February 2021. Brown Thomas Arnotts Limited T/A Brown Thomas and Arnotts, are part of Selfridges Group of retailers.

MAPPING THE PEOPLE IN OUR BUSINESS AND SUPPLY CHAINS

OUR STORES AND OPERATIONS OUR PEOPLE OUR SUPPLY CHAIN OUR CUSTOMERS

7 Stores Directly employed by us: Direct Suppliers: Over 5 million customers visited our stores, • Arnotts, Henry St, 900 – 1200 team members - Over 49 Goods Not for Resale: Suppliers that provide goods or and more than 35,000 • Brown Thomas, Grafton St, Dublin services that we use within our customers visited our • Brown Thomas, William St, Galway Work for a supplier: 3100– business and do not sell online stores in 2020 • Brown Thomas, O’ Connell St, 4000 people working with us via - 5 private label suppliers: suppliers Limerick agencies, concessions, service suppliers, contractors and we work with directly to source • Brown Thomas, St Patricks St, consultants private label products • BT2, Dundrum Town Centre Indirect suppliers: • BT2, Blanchardstown Shopping Due to the seasonal and flexible - Over 1,400 own bought suppliers: Centre nature of the business, the Brand partners who we buy number of people we employ product from to sell in our stores or 1 Distribution Centre and does change. Our average on our digital platform

Warehouse operated by DHL number of direct employees is - Over 500 concessions and 900 and peaks during Nov – consignment brands: Brand , Anne’s Lane, Dublin Office Dec to 1200. partners who sell their products in our stores or on our digital platform Online Digital Platform

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3.0 KEY DEVELOPMENTS IN 2020/2021

KEY DEVELOPMENTS in Financial Year 2020/2021

We continued to progress our responsible sourcing programme and commitment amidst the new environment, and we can report on the following developments in this period:

• We committed to materials targets for priority materials identified • We further mapped our GNFR packaging and private label factory in our business. By 2025 our cotton, leather, palm oil, wood, paper, base and worked closely with our suppliers to mitigate risk and man-made cellulosics will come from recycled and/or certified address areas of non- compliance at factory level; sustainable sources. Traceability of materials and certification standards with a focus on labour rights will further our commitment • We began alignment of our Ethical Trading Requirements and due to eradicate modern slavery from our supply chain; diligence process with Selfridges Group, and our sister retailers Selfridges & Co, and ; • We risk assessed over 100 of our key third party brands against our internal risk assessment protocol; for labour, environmental and • We created a sustainability e-learning module covering Modern animal welfare supply chain risks; Slavery, which has been completed by over 85% of our team members. • We hosted two Modern Slavery focussed webinars with our brands and goods not for resale suppliers, with support from AllianceHR;

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SELFRIDGES GROUP VISION AND PURPOSE: A new vision and purpose will be rolled out across Brown Thomas Arnotts in early financial year 21/22. FY20/21 DEVELOPMENTS

CODE OF ETHICS: This year a Selfridges Group Code of Ethics was developed to • This year we commenced an update to our Ethical Trading bring to life the new group values. This is relevant for everyone who works for or Requirements with parent company, Selfridges Group and our sister with Selfridges Group and reinforces our commitment to respect people. It covers a retailers, to strengthen and align our approach on common issues. range of issues including those relating to people, suppliers and sustainability. This is planned for roll out in Brown Thomas Arnotts in FY21/22. • We committed to materials targets for priority materials identified ETHICAL TRADING REQUIREMENTS:. Our Ethical Trade Requirements apply to in our business. By 2025 all cotton, leather, palm oil, wood, paper our brand partners and suppliers, including contractors and concession partners and and man-made cellulosics will come from recycled and/or certified are part of our standard Terms and Conditions. These Ethical Trade Requirements sustainable sources. This will enable further traceability in our supply include clauses on modern slavery, require compliance with any applicable modern chain, and will directly address multiple social and environmental slavery legislation, are aligned with the ETI Base Code and ILO Conventions, and issues in lower tiers, such as raw material sourcing and production. apply across all tiers of our supply chain. These are discussed and referenced by our Buying teams in brand partner and supplier conversations when applicable.

