COP REPORT 2019/2020 2 Contents

Page 3 CEO commitment Page 4 The Very Group at a glance Page 5 UNGC 10 principles Page 6 - 12 Labour, human rights and due diligence Page 13 - 15 People and colleague culture Page 16 Charity Page 17 - 19 Environment and travel Page 20 Anti-corruption Page 21 - 22 Data, security and privacy Page 23 - 24 Financial services Page 25 Action plan 3 CEO commitment

Sustainability at The Very Group

to the pandemic: continuing to The foundations that we have laid in operate and serving our customers the last 12 months will provide the and adapting to new ways of working. catalyst for us to deliver on our We also deployed initiatives to support ambitious strategy and work the NHS and our local communities. towards achieving our 2025 goals. Unfortunately, the impacts of COVID are likely to be here for some time To further support our sustainability and we will continue to support our programme, we remain active colleagues, our customers, and our participants of the UN Global Compact wider communities. and it’s working groups. This year we are pleased to join the global target Despite the significant challenges of gender equality group, we believe COVID, our full year results reported this will further support our work on a strong financial performance: a gender, both within the business and testament to the hard work of our across our supply chains. Alongside As the UK’s largest integrated pureplay colleagues. We also launched our new this, we are also active members of the digital retailer and financial services fulfilment centre, Skygate, located in newly formed group on child labour provider, we frame our purpose as the East Midlands. With 850,000sq and continue our participation in the “making good things easily accessible ft of automated warehousing space, SDG and modern slavery groups. to more people”. With our multi- Skygate allows us to better serve our category range of leading brands and customers with later cut-offs for next unique financial services products, day delivery, faster processing and which offer customers flexible ways reimbursement for returns and the to pay, we are well placed to deliver potential for same day deliveries. on that promise. It also gives us the opportunity for I continue to be proud of our a significant increase in scale, with work on sustainability and In our hundred years of history, best-in-class automated technology. the progress we are making we’ve gone from a catalogue and I am confident that retailer with high street stores to Over the last 12 months, we have we will make even greater becoming a fully digital retailer. refocused our sustainability agenda. strides over the next Over the past 12 months, we have In June 2019, we centralised our 12 months. continued that transformation CSR activities and agreed on a with our official rebrand to The Very business wide sustainability strategy. Group in January 2020. The rebrand The strategy is based on three brings the Group’s name and identity key pillars; our people, our planet Our report on progress for the 2019/20 in line with our flagship consumer and our communities. And despite calendar year provides an overview of brand, Very.co.uk. the challenges we have faced, we are key activities undertaken across our already making fantastic progress. business during this period. Less than three months after the We have joined both Stonewall’s rebrand, the COVID pandemic Diversity Champions programme We hope you find it useful. resulted in a set of unprecedented and signed up to the UN Women’s challenges, which impacted our Empowerment Principles. We are people, our supply chains and our also providing health and wellbeing customers. I am incredibly proud of training to over ten thousand factory Henry Birch the way our business has responded workers and their families. Group CEO The Very Group 4 at a glance

The Very Group is the UK’s largest integrated online retailer and integrated financial services provider and has a history that stretches back over 100 years. Three customer facing brands sit under the umbrella of The Very Group which are Very.co.uk, Littlewoods.com and LittlewoodsIreland.ie. Headquartered in Liverpool, we also have an office in London and warehouses both in the East Midlands and North West.

The benefits of being an integrated retailer and financial services provider mean we can provide our customer with flexible payment options to buy the things they need, thereby fulfilling our purpose to make good things easily accessible to more people.

4m £2bn 4,700

active annual engaged customers revenue colleagues

1,900 1.5m 79%

famous daily of online brands website sales from visits mobile 5 UN Ten Principles

Human Labour rights Principle 3 Businesses should uphold the freedom Principle 1 of association and the effective recognition Businesses should support and respect of the right to collective bargaining; the protection of internationally-proclaimed human rights; and Principle 4 The elimination of all forms of forced Principle 2 and compulsory labour; Make sure that they are not complicit in human rights abuses. Principle 5 The effective abolition of child labour; and

Principle 6 The elimination of discrimination in respect of employment and occupation.

Environment Anti-corruption

Principle 7 Principle 10 Businesses should support a precautionary Businesses should work against approach to environmental challenges; all forms of corruption, including extortion and bribery. Principle 8 Undertake initiatives to promote greater environmental responsibility; and

Principle 9 Encourage the development and diffusion of environmentally-friendly technologies.

The United Nations Global Compact (UNGC) is the world’s largest voluntary corporate citizenship initiative. The UNGC issues Ten Principles on Human Rights, Labour Standards, the Environment and Corruption. Membership of the UNGC requires companies to issue a ‘Communication on Progress’ report annually.

This report is our tenth COP and outlines The Very Group’s activities in support of these ten principles. Labour, Human Rights 6 and Due Diligence

APPROACH The Very Group are signatories to the an annual ethical audit whether this Supply Chain Transparency Pledge, be SMETA, Fast Forward, or BSCI. It is a priority at The Very Group that and we continue to give visibility of These audits are carried out by our we are protecting and respecting our manufacturing site by publishing three global audit partners and are human rights throughout our a full list of our first-tier factories conducted on an unannounced/semi organisation and in our supply chain. on our corporate website. This list announced basis, enabling us to gain We are committed to tackling labour is updated every six months and is an insight into working conditions. and human rights risks and our also included in our Modern Slavery Our local team offer ongoing support fundamental approach is to ensure Statement. Over the past twelve to our suppliers to remedy issues we are upholding the principles in months, we continued to work on which are found during audit and the Universal Declaration of Human gaining visibility of our tier 2 sites follow up audits are requested Rights and the International Labour which we aim to complete by June to close high risk issues needing Organisation’s Declaration on 2021. By publishing our supply chain, independent verification. Fundamental Principles and Rights at we encourage accountability both Work. for us and our supply chain partners Alongside our audit as well as driving collaboration to programme, our strategy achieve maximum impact with other POLICIES focusses on better organisations sharing facilities in our supporting our factories At The Very Group, we have clear supply chain. policies and processes in place and their workers through to support our commitment to SUPPLY CHAIN training and project conducting business responsibly. MONITORING work, looking at tackling These policies are reviewed and key risk areas within our updated regularly as we learn from At The Very Group, we have a broad supply chain and building our experiences, supply chain risk and varied supply chain. We source regional infrastructure assessments and industry best both own brand fashion, home practice. They are designed to ensure and living products from 520 tier 1 and capability to ensure that people are treated with dignity factories in 30 countries worldwide, sustained improvements and respect in all areas of business including China, India, Bangladesh, for workers. and supply chain and are based Malaysia, Poland and Turkey, where on the principles laid out in the we have in-country sourcing offices. International Labour Organisation’s Our in-country sourcing teams work Declaration on Fundamental in collaboration with head office Principles and Rights at Work. Buying and CSR teams to identify, on- board and develop suppliers which The Very Group policies include: align to our labour and human rights • Very Group Code of Conduct approach. All manufacturers of Very • Modern Slavery and Human product are required to commit to Rights Policy work under the terms of our code of • Homeworker Guidelines conduct and business policies [see • Child Labour Remediation and section ‘POLICIES’] Young Workers Policy • Migrant and Contract Worker In order to conduct due diligence Policy against our policies within our own • Syrian Refugee Remediation Policy brand supply chain all tier one • Access to Remedy Policy factories are required to undertake Labour, Human Rights 7 and Due Diligence

