SUSTAINABILITY AT BROWN THOMAS AND

BROWN THOMAS ARNOTTS MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR ENDING 31 JANUARY 2020 1.0  INTRODUCTION FROM BROWN THOMAS ARNOTTS MANAGING DIRECTOR

As part of Group, a family-owned, values-led business, modern slavery in all its forms goes against everything we stand for. We do not tolerate modern slavery in our business and supply chains. We expect our supply chain (whether direct suppliers or those that directly or indirectly supply our direct suppliers) to share the same values. As such we have made zero tolerance on modern slavery a requirement of our Ethical Trading Regulations which forms part of the Terms and Conditions of doing business with us. We understand that this is our legal obligation CONTENTS for our business under Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013. The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within our organisation and with our suppliers of goods and services.

2 1.0 INTRODUCTION FROM BROWN THOMAS This is our first Modern Slavery Statement which sets out the steps we are taking to help prevent ARNOTTS MANAGING DIRECTOR modern slavery from occurring in our businesses and supply chains within Brown Thomas Arnotts. It outlines the steps we have taken over the last year (ending 31 Jan 2020) and plans for this year (ending 31 Jan 2021). 3 2.0 WHO WE ARE We have an approach embedded across our business to help tackle modern slavery. This sits 4 3.0 PRINCIPLES AND APPROACH OVERVIEW within our sustainability and human resources programmes. Our approach focuses on ensuring appropriate governance mechanisms, policies and procedures are in place, setting clear expectations for team members and suppliers, and engaging key groups on the issue. We 6 4.0 DUE DILIGENCE PROCESSES know collaboration is key to tackling modern slavery and enabling root cause solutions. We are committed to working collectively across our businesses, with our brand partners and suppliers, 7 5.0 MONITORING AND REPORTING as part of the retail industry and wider business community, and with experts.

As a multi-brand retailer, we know our supply chains, which we have limited direct control over and 8 6.0 TRAINING AND COMMUNICATIONS visibility of, are our area of greatest risk. This is why collaboration with our suppliers is so crucial, to help tackle modern slavery together. We remain committed to helping ensure everyone who 8 7.0 COLLABORATION works for or with us as an employee, on our sites or in our supply chain is respected, protected and is able to access support should they need it. We know there is more we can do and we will continue to develop our approach to help tackle modern slavery and protect everyone who works with us.

MD Brown Thomas Arnotts, 31/08/2020 SUSTAINABILITY AT BROWN THOMAS AND ARNOTTS

2.0 WHO WE ARE

Brown Thomas & Co Limited T/A Brown Thomas and Arnotts Limited T/A Arnotts are part of Selfridges Group of retailers. SHEL Holdings Europe Limited (UK registered) is the ultimate shareholder of the companies which are the shareholders of Brown Thomas & Co Limited T/A Brown Thomas and Arnotts Limited T/A Arnotts.

KEY DEVELOPMENTS in Financial Year 2019/2020

We updated our Ethical Trading Regulations (ETR) to be more explicit on our modern slavery and wider sustainability requirements for suppliers. We formalised a Responsible Sourcing system for engaging, capacity building and risk assessing our suppliers on modern slavery and wider sustainability issues. We set targets and KPIs to implement and monitor this. The highlights of what we did are:

•  We assessed our processes for tackling modern slavery in our •  We engaged and commenced risk assessments of our top 10 brands recruitment of direct employees and procurement of goods and and concessions by sales value to the business (over 180 organisations). services. •  We conducted training by webinar and one to one with GNFR, brands • We mapped all our suppliers of products and services and identified and concessions and provided a supplier pack to support capacity those with the highest potential risk of modern slavery. building.

• We engaged and risk assessed all GNFR product and service •  We trained our buying teams and provided a “Better Buying” Guide and suppliers. pack for each of our product categories – fashion, beauty, home, food, restaurant.

