SUSTAINABILITY AT BROWN THOMAS AND ARNOTTS 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 Selfridges 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 to the 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, Dublin 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, Cork 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 retail 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 3 Modern Slavery Statement, 30/06/2021 SUSTAINABILITY AT BROWN THOMAS AND ARNOTTS 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, De Bijenkorf and Holt Renfrew; • 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; 4 Modern Slavery Statement, 30/06/2021 4.0 OUR APPROACH: POLICIES 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.