OUR PROJECTS were set up as a method of grievance result of the training programmes and redressal where necessary. wider awareness building initiatives. 15 local agents have agreed to adhere to India Labour Agents best practice recruitment guidelines. The mills we source from in Southern At the Labour Agent level, we looked We have also managed to conduct India are one of the few sources of at ensuring fair recruitment practices grievance redressal and life skills employment for young women in are adopted throughout the process training with over 1000 workers. The the region and provide them and across five villages. Setting up agent impact of these achievements means their families a much-needed income coordination committees enabled that we have been able to ensure source. Given the high numbers of us to create an ongoing dialogue that workers and their families have women employed in this industry we between agents, mills and the wider better knowledge of labour rights, saw it as an opportunity to further our community. Having a preferred pool that agents understand the need for work on gender equality, creating a of ethical recruiting agents would also responsible recruitment and that mills better working environment but also mean raising the level of expectations have improved relationships with both equipping workers with skills that for what is required from them if they the agents and workers. The project would support their development are to successfully recruit into the mills enabled us to meaningfully engage and future choices. In order to create in this area. with all relevant stakeholders in order scalable change, we partnered with to create the most impact for the retailers Next and Varner, along with a Mills workers, the factory and the wider local NGO called SAVE and developed We worked to ensure better community. The key to the success of a programme aimed at increasing relationships between the workers this project was the collaboration with awareness of employment rights and and leadership teams in mills. This other retailers and a local NGO, as we building the mechanisms to bring meant ensuring that workers know recognise that - only by working in about positive change amongst 3 what is expected of them by the partnership, can we achieve real long- key stakeholders: the community, leadership teams, as well as ensuring term change. the labour agents and the mills that the leadership teams know what themselves. is expected of them from the workers Bangladesh

and wider community. We wanted to At The Very Group, we aim to partner Community make sure that training programmes with suppliers who understand At the Community level the main were embedded into the project with the importance of their workforce. aim was to increase awareness for respect to required workplace training Collaborating with suppliers like those who were seeking employment, as well as enhancing behavioural & life this enables us to raise the level highlighting what is and isn’t skills. of expectation of how workers are acceptable in the recruitment process. treated, by implementing training Confidence building measures with This was not exclusively aimed at the courses that take a holistic approach family and broader society were workers, as it was important to ensure to worker wellbeing and productivity. integral to the programme in order to the management teams understood In Bangladesh, we identified two of create an environment where potential the behavioural requirements the 16 factories we source from to recruits could speak out about the expected from them as well. Finally, implement a programme that focused experiences they had suffered. as per the community aspect, it was on productivity, worker-employer also necessary to ensure that effective relationships and general wellbeing. Ensuring human rights are respected grievance redressal mechanisms were during both the recruitment journey implemented. The human resources module was and whilst at work was central to the designed to increase dialogue between entire process, in order to offer workers Since the project was launched, workers and management to improve and their families a mechanism to raise we have reached over 8500 people ways of working. The training looked concerns Village Vigilance Committees throughout the communities as a at how processes within the factories Labour, Human Rights 8 and Due Diligence

could be simplified allowing workers workers, but especially women to take leave more easily and enabling workers, the tools to build confidence, factories to better plan production. find a voice and make more informed Alongside this buddy schemes choices both at work and at home. We Managing finances every were also set up, ensuring that new achieved this by providing training month was a struggle, but workers had someone to support on confidence and communication, thanks to the support given, them through their first few months as well as health and wellbeing, I now have a better view of my in the factory. As a direct result of this, particularly focussing on the important household’s monthly budget migration and absenteeism rates at of eating the right foods and drinking and can work with my husband both factories dropped significantly. plenty of water. The improved to manage our spend better. Absenteeism saw at least a 55% drop communication skills, coupled with the We have even setup whilst migration rates reduced by at benefits of the productivity module, a savings account least 86%. have led to more than 60% of workers for our child. now receiving an attendance bonus In order to have full engagement which is a significant improvement on from all key stakeholders we had to prior to the module’s inception. Malaysia ensure that there were clear benefits The Malaysian manufacturing sector to all parties. The productivity element The final part of this module focused is heavily biased towards migrant achieved this for the factory owners on financial literacy. It encouraged workers, with recent estimates as it resulted in a reduced defect rate, the workforce to open their own bank suggesting that there are up to five improved cut to ship ratios and also led accounts, understand necessary and million migrant workers in Malaysia to the factories implementing kaizen discretionary spending, how to create (around 15% of the population). practices that helped the leadership their own budgets and understand the Migrant workers are a vulnerable team better understand their existing benefits of saving part of their income. group, often exposed to poor living processes and where improvements This training gave the workers a clearer and working conditions, facing could be made. understanding of their income versus discrimination and social exclusion,