5 Modern Slavery Statement, 30/06/2021 5.0 OUR APPROACH: RISK ASSESSMENT & DUE DILIGENCE

To ensure we focus our efforts where they are most needed and where we can have the greatest impact, we take a risk-based approach which is outlined for our team, brands and suppliers below.

OUR TEAM ON-BOARDING Team member monitoring: We monitor key team member details via our HR system to identify and investigate any Directly employed by us: Our People team ensure all unusual patterns which might indicate an issue. Directly employed by us: The modern slavery risks within directly employed team members have the correct legal our team member population (those directly employed right to work status, individual address and bank account ESCALATING by our businesses) are relatively low. We directly recruit details as part of our on-boarding process. For these and manage our team members; the jurisdiction in which reasons, risk of modern slavery and human trafficking Whistleblowing: We have a dedicated whistleblowing and we operate, although modern slavery exists, has lower occurring through these routes are low. support line, our Speak Up Helpline. This is accessible 24 prevalence than elsewhere in the world; the roles are office- hours a day all year by anyone who works for or with us and based or retail which are lower risk industries; and we have Employed by a supplier: We rely on our contractors, is promoted through team member guides, on payslips and formalised people policies, processes and controls in place. concessions, agencies and suppliers to ensure people in team member communication. This year, with most head office roles working remotely, working for them are eligible to work and are compliant we put extra provisions in place to ensure the safety and with our policies and procedures. This is set out in our wellbeing of our teams off site. Ethical Trade Requirements and we engage our suppliers accordingly. Employed by a supplier: The risk within the population of other people working on our sites, is higher, but still MONITORING comparatively low. We do not directly recruit or manage Grievance process: We have grievance processes for team these people, our concession or supplier partners do. As members to address any concerns or issues that they have. well as retail workers they include workers in industries of In addition, our Group-wide Speak Up Helpline allows team higher risk such as construction, cleaning, security and members, anyone working on our sites or with us, to raise other areas where temporary work is commonplace. During concerns anonymously. peak periods there may be need to increase the number of temporary workers in our businesses to meet seasonal demand. As these individuals are based on our sites, we have visibility of their practices. In addition our partners are Responsible managers: Key managers in our businesses required to ensure that the workers’ identity documents and are responsible for the safety and wellbeing of those right to work are checked. who work in their areas whether they are team members, contractors or concession staff.

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OUR BRANDS AND SUPPLIERS FY20/21 DEVELOPMENTS

• We began alignment of risk assessment and due diligence processes Third party brands: Over 99% of our business comes from third party brands. We recognise that this is where our greatest modern slavery risk exists. We do not control with Selfridges Group, and our sister retailers Selfridges & Co, our indirect supply chains, which span the globe and include countries and industries De Bijenkorf and Holt Renfrew, to ensure consistency and the with a higher prevalence of modern slavery. Whilst we do have formal measures robustness of our programme. in place, such as our Ethical Trading Requirements, we recognise that seeking meaningful assurance that issues do not exist and that measures are effective across • We individually assessed over 100 of our top brands (by sales) all suppliers is challenging. using our risk assessment protocol. We have identified focus areas In line with the importance of responsible sourcing and the promotion of fair and safe for engagement with our brands, and plan further engagement working conditions within our supply chain, all supply partners must meet or exceed throughout FY21/22 to provide additional resource and guidance. the human rights requirements in our Ethical Trading Requirements (ETR), as relevant We plan to complete assessments of the remaining brands from this to the goods and services they provide to us. segment in FY21/22.

In order to assess brand status on a variety of areas, brands are required to complete a Self Assessment Questionnaire (SAQs) or provide this information via a public report or industry tool. This information is then reviewed by our sustainability team to identify risk at individual brand level. We commenced our risk assessment in 2019, initially focussing on our top 10 brands by sales for each department (180 brands in total), assessing risk in areas of labour and human rights, environment, animal welfare and chemical management.

Suppliers are responsible for auditing, monitoring, implementing and reporting corrective actions in their supply chains. They must provide us with audit reports, and compliance related documentation, if requested by us in response to a request from a customer or regulatory body. We reserve the right to investigate the answers they have given in response to the Self Assessment Questionnaire, policy statements and other documentation provided, if required to ensure compliance with legal obligations. Suppliers are responsible for maintaining audit documentation and evidence to demonstrate compliance with their sourcing policies. We may also collect this information and hold such information confidentially.