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3.0 PRINCIPLES AND APPROACH – OVERVIEW

We take a risk based approach to tackling modern slavery. It starts with mapping the people in our business and supply chain. This covers: • Team members directly employed by us • Team members working for a supplier but are based on our sites • People who work for a supplier elsewhere

MAPPING THE PEOPLE IN OUR BUSINESS AND SUPPLY CHAINS

Our Business Our People who work on our sites Our Supply Chain Our Customers

7 Stores Directly employed by us: types of role and seasonality. Direct Suppliers: Over 8 million customers from around the world • Arnotts, Henry St, 1300 – 1900 team members For example, roles with a - Over 35 Goods Not for Resale: • Brown Thomas, Grafton St, Dublin potential higher risk of modern Suppliers that provide goods or visited our stores in 2019. • Brown Thomas, William St, Galway Work for a supplier: 3100– slavery can include seasonal services that we use within our • Brown Thomas, O’ Connell St, 4000 people working with us recruits to distribution centres, business and do not sell - 6 private label suppliers Limerick via agencies, concessions, contractors in cleaning, • Brown Thomas, St Patricks St, service suppliers, contractors security, shop fit/construction/ Indirect suppliers: • BT2, Dundrum Town Centre and consultants facilities supports and restaurants. We work with our - Over 1,300 own bought suppliers: • BT2, Blanchardstown Shopping Due to the seasonal and suppliers of these roles and Brand partners who we buy Centre flexible nature of the retail any agencies to support them product from to sell in our stores or business, the number of mitigate these risks. Regarding on our digital platform. 1 Distribution Centre and people we employ does employment agencies, - Over 350 concessions and Warehouse operated by DHL change. Our average number we work both directly and consignment brands: Brand of direct employees is 1300 indirectly with 6 recruitment partners who sell their products in Office, Anne’s Lane, Dublin and peaks during Nov – Dec agencies to assist in the our stores or on our digital platform. to 1900. We take a risk hiring of our team members Online Digital Platform based approach to identifying and those of our concession modern slavery based on the partners.

4 Modern Slavery Statement, 31/08/2020 Our human resource programme incorporates the measures we take to mitigate modern slavery risk Elements in our Responsible to employees. Our sustainability programme incorporates measures to tackle modern slavery risk Sourcing Approach associated with our suppliers and supply chain. The approaches for these are outlined below.

Sustainability Policy HR policies and processes Governance - Responsible sourcing is a key element Our Codes of Conduct, HR policies and Our organisational and governance structure embeds sustainability from the top Goods & Services Procured processes set out our expectations of, and our and in all key business functions. We have a dedicated sustainability team of three - Private label, own-bought and responsibilities towards, our team members. to lead our programme with oversight from our Sustainability Executive Group. concessions These include specifying recruitment fees should Our Sustainability Executive Group includes all executive functions, is chaired - Services and non- sale GNFR never be incurred by an individual and salary products payments must not go into bank accounts in by our M.D. and meets monthly. Across Selfridges Group and all our sister retailers, there are similar sustainability teams. These teams work together and someone else’s name more than once and Organisation without written authorisation from the team have a group wide call monthly to track progress and share learnings. - Managing Director member. These policies are highlighted to all We work closely with our brands, concessions and supply partners on - People Director new team members joining our business, and managing sustainability risks and unlocking opportunities. We engage with - Buying Directors are available to view at any time via the our suppliers and require them to nominate a senior manager to undertake - Head of Sustainability & Responsible Sourcing Coordinator Brown Thomas Arnotts internal communications responsibility for compliance with our Ethical Trading Regulations. This is the platform BASE. day to day contact for our Responsible Sourcing team for communications in Ethical Trading Regulation both directions as required. - Responsible Sourcing Code of Conduct

Sustainability Due Diligence - Mapping and risk assessment of existing suppliers to KPIs We are dedicated to our sustainability communities. To deliver our aim, our have a Responsible Sourcing system to - Sustainability Supplier commitments, from working, buying sustainability programme has three support us manage the environmental Questionnaire and selling responsibly to supporting pillars of action – Work responsibly, and ethical impacts across our business - New supplier assessment our communities. Our sustainability Buy & Sell Responsibly and Support and supply chain. Responsible sourcing procedure vision is to achieve Positive Change Community through charity and of products, packaging and services - Monitor and support our customers to Buy volunteering. Our Sustainability Policy, is a key element of our sustainability - Database Better. We see this as Doing the Right annual Targets and programme to policy, targets and programme. Thing, one of our core business values. drive continuous improvement are This incorporates modern slavery Training We’re at an early stage, but committed published on our website for all to and human rights, environmental - Internal teams to placing sustainability at the heart of see. Our sustainability strategy is management and animal welfare. The - Supporting supply partners how we work, what we buy and sell. integrated in all parts of the business, elements in our Responsible Sourcing Collaboration management objectives and monthly approach are illustrated. Our aim is to manage our environmental - Partners footprint, responsibly source our Key Performance Indicators (KPI). products and support our people and Under our Buy & Sell Action pillar we Reporting - Monthly internal reporting - Annual Modern Slavery Statement