expenditure and in doing so improved and lacking the power to negotiate. Worker recognition schemes have also their ability to manage their finances. In The Very Group’s Malaysian supply had a positive impact on performance chain, migrant workers account for as well as staff morale, with Over 2200 workers have now nearly 70% of the workforce. motivational tools such as the “Hall of completed this training across the Fame” being introduced to highlight two factories and the worker feedback Migrant workers in Malaysia regularly good performance. speaks for itself: pay fees to unregistered and The general wellbeing element of misleading recruitment agencies the programme was entitled UP! prior to gaining employment, leaving and was split into 3 subsections; workers trapped in debt bondage. Communication, Health & Hygiene Alongside this, migrant workers are The course has increased my and Finance. often not made aware of their rights confidence so much. Before or terms of employment. starting this programme, Many of the workers in the garment I never thought I would be industry in Bangladesh are women, Through our third-party audit able to stand up and present who often have low levels of programme, we identified these in front of groups of people, confidence and feel disempowered risks in our own supply chain and so but doing this now allows me when it comes to making decisions. conducted visits to supplier sites in to share my knowledge Through the training we wanted Malaysia where we uncovered several with my colleagues. to address these challenges giving key risks, specifically relatedto the Labour, Human Rights 9 and Due Diligence

recruitment and employment stage. Kordus enables companies, to give Syrian refugees access to legal of migrant workers. suppliers, employees, labour providers employment and providing them with and recruiters to collaboratively support whilst in work. In China, our Since uncovering these issues, we drive greater transparency and team regularly visit factories across have worked with suppliers on efficiency and will enable users to the country to ensure a collaborative improving daily conditions for the make informed choices throughout approach to solving workers’ rights workers, including ensuring the recruitment process and their issues. We will continue this support improved health and safety and employment. The app will also allow over the coming year. dormitory conditions, as well as us and our suppliers to monitor the translating contracts and pay slips into recruitment journey and provide PARTNERSHIPS the workers’ local language. us with measurable data on the effectiveness and impact of our Partnerships are key to ensuring Last year, we hosted a responsible implementation of the Employer effective protection of workers and partnerships conference with all Pays Principle. so we play an active role with each suppliers where we stressed the of our partners to respond to the risk importance of the ‘Employer Pays’ Unfortunately, due to the and needs of our supply chain. We principle – a commitment that restrictions put in place by the continue to build and maintain strong ensures no worker pays for a job and Malaysian government on migrant relationships with varied stakeholders all costs are borne by the employer. workers entering the country we have including NGOs, trade unions and not yet been able to utilise this app to government departments to ensure There have been many political monitor people’s recruitment journey. integrity in our work and provide the changes in Malaysia over the last 12 This delay has though enabled us to best solutions to workers in our supply months, which have led to the main have the app ready in both Nepali chain. recruitment corridors from Nepal and Hindi and allowed for us to test and Bangladesh being closed whilst the information and suitability of the In the past year we new migration agreements are put app with workers already in factories. have continued to work in place. This has slowed our work The feedback we have had so far with several partner in this area but has led us to move has been overwhelmingly positive organisations including: our focus to ensuring workers who with many workers saying that migrate to Malaysia have the best they wished this information had United Nations Global Compact possible information prior to making been available to them during their A movement of sustainable companies the decisions. recruitment, so we are confident and stakeholders working together that when recruitment routes with shared responsibility for We have been working on the open up again we have an app that achieving a better world. development of a pre and post will support workers make more This year we took the decision to departure worker training app, Kordus, informed decisions. support their global workstream which will allow workers to fully Target Gender Equality, which will understand their recruitment journey. Outside of these key projects we further support and embed the work Kordus provides employees with a continue to work to ensure that the we currently do on gender both in user-friendly, mobile interface with all support for human rights and the our business and throughout our the information workers need to go expectations of worker conditions supply chains. Alongside this we joined through the recruitment journey and are raised throughout all our sourcing the child labour working group, this for life on the job. It allows document countries. We react to the most group brings together a number of storage, provides information to pressing social needs in each country stakeholders with a view to test and workers’ families, offers points of help such as working in partnership with measure innovative approaches to and invites real-time feedback at every Mudem and United Work in Turkey understanding and tackling child Labour, Human Rights 10 and Due Diligence

labour in supply chains. Participation garment sourcing highlighted through ILO Global Garment Industry in UN Global Compact working groups campaigning groups and the media. Call to Action further strengthens our approach We are actively working with other In response to the Coronavirus to human rights due diligence and Fast Forward members to develop pandemic in 2020 we announced enables us to learn and share best a response to the issues highlighted our support for the call to action practice across a range of industries. and ensuring the tool continues to which aims to bring together actors support the protection of workers in our from across the sector to help Ethical Trade Initiative garment supply chain in the UK. manufacturers survive the economic A multi stakeholder initiative attended disruption caused by Covid-19. We by companies, NGOs and Trade Apparel and General Merchandise have pledged the support of our team Unions working together to tackle the Public Private Protocol in India to the work and will continue complex challenges in global supply A revolutionary agreement with UK to play an active role. chains and achieve positive impact enforcement bodies including the to workers lives. Gangmasters and Labour Abuse Social Awareness and Voluntary This year we have submitted our Authority (GLAA), Department for Work Education (SAVE) annual report to the ETI achieving and Pensions (DWP), Health and Safety SAVE are our implementation partner improver status, making a 4% Executive (HSE), and HMRC to help for the work we do in Tamil Nadu. SAVE improvement from last year. We have eradicate modern slavery in the UK are a not for profit organisation who also contributed to the direction of the textiles industry. work for the elimination of child labour, China Working Group investigating Signatories to work together to empowerment of women and youth, and responding the Uyghur Human eradicate slavery and exploitation in promotion of fair labour standards, Rights Crisis in Xinjiang. textile supply chains. As a partner, we and comprehensive development of have pledged to raise awareness to both rural and urban poor community. British Retail Consortium (BRC) prevent worker exploitation, protect Alongside SAVE we continue to The BRC works with members to vulnerable and exploited workers and support mill workers and their drive positive change and use their disrupt exploitative practices within families through training and access expertise and influence to create an the industry. In the past year and in to information in both the mills economic and policy environment response to the issues raised regarding and wider communities. that enables retail businesses to UK sourcing we have continued to thrive and consumers to benefit. engage with this forum to ensure Mudem Over the last twelve months we have a united response in the changing A non-profit association, supporting increased our engagement with the landscape of risk to workers. refugees to access their basic rights BRC working with them on a range of and social rights by providing free topics, including UK manufacturing, Bangladesh Accord on Fire and legal advice in Turkey. Alongside this, the governments consultation on Building Safety MUDEM works to distribute aid for transparency in supply chains and The Accord is an independent, legally the urgent needs of refugees and gender equality. binding agreement between brands asylum seekers and to strengthen and trade unions to work towards a communication between community Fast Forward safe and healthy garment and textile organisations and public institutions A UK centric audit programme industry in Bangladesh. Over the last on the issue of refugees. working to ensure manufacturing twelve months we have continued to and processing units in the UK are support our factories with remediation United Work compliant to UK legal requirements against Accord inspections and now United Work functions as a non-profit and on a journey to leading industry have an average completed remediation organisation supporting refugees standards. rate of 95% with 5 of our factories in Turkey. They offer complimentary 2020 has seen the risks of UK being recognised as 100% complete. search and selection services based Labour, Human Rights 11 and Due Diligence