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OUR BRANDS AND SUPPLIERS FY20/21 DEVELOPMENTS

• We mapped our packaging and private label factory bases, allowing Goods not for resale: Even though we have more direct control over this area of us to understand further the geography of our direct supply chain and our business, due to the global nature of our goods not for resale supply chain, we the worker demographics, and helping us to identify and prioritise recognize the risk of modern slavery is high. Our goods not for resale suppliers are areas of particular risk. Our private label and packaging supply chain also required to complete our SAQ, and to provide in date third party audits for tier is summarised below: 1 factories (finished goods production sites) at a minimum. In certain circumstances factories will complete a self assessment audit, where a recent third party audit is not available. PACKAGING* • 446 workers (Tier 1) We work closely with our suppliers to address any non compliances flagged in an • 7 factories – China (4) Ireland (1) UK (1) Slovenia (1) audit report. In late 2020 we launched quarterly supplier reviews with our key direct suppliers, focussing on ethical and environmental issues and required improvements, PRIVATE LABEL* as well as creating a regular and open dialogue for any opportunities for our own • 2,724 workers (Tier 1) purchasing practices. • 9 factories – Ireland (4) China (3) Egypt (1) Estonia (1)

Private Label: This is a very small part of our business. Currently we use just five Additionally, we engaged this supply base to launch quarterly supplier suppliers to provide own branded products such as Arnotts and Karla Bree branded reviews, which will formally commence in Q1 2021/2022. The supplier duvets, mattresses and bed linen. reviews will focus on current improvement opportunities, enhancing transparency and increasing certification for materials at source.

*based on information from suppliers and factory audit reports correct as of January 2021

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Investigating individual issues: When we become aware of FY20/21 DEVELOPMENTS individual potential issues within a brand partner’s supply • In February 2020 a Channel 4 project with a local partner to provide brand now plan to launch management chain, we immediately contact “Dispatches” documentary uncovered on-site childcare for parents. We continue communications training and further the relevant brand partner or evidence of child labour in the supply to receive updates from our brand partner promotion of grievance mechanisms on supplier, working with our sister chain of one of our brand partners, which throughout to ensure corrective action site. We continue to monitor this matter. retailers where issues impact was later confirmed by the brand during has been taken to address this extremely the wider group. This is to their own investigation. We immediately serious issue. • In January 2021, through media reporting determine whether or not the took action by requesting an account we became aware of a most serious issue has arisen in the supply from the brand on the allegations, • In November 2020, through media case; the death of a factory worker in the chain of any of our own goods including details around the remediation reporting we became aware of exploitative wider supply chain of two of our brand and services and what steps the action to be taken in the short, medium conditions (verbal abuse and excessive partners. The death of this worker was brand is taking to investigate the and long term. As of 31st January, overtime) at a factory linked to one of our reported as having been connected to a potential issues, to support any much of the remediation work by the brand partners. Together with one of our supervisor from her place of work. The victims, and to remedy individual brand is either on-going, or complete. sister retailers, we requested an account third-party investigation which was jointly instances. This includes increasing the number from our brand partner on the allegations commissioned by the brands operating In addition this allows us to of agronomists on the ground in the and their process of investigation. The in the factory, has not concluded as of understand the processes and identified region, Guatemala, increasing investigation by the brand concluded 31st January 2021. We will continue controls in place to prevent un-announced farm visits by third party that pressures relating to delays of raw engagement with our brand partner until reoccurrence, and understand bodies, education and awareness training material deliveries caused by Covid19, such time as appropriate action has been whether there is any wider risk. with external NGO partners as well as the had caused the excessive overtime concluded, both at the factory involved, We also consider whether there commissioning of a root-cause analysis for workers. The allegations regarding and for root-cause solutions for the wider is a risk the issue could appear by the Fair Labor Association. In addition serious verbal abuse were not confirmed supply chain to address gender based elsewhere in our supply chains the brand is looking to expand a pilot by the investigation, although the violence and workplace safety. and we take necessary steps to investigate. Finally this process helps us to focus and make improvements to our risk assessment and due diligence processes.