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4.0 DUE DILIGENCE Responsible managers: Key managers in our businesses store or online meet our sustainability requirements. are responsible for the safety and wellbeing of those who work in their areas whether they are team members, Goods not for Resale (GNFR), Agencies and Services Our due diligence approach to tackling modern slavery is contractors or concession staff. Suppliers – we use third party service providers to provide based on the risk which is different for each category below. key services to us such as logistics, seasonal staff at our - Team members directly employed by us Team member monitoring: We monitor key team member distribution centre, IT security and cleaning. Again whilst - Goods and services procured details via our HR system to identify and investigate any we have less direct control of the environmental and ethical - Team members working for a supplier but are based on unusual patterns which might indicate an issue. impacts of our service providers, we have requested they our sites meet our sustainability requirements, as relevant to the - People who work for a supplier elsewhere via our brands Escalating services they provide. In addition, we monitor the external and concessions. agencies used for recruitment purposes within our business. Whistleblowing - We have a dedicated whistleblowing and The relationships are managed by department managers, support line, our Speak Up Helpline. This is accessible 24 4.1 Team Members Directly Employed by US our human resources team and our concession partners. hours a day all year by anyone who works for or with us and The sustainability team are notified of the addition of any is promoted through team member guides, on payslips and On boarding new agency partners before use, for relevant due diligence in team member communications. engagement. Right to work: Our People team ensure all directly employed team members have the correct legal right to 4.2 Good and Services Procured – ETRs and responsible sourcing work status, individual address and bank account details GNFR & Agencies, Private Label, Brands, Concessions as part of our on-boarding process. For these reasons, risk In line with importance of responsible sourcing and the of modern slavery and human trafficking occurring through In our business we source products, packaging and promotion of fair and safe working conditions within our these routes are low. services through these three main routes. All must comply supply chain, all supply partners must meet or exceed with our Ethical Trading Regulations (ETRs), to include the sustainability requirements in our Ethical Trading Contractor, concession, agency and supplier checks: regarding modern slavery. Requirements (ETR), as relevant to the goods and services We rely on our contractors, concessions, agencies and they provide to us. As a minimum these require supply suppliers to ensure people working for them are eligible to Private Label – This is a very small part of our business. partners to meet their legal obligations in the following areas: work and are compliant with our policies and procedures. Currently we use six suppliers to provide own branded - Human rights, labour and modern slavery This is set out in our Ethical Trade Requirements and we products such as Arnotts branded duvets and towels, and - Health & Safety engage our suppliers accordingly. Brown Thomas brand ties and Christmas decorations. - Environment - Animal Welfare Monitoring Concessions and own-bought brands – We source third party branded products and services via concessionaires We have mapped our existing supply partners and Grievance process: We have grievance processes for team (including our restaurant concessions as well as commenced risk assessments to review their sustainability members to address any concerns or issues that they have. concessions selling products/services) and suppliers of performance against our ETR requirements. We also assess In addition, our Group-wide Speak Up Helpline allows team third party brands. Whilst we have less direct control of the opportunities to showcase brands on our Sustainable Edits members, anyone working on our sites or with us, to raise environmental and ethical impacts of our concession and on both Arnotts and Brown Thomas websites meeting third concerns anonymously. own bought supplier’s supply chain, we strive to play an party certified standards. increasing role in ensuring that third party products sold in