on job descriptions that companies In-country team visits The Very Group code of conduct, provide, organising interviews along – our in-country experts carry out which is signed by all suppliers, with pre-job trainings focusing on regular visits to our factories to offer states the following: enhancing soft skills, improving advice and support on improving • There must be no form of forced cultural learning and on social and issues and implementing best practice. labour, whether it be involuntary work life adaptation and work prison labour, indentured labour, permit consultancy. Training and capacity building bonded labour or otherwise. – where we recognise salient human • No employee should be obliged to HUMAN RIGHTS rights risks or identify problems work through force, financial DUE DILIGENCE relating to specific issues within our pressure, intimidation or any other supply chain, we work with partners means. Our dedicated CSR team, both in to develop and deliver training Workers are not required to lodge the UK and key sourcing countries, • to both factories and workers to deposits or their identity papers continues to work hard to understand mitigate and remediate these risks. with their employer and are free risks specific to our supply chain and to leave their employment after the countries we source from. From this work we recognise reasonable notice. that there is an increased risk of There must not be any form of To enable us to do • potential human rights abuses social pressure, unpaid loans or this we employ a due where there are: other restrictions imposed by the diligence approach which • A prevalence of migrant labour employer that would restrict encompasses several • Contract and agency workers workers’ freedom stages: • High presence of refugees • Young workers and risk of child A copy of the code of conduct can Desk-based country assessments labour be found here and supplier self-assessments Vulnerable workers • In line with the legislative requirement, – carried out via the use of internal Unauthorised subcontracting expertise and databases, Ethical • we updated our Modern Slavery Statement in December 2019 and will Trading Initiatives (ETI) updates, trade Certain countries within our operations further update this in December 2020 union risk maps and NGO country may have one or more of these risks reports. All suppliers are required and this leads us to more closely In our continued efforts to support the to complete a self-assessment monitor these areas. We do this fight to eradicate modern slavery over questionnaire related to their polices through regular visits by our in-country the past year we have built a strong and processes around human rights. teams, who offer additional support relationship with the International and guidance to our suppliers to Third party factory audits Slavery Museum (ISM) in order to look ensure that they are managing – we understand that audits only at opportunities for collaboration. these situations responsibly. provide us with a snapshot in time The ISM is based near to our head at our manufacturing sites, however MODERN SLAVERY office in Liverpool, so we have begun they remain a crucial part of our due the process of developing training diligence programme. Our audits are As a business we recognise the risks for our colleagues as well as looking carried out by three third party audit of potential modern slavery within our to develop an initiative that would companies against local law, our code supply chains and also understand the increase community engagement of conduct and the ETI base code. need to take a holistic approach and and demonstrate to the general These audits allow us to identify risks work with our suppliers, factories and public that slavery is an ongoing and enable our in-country teams to peers to tackle the root causes in order problem that we all need to work work with factories on improvement to achieve lasting change. together on to eradicate. actions. Labour, Human Rights 12 and Due Diligence

COVID-19 As factories began to increase In May of 2020, The Very Group production again after the initial endorsed the ILO global garment outbreak, we quickly moved to industry call to action, which aims to As Covid 19 struck across the mitigate risk where we felt we could bring together actors from across the world, we were acutely aware make the most impact. All factories sector to help manufacturers survive of the impact it would have in India and Bangladesh were sent the economic disruption caused by on the workers across our best practice guidance and training the Covid-19 pandemic and protect supply chain. As production materials to enable them to reopen garment workers’ income, health slowed down across the world, safely and ensure that measures were and employment. We will continue our in-country teams quickly in place to protect workers and staff. to collaborate as the lasting effects mobilised to support those We also continued to support our of the pandemic continue to evolve. most vulnerable by providing factories with orders during this time food and hygiene parcels, and ensured that all orders made and through trusted NGO’s on in production were taken and paid for. the ground. In Bangladesh we recognised that access to In order to address issues as complex running water can sometimes as those presented as a result of the pandemic, we understood the need be limited in worker to collaborate with partners, industry communities, so to combat peers and international organisations this we worked with our to play our part in a concerted effort in-country partners to install to support those who have been hand washing stations in key affected by it. communities for workers and their families.

PLANS FOR 2020/21

In FY 20/21 we intend to: CCR CSR partner to support in Continue to work with the ETI and Fully map our tier 2 supply chain. remediation of suspected or AGM PPP to develop an industry confirmed child labour cases response to the issues in the Partner with Unseen, gaining Reach 10000 people through our garment supply chain in Leicester access to their Modern Slavery community centres in south India and commit to a sector wide helpline further supporting our Launch a community initiative solution. efforts in the UK. in Bangladesh offering workers access to skills training and Explore our non-stock supply Roll out the use of Everyone’s welfare support. chain and understand risk. business, a web platform Roll out the use of the Kordus app enabling everyone in the for recruitment of migrant workers business to carry out. into Malaysia. People & 13 Colleague Culture