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FY20/21 DEVELOPMENTS

UPDATE FROM 2019-20 FORCED LABOUR IN XINJIANG UYGHUR COVID19 AUTONOMOUS REGION (XUAR), CHINA Last year we reported: “During the year we became Covid19 has been one of the biggest risks to the supply aware of concerning reports of labour abuses in a factory We are aware of long-standing reports of forced labour chain this year. We know that the pandemic has made associated with one of our brand partners. We immediately associated with the Xinjiang Uyghur Autonomous Region those who are at the highest risk of modern slavery and requested a detailed account of the investigation and its (XUAR) of China. These reports raised that forced training exploitation even more vulnerable. The fluctuations in outcomes, including remediation which has been on-going programmes supply imprisoned camp detainees to mills demand for products globally, in part due to unexpected with an ethical trade consultancy on the ground since the and factories in the area, as well as within cotton picking store closures, will have led to labour issues such as loss discovery. We have been assured that no current orders in the region. For our business, we have investigated of work, and therefore sudden loss of wages for many. In are in place with this facility and that future business will be links to XUAR within our own private label and GNFR addition, this fluctuation in demand has been known to evaluated when the actions are successfully completed. We supply base. We identified one fabric supplier in our wider cause excessive overtime for production workers. will continue dialogue with the brand in relation to its due supply chain who confirmed that cotton for their business diligence of this site and all other production sites.” was in part sourced from this region. Following this As a business we have endeavoured to make the right identification, we requested through our manufacturers decisions throughout this pandemic to protect our During 2020, we continued dialogue with our brand partner. that the fabric sourcing for these particular products was people, our business and the communities in which The brand partner confirmed they no longer source from the moved to a certified cotton sourcing scheme, in line with we live and work. Some of the challenges we have had factory and have revised their supplier on boarding process, industry guidance on this topic. The scheme focusses on to face included delayed and cancelled orders due to increased the frequency of key supplier audits and are in sustainable cotton farming and production and ceased factories being closed or delays at key supply chain hubs. the process of becoming Fair Labor Association accredited. licensing for the production of cotton in Xinjiang. Buying teams worked with our brand partners to discuss This accreditation is designed to provide assurance that individual orders to reach agreements on amends. We the brand partner has systems and procedures required for With regards our brand and concession partners, we have also moved to remote working including remote successfully upholding fair labour standards throughout its have been engaging individually, where specific risk was buying via Microsoft Teams to ensure the safety of our supply chains. We have been in dialogue with several other identified, and also more broadly with our brands on this teams and supply partners. brands sourcing from the same site to gain an overview issue as we acknowledge this impacts the vast amount of the management processes they have in place and to of brands in both the textiles and electronics sectors. In understand progress on the on-going remedial measures. October we hosted a webinar, highlighting modern slavery risks including the on-going concerns in Xinjiang, with our recommendations and guidance for approaching this risk. We continue to monitor the situation.

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OUR TEAM: FY20/21 DEVELOPMENTS Our induction programme for new team member and concession employees includes an introduction to our sustainability and responsible sourcing programme. In addition Our team: We developed the sustainability e-learning module, which to this, we have developed a new sustainability e-learning training module which is has been completed by 85% of team members as of 31st January now mandatory for all new team members. New managers across our business also 2021. The module included sections pertaining to Responsible attend Line Manager Development training. Sourcing and Modern Slavery. The training covered capacity building on the risks in our business and supply chain, and how we are OUR BRANDS AND SUPPLIERS: addressing them at Brown Thomas Arnotts.

As a multi-brand retailer we are in a unique position to have interaction with a Our brands and suppliers: We held two modern slavery webinars in substantial portion of the fashion, furniture and cosmetics industries. We aim to use 2020 for both suppliers of goods and services not for resale, and brand this position to provide guidance and learnings for brands and suppliers in areas of and concession partners. The webinars focussed on capacity building social and environmental responsibility. We will continue to engage with our brands on the topic of modern slavery, as well as discussing the increased on topics pertaining to modern slavery and ethical trade. risk presented by COVID-19 and wider issues impacting supply chains (such as in the Xinjiang region of China). One of the webinars was co-hosted by allianceHR who shared practical steps and processes for addressing modern slavery risk throughout supply chains.