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Our process for existing brand partners and Questionnaire, policy statements and other documentation 5.0 MONITORING AND REPORTING GNFR suppliers: provided, if required to ensure compliance with legal obligations. - We identified the top 10 brand partners across all We maintain data and records on supplier risk - Suppliers are responsible for maintaining audit categories (180 in all) in 2018 based on total sales assessment. This includes: - We reached out to these brands in May 2019 to documentation and evidence to demonstrate compliance - The information they provided us in response to our communicate the new changes to our ETR’s and prepared with their sourcing policies. We may also collect this Sustainability Supplier Questionnaire, including on modern a responsible sourcing pack which is intended as a information and hold such information confidentially, slavery. supporting guide to the ETRs. unless a legal obligation requires otherwise, for example in - Associated certificates - We request all supply partners to complete our the case of Modern Slavery reporting. - Audits of own brand/private label factories or GNFR Sustainability Supplier Questionnaire, providing associated suppliers as relevant and any corrective actions agreed. compliance and third party certification details as Our process for own brand (private label) brands necessary. We use this information to assess their - In addition to the requirements above, private label brands We monitor our progress on meeting our Responsible performance against our ETR and gather information on must also provide full supply chain details of all factories Sourcing system and use associated KPIs as part of internal Sustainable Edit compliance and charitable giving. The and locations. They must have a recent 3rd party ethical business reporting. questionnaire has specific questions on how they are audit (no less than 18 months old). Supply partners may addressing modern slavery. All suppliers must complete utilise industry standard audits, such as SEDEX Members To year ending 31 January 2020, one instance of labour this questionnaire satisfactorily and provide evidence of Ethical Trade Audit (SMETA) or third party audits as part exploitation was identified in the supply chain of a brand their activities. of our assessment. We also may conduct our own audits. partner. Brown Thomas immediately requested a detailed - Supply partner risk assessment is conducted through a On average, we require all audit non-compliances to have account of the investigation and its outcomes, including mixture of desk based reviews of questionnaire data and been dealt with no later than three months after an audit remediation, which has been on-going with an ethical trade associated information. or when otherwise raised. Satisfactory evidence of non- consultancy on the ground since the discovery. They have - We engage with suppliers one to one, hold workshops per compliance resolution must be provided by them. been assured that no current orders are in place with this product/supplier type and held a recorded webinar to help facility and that future business will be evaluated when our GNFR suppliers and brand partners understand our Our process for all new suppliers: the actions are successfully completed. Brown Thomas requirements. 1. All new suppliers are sent a supplier pack on set up. will continue dialogue with the brand in relation to its due - We require brand partners to use SEDEX or an equivalent 2. The pack contains a supplier set up form (which identifies diligence of this site, and all other production sites. scheme provide transparency across their supply chains. sustainability lead in brand), supplier guidelines, ETR and - Suppliers are responsible for auditing, monitoring, associated guide. implementing and reporting corrective actions in their 3. Sustainability team then engage the supplier to supply chains. They must provide us with audit reports, commence the risk assessment process against the and compliance related documentation, if requested by ETR as above as well as identify opportunities for the us in response to a request from a customer or regulatory Sustainable Edit. body. - We reserve the right to investigate the answers they Brand is set up with accounts department once approved have given in response to the Sustainability Supplier by buying director.

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6.0 TRAINING DevelopedBetterBuyingGuideforbuyersandconducted dedicatedtodrivingimprovementsinresponsibleand training in each product category. ethicalbusinesspracticesinglobalsupplychains; -Webinarforallbrandsonsustainabilityrequirementsand Employee training: modern slavery. - Sustainable Apparel Coalition –theleadingglobal Everynewteammemberandconcessionemployeeattends -WorkshopswithGNFRandshop-fitsupplierson collaborationonsustainableapparel,textilesand ourInduction,whichfeaturessustainabilitytraining.New sustainabilityrequirementsandmodernslavery. footwear; managersacrossourbusinessalsoattendLineManager Developmenttraining.In2020wewilldevelopandrequire Suppliers: - Better Cotton Initiative -non-for-profit,multi-stakeholder allteamstocompleteane-Learning&Development ToensureawarenessofourETRrequirementsandcapacity initiativeaimingtomakeglobalcottonproductionbetter sustainabilitymodule.Thisincludesmodernslaveryand build,weengagewithoursuppliersonetoone,provide for the farmers and the environment whilst safeguarding a howwetackleitinourbusiness. guidanceandworkshops/webinarsonourETRand sustainablefutureforthecottonindustry. requirements.In2020,weplantrainingonModernSlavery ThebuyingteamsreceivetrainingonourResponsible for our GNFR suppliers. - Programme for Environmental Forest Certifi cation & Forest Sourcingsystem.Thesustainabilityteamonresponsible Stewardship Council –sustainablesupplychaininitiatives sourcing have regular training to understand our fortimberproducts. ResponsibleSourcingsupplierobligations,initiativesand approachesonsustainablesupplychainmanagement.In 7.0 COLLABORATIONS theyearend31stJanuary2020thefollowingtrainingwas conducted: Toscaleouractivitiesandfocusonrootcausesolutions,we arealsoamemberofthefollowingindustrygroups: -EthicalTradingInitiative(ETI)Buyingethicallyworkshop– attendedbytwonewsustainabilityteammembers - SEDEX -theSupplierEthicalDataExchangeworking -SustainabilityTeamandconsultancyCREATESustain– groups.SEDEXisanotforprofitmembershiporganisation

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