APPROACH trading performance, economic the business’ expectations, and help conditions and other relevant matters. colleagues focus their efforts on The Very Group is compliant with all They are also represented on our what matters most. UK employment law and we pension trustee boards. During the proactively look to integrate updates COVID-19 pandemic, we relied more Development and improvements. For example, on digital communications to Our focus remains on building a we have recently updated our policies engage our colleagues than ever collaborative, customer-centric in line with the Senior Manager before, including a recent two-day business. In view of new ways of Certification Regime. digital conference to bring all of our working and in line with The Very colleagues together remotely. Mindset, we revised our core learning POLICIES offer to include behavioural and digital SUMMARY OF PROGRESS skills. We also revised our approach We want to create the best possible to delivery to create a high impact company to work for. A great learning culture, providing a more COVID-19 response environment for our people will help blended learning approach. To support During COVID-19, we supported us thrive together as a business. colleague wellbeing, we ramped up our people in working remotely, According to Retail Week research our coaching offer, providing every including setting up our contact centre based on Glassdoor data published colleague with the opportunity to colleagues to work from home for the in August 2020, we are the third best ‘call a coach’ to help them focus their first time. This included embedding retailer to work for in the UK – so we thinking and plans in any aspect of new policies and technology, whilst know we are on the way to achieving their work or life. We also rolled out introducing new procedures to our ambition. mental health awareness training to support colleagues working from all colleagues, helping them to explore home. In addition, we developed a We believe that we will create the mental health and raise awareness, new, permanent working model, best possible company to work for by and share tips to help people support which will see our colleague spend accelerating our digital transformation their own and others’ mental health. on average half their time working and investing in people. Our plan remotely and half their time in the focuses on creating a high-performing Leaders office. We will work to embed this culture, attracting more amazing, The Very Mindset redefines what we new model in the coming year as diverse talent and re-writing how expect of our leaders and we provided soon as it is safe to do so. we work together and collaborate. a self-assessment tool for all leaders

Coronavirus has accelerated our plans to help review themselves. This is Performance and helped us make huge progress in giving us the insight on which areas of To support our colleagues who found a short time, whilst remaining true to leadership need further development. our values and our purpose. themselves working remotely as a result of the pandemic, we revised our Early talent PARTNERSHIPS approach to performance. We provided We continue with our strategic greater rhythm and routine, clarity of partnership with schools and We continue to seek full and open expectation and better connection to universities to fuel our talent pipeline dialogue with our colleagues and their others via online tools, while continuing and provide specific development representatives through channels such to support development and wellbeing for our existing apprentices, interns as people forums, joint working parties, remotely. We also introduced The Very and graduates. We’re also exploring briefing groups and our collective Mindset, a tool that defines how we new initiatives to encourage young bargaining approach with the USDAW work together to live our values and talent to our business. and SATA trade unions. We keep create our target culture. Both our colleagues updated on corporate and revised approach to performance and individual business unit objectives, The Very Mindset give better clarity of People & 14 Colleague Culture

Fulfilment In response, we reduced our leaders’ We continually review our benefits We continued to support colleagues and senior managers’ salaries by offering so colleagues can reshape and communities impacted by the 20% in April and May 2020. Following their benefits package to suit them closure of our Greater Manchester a strong commercial performance each year. Linked to our focus on fulfilment centres, right up to the throughout the pandemic, this money wellbeing, we have partnered with closures of Little Hulton and Shaw in will be repaid to all affected colleagues Nudge, an organisation which provides July and August 2020 respectively. in December 2020. In addition, we colleagues with personalised financial We worked with a taskforce including continue to operate a market-based education to help make money our trade union Usdaw, as well as a salary approach. This fairer and more matters simpler. wealth of local councils, Government transparent approach to our annual bodies and inward investment pay review process was well received Diversity and inclusion organisations, to deliver a coordinated by colleagues, and will continue for a In addition to annually publishing package of tailored support for each further two years before it is reviewed. the work we are doing to reduce the colleague to help prepare them for the The next annual pay review process Gender Pay Gap within our business future. This included apprenticeships, will take place in [April] 2021. This will we have taken proactive steps to forklift truck accreditations, functional provide additional time for cross-market become a more diverse and inclusive skills training, and career and wages to normalise following the early organisation. In March 2020 we employment training. The collaborative impact of the pandemic. partnered with Stonewall in order model for colleague and community for them to become a critical friend support has since been recognised As a business, we go beyond the to our business and highlight areas as a benchmark model by other minimum when it comes to colleague where we could improve. As a result companies and stakeholders in similar benefits. Our minimum pension offer of our initial discussions, we became circumstances. We continue to support is 4% of qualifying earnings split equally, members of their Diversity colleagues who have now left the rather than the government split of Champion programme. business and track their progress. 5% employee and 3% employer.

At our new fulfilment centre in the East Midlands, which is now operational, we have so far hired 800 committed and talented colleagues. Our ability to secure mutli-skilled talent is underpinned by a colleague proposition that we believe sets us apart from other organisations locally, and includes flexible working patterns and on-site wellbeing facilities like a gym and multi-use games pitch.

Colleague reward During the pandemic, we made some early decisions to protect the financial stability of our business. Like every retailer, at the outset of COVID-19 we did not know how our business would perform. We stress tested against a scenario in which Group revenue declined by 25% in Q4. People & 15 Colleague Culture

We will continue to work with WOMEN’S EMPOWERMENT themes and purpose of the principles Stonewall over the next 12 months, Across all our operations at The Very met with our own values and that to working towards their Workplace Group, we strive for gender equality further our work on gender equality Equality Index. We also built on the whether that is in our head office or we should adopt these principles. work of last year by continuing to logistics operations in the UK, support Pride in Liverpool. or in our key sourcing countries The importance of the WEPs were across the world. clear to our Group CEO Henry Birch, Following the tragic death and with his support we proudly of George Floyd and the announced our commitment to increased spotlight on the this initiative and advancing gender equality. As of January 2020, we Black Lives Matter movement, We have successfully became The Very Group, so to sign we made a commitment to developed and delivered training programmes in these principles and publicly commit listen, learn and understand India and Bangladesh to upholding them in our first month more, take action to continue which put gender under our new name is a decision that to make things better in equality at their heart, we are very proud of. our workplace, and invest in aiming to ensure the fair our brands to ensure they treatment of workers in To further support our work on Gender are even more supportive our factories. Equality we are also part of the UN and representative of all of Global Compacts Target Gender the communities we serve. Equality workstream. The objective This began last year with of this global working group is to a colleague census to help Gender inequality reveals itself in generate behaviour change across us better understand the different ways across the world, so we over 1000 organisations, supporting different people who make up recognise that this is a global issue and women’s participation and leadership different approaches may be needed in business. As a first step in this The Very Group. We will use depending on the country to properly process, in April 2020, we started these findings to take action. address it. On a trip to India in October undertaking a gap analysis using the And while we were unable 2019, our sustainability team visited WEPs tool to gain an understanding to hold our annual diversity the United Nations offices in New of how the company is performing in and inclusion conference, Delhi to meet with representatives comparison with our peers and what Inclusion Live, we heard from from UN Women. During the we can do to improve. This process will a number of external speakers meeting, we discussed the Women’s continue into the new financial year on the subject at our digital Empowerment Principles (WEPs). as we continue to participate in this conference during lockdown. It quickly became apparent that the multi-sector working group.