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GOVERNANCE SUSTAINABILITY

Our organisational and governance structure embeds sustainability from the top and We are dedicated to our sustainability commitments, from working, buying and selling in all key business functions. We have a dedicated sustainability team to lead our responsibly to supporting our communities. In fi nancial year 21/22 we will launch programme with oversight from our Sustainability Executive Group. Our Sustainability our new company wide vision; “Reinventing retail”, which will be underpinned by our Executive Group includes all executive functions, is chaired by our M.D. and meets purpose, existing to imagine and create a sustainable future for our people, customers monthly. and communities. Across Selfridges Group and all our sister retailers, there are similar sustainability teams. Our sustainability vision is to achieve Positive Change and support our customers to These teams work together and have a group wide call monthly to track progress and Buy Better. We see this as Doing the Right Thing, one of our core business values. share learnings. We work closely with our brands, concessions and supply partners on We’re committed to placing sustainability at the heart of how we work, what we buy and managing sustainability risks and unlocking opportunities. sell. Our aim is to manage our environmental footprint, responsibly source our products and support our people and communities. To deliver on this vision, our sustainability programme has three pillars of action – Work Responsibly, Buy & Sell Responsibly and Support Community through charity and volunteering. Our Sustainability Policy, annual targets and programme to drive continuous improvement are published on our website for all to see. Our sustainability strategy is integrated in all parts of the business, management objectives and monthly Key Performance Indicators (KPI).

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Monitoring key measures helps us identify and tackle risks and issues, evaluate whether our approach is effective, direct our future activity, DURING 2021/22 WE PLAN TO: and highlight potential areas of improvement. Each year we review the measures we use to help us continue to do this. Our business • Complete the Brand Retailer Module (BRM), in association with reports our headline sustainability performance monthly to our parent the Sustainable Apparel Coalition (SAC)/Higg Co. The BRM is an company, Selfridges Group. This sustainability dashboard includes independent self- assessment of our business from both a human measures on team member awareness and engagement, supply chain rights and environmental perspective. This will enable us to identify visibility, non-compliances and brand and supplier engagement. In any short comings and opportunities for our responsible sourcing addition to this, sustainability and ethical trade risks are considered in programme, across all areas of our business, including our our bi-monthly business risk reviews. purchasing practices; • Complete risk assessments of all of our top 180 brands across departments and engage our brands by providing support and resource on areas where improvement opportunities are identified; • Continue to utilise the existing measures we have in place; • Continue to monitor and take action as necessary in relation to the potential impacts from areas of increased risk including covid-19 and investigations in Xinjiang; • Roll out our common Ethical Trade Requirements with our sister retailers at Selfridges Group; • Trial and refine our common risk assessment and due diligence approach, including monitoring key performance measures; • Continue to collaborate with external experts, other organisations and collaborative forums such as the SAC and Stronger Together, to gain further insight and continue to build our approach; • Continue to engage our team members, brand partners and suppliers on the issue of modern slavery.

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ORGANISATION ORGANISATION OVERVIEW HOW DOES THIS ADDRESS MODERN SLAVERY?

The Supplier Ethical Data Exchange working groups. As members of SEDEX we have continued access to a variety of resources and SEDEX is a not for profi t membership organisation guidance on specifi c supply chain issues, across various regions and sectors. dedicated to driving improvements in responsible and ethical business practices in global supply chains

The leading global collaboration on sustainable The Sustainable Apparel Coalition provides us with a forum for shared resource and apparel, textiles and footwear guidance on many social and environmental issues common to the apparel industry, as well as a suite of tools to allow us to benchmark our performance and identify opportunities to strengthen our procedures.

A non-profi t organization, FSC sets voluntary By sourcing FSC and PEFC certifi ed goods not for resale, such as our packaging, standards by which forests are independently certifi ed we ensure our supply chain is traceable, and that labour rights are respected and to help customers identify and purchase products from protected for those working in it. responsibly managed forests.

PEFC is an alliance of national forest certifi cation systems, NGOs, associations, companies and individuals, working together towards our vision of a world that values the contribution of sustainable forests to our planet and our lives.

Non-for-profi t, multi-stakeholder initiative aiming to As members of the Better Cotton Initiative we are proud to support the work that is make global cotton production better for the farmers undertaken by this organisation to address social and environmental issues at farm and the environment whilst safeguarding a sustainable level in the cotton supply chain, by providing training and resource on sustainable future for the cotton industry cotton farming practices.

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