PLANS FOR 2020/21

We will continue to embed We will also work with experts a historic, systemic and performance and The Very to develop a new Race at Work unconscious bias level, enabling Mindset, and focus significant development programme for them to recognise what they time in supporting our leaders to our leaders. Our ambition is can do differently to drive change. lead effectively in a post pandemic leaders – and later, all colleagues – and virtual working environment. to better understand racism at 16 Charity

POLICIES During the partnership, colleagues reading charity Coram Beanstalk as organised a huge range of fundraising our new partner. We will raise £600,000 We continue to play a positive role in initiatives, including a charity ball over two years, as well as providing our communities through our charity featuring pop stars Jason Donovan, industry-leading tech knowledge, to programme. Our colleagues vote Blue and S Club, which raised £210,000. help Coram Beanstalk support 40,000 for a digitally focused project that 40 colleagues took the plunge with children with one-to-one reading will deliver maximum impact in the sponsored sky dives from 15,000 feet, support. locations in which we operate. We while others completed an overnight support our chosen charity through ‘sleep out’ in our HQ carpark. The partnership will enable the charity colleague fundraising, as well as to expand its network of reading our digital expertise. With support from our colleagues, helpers in the North West and London, the charities have begun investing and to launch a network in the East The following policies underpin the funds in digital inclusion initiatives, Midlands, where our new fulfilment our approach: including an online advice service centre is located. • We match-fund colleague for young homeless people, a youth fundraising up to £200 per activity awareness programme to reduce Coram Beanstalk will also use the • We raise funds for our charity homelessness for future generations, funds raised to develop a new digital partner through a biennial improving Wi-Fi at their centres and platform and training materials to themed ball creating IT suites used by people support its reading helpers nationally. • We offer payroll giving to allow of all ages. The technology will connect helpers colleagues to donate directly with each other and allow the charity to their chosen charities By the end of the partnership, the to recruit new volunteers even more new digital infrastructure had effectively. PARTNERSHIPS already allowed the charities to host 430 employment and skills training Activities so far have included charity The Booth Centre and sessions, helped 406 people into visits to all company sites to drive The Whitechapel Centre employment and 315 people to gain colleague engagement, regular Over a two-year partnership that qualifications, with much more group-wide communications and a ended in December 2019, we raised activity to come. calendar of group-wide fundraising £710,000 for The Booth Centre, activities, including dressing up for Manchester and The Whitechapel Coram Beanstalk World Book Day, a ‘digi-pets’ colleague Centre, Liverpool, smashing the In February 2020, we announced that voting competition and sponsored £600,000 target we set in 2017. our colleagues had selected national sunflower growing.

PLANS FOR 2020/21 The amount represented the largest We will continue to support and This will be supported by our donation ever received by engage our colleagues to reach commitment to a shared the organisations, which provide support for people our target of £600,000 for Coram innovation board to share affected by homelessness, Beanstalk, including offering knowledge and expertise to drive social exclusion and up innovative new ways for our the project, as well as working housing poverty in the colleagues to raise funds remotely more closely with our retail teams North West. as we continue to encourage to spot commercial opportunities home working during the that align to best-foot-forward coronavirus pandemic. brand campaigns. Environment 17 and Travel

ENERGY of road miles and carbon emissions 2020 with air, train and road mileage versus our previous inbound for work activities seeing a significant The Covid 19 pandemic has resulted in logistics processes. reduction. Given planned travel and a reduction of energy usage across our accommodation that had to be The group decided to incorporate office facilities with colleagues working cancelled, in addition to what we a closed loop system with regard to from home in line with government would have otherwise seen booked at procuring cardboard. Our partner guidance. As a pure digital retailer the this time of year, our carbon emissions Smurfit Kappa provide all of our pandemic has forced us to review our were 25% less than we would have cardboard required for deliveries. ways of working; resulting in home anticipated. As a key business during Smurfit Kappa also collect our working becoming part of a new the pandemic our operations have decanted inbound logistics cardboard normal, with this in mind we expect continued to serve our customers which is baled, along with customer that going forward we will continue to ensure people are still able to buy returned cardboard packaging, to see this reduction in energy what they need online when retail which is then collected and recycled. consumption at our offices. stores were forced to close. This has resulted in increased deliveries via our Our refuse partner Veolia have The Very Group continue to work with outbound logistics partners, and we will collected all other waste produced Inspired Energy to ensure our energy be working hard to reduce our negative by the group during the financial year consumption is monitored, assessed carbon impact from the increase in 19/20, out of which 44.56% of waste and reduced to be as efficient as deliveries, in the coming financial year. was successfully recycled. possible.

We continue our LED replacement At the end of the financial year we In March 2020 our new project across our head office engaged Mitie to conduct an energy £250million fulfilment centre operations and now 60% of lights tender for our business operations, opened in Castle Donnington, utilise energy efficient LED fittings. through this process we will be able which has resulted in further to explore renewable energy options consolidation of sites across The pandemic has seen our business with a view to switching to these the group as we migrate travel rapidly reduce from March where possible. to just one warehouse for all distribution.

The warehouse uses state of the art technology to operate as efficiently as possible. As an A-rated energy certified building it is designed with the highest levels of energy efficiency in mind. The building incorporates water harvesting technology, LED lighting, onsite generation offsetting as well as potential for a solar panel installation to generate our own renewable energy. The Warehouse is located by a rail freight terminal which means our imported goods arrive to the warehouse by train. This has significantly reduced the amount Environment 18 and Travel

Energy and Carbon Report

FY20

Energy performance results Carbon performance results

Carbon Energy Dioxide use Equivalent (kWh) Emissions (t/CO2e)

Gaseous fuels Purchased electricity Transport Gaseous fuels Purchased electricity Transport 13,119,658 19,957,931 774,387 2,412 5,101 18

TOTAL TOTAL 33,851,976 7,699

ENERGY AND CARBON PERFORMANCE COMMENTARY

The Very Group is a member of the Carbon Trust, a 16.6% the Carbon Trust and works in absolute reduction in its carbon collaboration with them to pursue footprint has been achieved ways of minimising our carbon and the group continues to footprint. In the 4 years since The work on a 3% reduction Very Group began working with each year. Environment 19 and Travel

SUSTAINABLE COTTON In 2019, we successfully started the With our move to BCI cotton plan on Fashion to hit a total BCI and our intention to utilise cotton percentage of 16.6%. For more sustainable fabrics FY20, the goal will be to have 50% of all cotton used in the business within our clothing ranges to be BCI cotton. This will mean an going forward we sought to increase in the amount of BCI cotton identify a way of formalising used in Fashion by three times as our commitment to this, much as the previous year, as well to help us better engage as introducing BCI cotton across colleagues and customers. our Home categories. This will step This led us to the Textile up again in FY21 to a 90% share Exchanges Sustainable Cotton before reaching our target in FY22 Challenge, supported by the of 100% BCI cotton, as part of our Prince of Wales, where brands commitment to more sustainable commit to purchase 100% of sourcing. their cotton from sustainable sources by 2025. For FY20, We have worked to embed this initiative and developed our own the goal will be commitment to exceed the targets to have 50% of the Sustainable Cotton Challenge of all cotton used of 100% sustainable cotton by 2025, in the business we drafted a 4 year plan to ensure that all cotton used in the business, to be BCI cotton. across all Fashion and Home categories, will be BCI cotton by 2022.

Targets 2020/21 • During the next financial To sign up to the British Retail year, we aim to have moved • Consortium (BRC) roadmap our electricity from fossil fuel to net zero for retail to renewable energy • To sign up to RE100 • To complete a solar power Complete the LED retrofit energy tender and • at our head office installation at our new Skygate fulfilment centre 20 Anti-corruption

POLICIES • Negligence or breaches of SUMMARY OF PROGRESS contract including the AND MEASUREMENT OF We have maintained our zero- performance of or omissions in OUTCOMES tolerance approach to corruption, relation to administration or any which is underpinned by a or those described in the scope Specific areas of focus and number of key policies and • Inappropriate behaviour or development over the period processes, including: relationship with or towards included: suppliers or any other third • Conducting annual refresher Any gifts, hospitality and entertaining parties with who the Company training on key policies, with must be formally approved in has a relationship the training module driving 97% advance and must be appropriate, • The deliberate concealment participation and engagement proportionate and not have the of any of the above • All internal policies were regularly ability to unduly influence decisions. reviewed as part of our ongoing Calls to the whistleblowing line are assurance activity Any potential conflicts of interest entirely confidential and where a call • Our gifts and hospitality policy must be declared, and registered, and is received, an anonymous report is has been re-communicated to potential mitigating action considered provided to nominated persons within all relevant colleagues by the appropriate director. TVG for independent review, and where • Bribery and corruption risks appropriate further investigation. were considered within all A confidential whistleblowing line The outcomes of all calls and any relevant internal is in operation and is operated by resultant investigations are reported Falsification of accounts a third party. The whistleblowing to our quarterly Audit Committee. • line is available to anyone, who has MEASUREMENT OF reasonable grounds to believe that All new suppliers receive The OUTCOMES they have information relating to: • Very Group’s code of conduct We report on adherence to bribery and a statement of our zero- The commission of a and corruption policies in our quarterly • tolerance approach to bribery and criminal offence audit committee including the corruption, with existing suppliers The failure to comply with outcome of any whistleblowing • also receiving periodic a legal obligation cases. There were no instances of non- reinforcement communications A miscarriage of justice adherence to policy identified during • Bribery and corruption risks are Danger to health and safety • the period and all whistleblowing • reviewed on an annual basis Damage to the environment incidents were independently • and are factored into the audit Criminal acts committed investigated to a satisfactory outcome. • planning process against the Company such as theft, deception, fraud, bribery • All employees are trained annually and corruption on the above key policies, • Blackmail including a knowledge check PLANS FOR 2020/21 • Falsification of accounts • Bullying, harassment, victimisation, PARTNERSHIPS We are currently reviewing key discrimination, racial or ethnic policies to ensure consistency and We manage our own policies through intolerance towards or by workers drive awareness at the Very Group. internal teams. Our confidential or those described in the scope In parallel with this, we will review Breach of health and safety or whistleblowing line is operated by • and update all key processes as environmental law in relation our external service provider, In Touch. appropriate and online training to Company workers or those will be updated and refreshed for persons described in the scope all colleagues in November 2020. Data, security 21 and privacy

POLICIES PARTNERSHIPS SUMMARY OF PROGRESS

At The Very Group security underpins We work with leading security As part of our security all our activities. We are committed organisations to help us deliver transformation across this to building stronger defences to a cyber resilient service for our period, we: thwart cyber-attacks, preserving customers. • Had a full audit of our Security KPI the confidentiality, integrity evaluations. Ensuring that we have and availability of all customer These partnerships include: the correct methodology in place information. • NCSC - the UK’s National Cyber to rate and improve our cyber Security Centre, which advises security controls With our new Head of Information organisations on how to protect Improved our defences against Security in place we have reviewed • their information and information Credential Stuffing and other cyber and updated all the policies and systems against today’s threats related attacks on our website Standards related to Information ICO – the UK’s Information Continued with our strategic and cyber security. • • Commissioner’s Office, which education and awareness upholds information rights in the programmes across The Very Our policies and procedures public interest and data privacy Group. Including regular phishing outline our guidelines and for individuals tests of our colleagues provisions for preserving ISF – the Information Security Commenced the roll out of the security of our data and • • Forum, which is the world’s leading multi-factor authorization for technology infrastructure: authority on cyber, information our colleagues using Group Information security • security and risk management Microsoft Office 365 policy: ensuring that the business IBM – IBM provide enterprise-wide implements a secure environment • security intelligence and expertise to protect the confidentiality, integrity, and availability of all information, in all its forms held by or on behalf of Shop Direct • Acceptable use policy: ensuring that our colleagues are aware of their responsibilities in regard to protecting company and customer data • Secure configuration: establishing and actively maintaining the secure configuration of information and communications technology (ICT) by having policies and processes in place to develop secure baseline builds • Data security risk management policy demonstrates our upmost commitment to comply with those relevant laws and legalisation related to data privacy • Data protection policy: ensuring the business applies the principles of the data protection regulations Data, security 22 and privacy

MEASUREMENTS OF This allows us to measure and OUTCOMES report upon the effectiveness and value of our security programme Using information security and security investments. KPIs, we regularly assess and measure our resilience to We also work towards independent certifications for cyber threats by objectively our security measures to evaluating our environments protect customers’ financial against global information and personal information. security standards like the NIST Cybersecurity Framework, ISO/IEC 27001 and compliance requirements like PCI DSS, the Data Protection Act and the GDPR.

PLANS FOR 2020/21

The biggest security regarding the organisation’s We are building an approach that improvements this year will be information security activity, will ultimately lead to alignment the set-up of our Technology costs and prioritisation. with the NIST Cybersecurity Operations Centre or TOC. Additionally, this will facilitate the Framework and ISO/IEC 27001, work of our Head of Information which are standards, guidelines, This will be a 24/7 team monitoring Security, as it provides continuous and best practices to manage both operational and security and up-to-date security cyber security-related risks. Our alerts, we are bringing all security measurements necessary to capabilities to identify, protect, operations in house with our own support management decisions. detect, respond and recover will be SIEM tool providing a single pane greatly enhanced by these efforts. of glass for the TOC to monitor We will also: This will also help to address security alerts. Continue to mature information compliance requirements, such • security as the GDPR and PCI DSS, all of We will continue to build on Increase our technical capability which will support the security our security KPIs tool, which will • Meet our regulatory and CSR and privacy of customer data. empower our board to understand • requirements the current cyber threats and Use information security to associated defences so that they • enable and enhance the can make informed decisions business 23 Financial services

POLICIES PARTNERSHIPS SUMMARY OF PROGRESS

As a responsible lender authorised by Shop Direct Financial Services is the We are proud of the range of the FCA, we will not lend to customers sole provider of credit facilities to financial services products we offer where we believe the lending is support our retail offering. This enables and the important role we play in unaffordable or unsustainable. customers to finance their purchases our customers’ lives. using clear, easy to understand We monitor customers’ financial credit products. wellbeing every month, both in terms We take our In addition, we partner with other of account performance with Shop responsibilities as a lenders to offer credit card and Direct and external performance using credit provider seriously unsecured personal loan facilities to credit bureaux data. This information and as such ensure customers. Before working with other is considered in every credit lending that we have a suite lenders, we conduct due diligence decision we make using highly of policies in placed to to ensure that firms are acting predictive scoring systems, which ensure we do things in responsibly and in line with ensures that our decisions the right way. are consistent and robust. regulatory requirements.

We continue to enhance both our product offering and customer journey to ensure that our customers are provided with credit products that meet their needs and are clear to understand.

This includes our improved self-serve functionality which allows our customers to manage the amount of credit that they have with us at all times. 24 Financial services

MEASUREMENTS OF We also recognise that there may be OUTCOMES times when customers experience financial difficulties, for a variety We continue to ensure that good of reasons. Whilst most customers customer outcomes are at the heart are able to resolve these difficulties of everything we do - from ensuring without assistance, we know that a customer can afford the credit some customers require support from we provide to them, to supporting us. At such times, those colleagues customers through periods of who are trained in dealing with financial difficulty. people in financial difficulty work with individual customers to find solutions Our creditworthiness and affordability to meet their needs. Solutions approach ensure that we continue to range from short to longer-term enhance our capability to provide an arrangements and, if we identify that ongoing assessment of our customers’ the customer is in broader financial circumstances, making sure that we difficulty, we refer customers to continue to make the best and most independent debt advisory services responsible possible credit decisions and charities. based on the most up-to-date information available. We continue to protect our customers by investing heavily in measures to Our proactive approach to prevent and detect criminal activity assessing the financial wellbeing and lessen the effects this can have of our customers can result in us upon our customers and wider society. refusing or restricting the credit Our fraud prevention measures afforded to some customers. improve each year and we currently Last year, this resulted in: deploy machine learning solutions to • Shop Direct only accepting identify likely potential fraud before 31% of new applicants referring these cases for human review • Shop Direct affording c.900,000 and decision. This approach allows us credit limit increases to existing to detect fraud trends and patterns customers whilst ensuring that we reduce the • Shop Direct reducing impact our fraud prevention strategies c.1,400,000 credit limits have on genuine customers.

PLANS FOR 2020/21

We will continue to test and whether that be with regard to an We will continue to enhance our develop additional tools to help individual lending decision or by customer journey and associated us understand and monitor identifying potential vulnerabilities communications, providing our customers’ use of credit. and proactively reaching out to customers with reminders and Using near-time data, we will customers to offer support. timely education pieces to ensure continue to better personalise that they are aware of the risks our approach for customers, associated with using credit. 25 Action Plan

In 2020/21, in addition to Planet Charity our ongoing strategy to implement the SDGs and Move our electricity supply from As we move into the final year of our embed the Ten Principles fossil fuels to a renewable source. 2-year partnership, we will reach our across our operations we goal of hitting £600,000 to donate will also work towards Achieve at least 80% recycled content to Coram Beanstalk. these key targets in despatch bags and implement a closed loop system for packaging. Data People Launch a clothing takeback scheme We will create a public charter to

with external partners for customers demonstrate to our customers the 10,000 workers trained across to enable them to act more importance that we place on their the supply chain we will seek to sustainably. data protection. strengthen our relationships with more factories across our supply Communities Financial Services chain so projects like what we have seen in Bangladesh can Build on partnership with the We will work with external partners to be embedded further. International Slavery Museum to create a financial services education create a community engagement programme, to educate young people Open six community centres in programme educating people on the on responsible lending and access Southern India to support mill signs on modern slavery and what to credit. workers and their families: providing they can do to help combat it. health, wellbeing and legal support and training opportunities.

When recruiting we will ensure that our shortlists are no more than 75% filled with applicants from one demographic.