1 2 ASOS Modern Slavery Statement February 2020 – January 2021 3 Contents Introduction 5 ASOS Brands 21 About ASOS 6 Due diligence 21 Our supply chain 7 Audit programme 21 Spotlight issues 24 ASOS brands 7 Uyghur forced labour 24 Supplier and factory data 7 Modern Slavery Innovation Fund 25 Policies and contractual controls 8 UK risk 26 Third-party brands 9 Procurement 9 Contents Progress report 27 COVID-19 pandemic 11 Procurement 29 Our approach to business and human rights 13 Third-party brands 32 Empowering workers 14 Addressing business impact 15 Collaboration and Engaging on policy and legislation 16 stakeholder engagement 33 Anti-Slavery Our ongoing commitments International Reflections 17 and future plans 36 Assessment of effectiveness 37 4 Introduction ASOS is committed to respecting, protecting and championing the human The COVID-19 pandemic has brought unprecedented challenges for the fight rights of all who come into contact with our operations, including employees, against modern slavery. It has required various stakeholders – businesses, supply chain workers, customers and local communities. Modern slavery is trade unions, governments and multilateral organisations – to re-evaluate unacceptable within our business and supply chain, and combatting it is an their roles and responsibilities to protect lives and build social protection important element of our approach to business and human rights. We accept systems and business resilience to the new reality, while seeking to our responsibility to increase transparency; to find and resolve problems; support businesses and the health, safety, employment and income of to review our business practices regularly; and to collaborate with others to vulnerable workers. At ASOS, we are doing all we can to mitigate the risks to protect the rights of workers, particularly those who are most vulnerable to workers, and further detail on our approach is detailed in this statement. abuses such as modern slavery. This statement details how ASOS’ approach to business and human rights is Introduction This, our fifth Modern Slavery Statement, has been published in accordance helping to tackle modern slavery in our supply chain. It provides an update with the UK Modern Slavery Act (2015). Section 54, Transparency in on the activities and commitments detailed in our fourth Modern Slavery Supply Chains, has brought businesses into the heart of the UK’s modern Statement and the steps taken from February 2020 to January 2021. The slavery agenda, challenging them to identify and address modern slavery statement also outlines our commitments towards mitigating the risk of and transparently report on actions taken. As an international business we modern slavery in our supply chain to 2022. welcome the increasing momentum towards mandatory human-rights due diligence in a number of countries, recognising the need for harmonisation Impact of acquisition and alignment of the existing and proposed frameworks. This statement does not cover acquisitions made in February 2021, but we look forward to reporting on these in future statements. Please see our public As more businesses disclose their risks, findings and actions, together we statement here for our approach to the Topshop, Topman, Miss Selfridge & add to an industry-wide discourse on tackling modern slavery, learning from HIIT supply chains. one another and discovering opportunities to collaborate. At the same time, businesses should also be looking to develop ways to tackle the root causes of modern slavery in supply chains, such as lack of access to freedom of association and collective bargaining, purchasing practices, and a living wage. 5 About ASOS ASOS is an online shopping destination selling womenswear, menswear, footwear, accessories, gifts and beauty products to millions of fashion-loving 20-somethings in more than 200 markets. c.3,280 2,691m 85,000 About ASOS employees visits to our products available to purchase platforms FY2020 at any one time, with up to 5,000 new products a week 23.4m 24.2m 850+ active customers followers across our third-party brands in 2020 social media platforms Business Structure ASOS is based in the UK, with its head office in London, a smaller technology office in Birmingham, and a Customer Care hub in Leavesden. Three third-party-run fulfilment centres (Barnsley, UK; Berlin, Germany; and Atlanta, USA); with investment in a fourth under way (Lichfield, UK) Five third-party-operated returns and reprocessing sites (Poland; Czech Republic; UK) 6 Our supply chain ASOS Brands ASOS Brands products are designed in-house, manufactured by third-party Supplier and factory data: supplier factories and sold on our platforms. The Responsible Sourcing team Data correct as of January 2021 manages the ASOS Brands supply chain. The Ethical Trade and Responsible Materials teams are located within this department to ensure product and 27 source countries raw material suppliers are selected based on ethical and sustainable, as well as commercial, criteria. Product supply chains are complex, involving 160 suppliers a number of different manufacturing processes. ASOS maps and describes Our supply chain them as follows: 930 factories (tiers 1 to 3) Tier Definition Example Status 174,267 workers (tiers 1 to 3), Tier 1 Main Factory which cuts, sews, finishes ASOS Fully of which 49% are male, production sites Brands product and ships to ASOS mapped Tier 2 Process integral Provider of one or more processes, Fully 51% female, 12% migrant to production e.g. stitching, cutting, packing, mapped quality control, warehouses Tier 3 Enhancements Provider of one or more processes, Fully to product e.g. printing, dyeing, laundry, mapped embroidery Tier 4 Fabric and Fabric mills, tanneries, Partially components hardware and trims mapped Tier 5 Raw materials Textile fibres, natural Partially and manmade materials mapped 7 Policies and contractual controls Guidelines ASOS Supplier Ethical Code: is aligned with the Ethical Trading We have also developed guidelines to support our suppliers Initiative Base Code and International Labour Organisation’s Fundamental in implementing our policies. Conventions and defines the minimum standards we require from our suppliers. It includes what constitutes forced or compulsory labour. ASOS Accommodation Guidelines: developed in 2019, provides guidance for suppliers on the provision of accommodation for workers. ASOS Child Labour Remediation and Young Worker Policy: sets Poor accommodation and associated excessive fees can be an indicator of out the steps suppliers need to take to protect young workers and to make modern slavery. sure no children are involved in the manufacture of any of our products. If we discover child labour in our supply chain, the policy sets out our remediation ASOS Migrant Worker Guidelines: provides guidance for process. It also prohibits the recruitment of young migrant workers through suppliers in the implementation of our Migrant Worker Policy. labour agents. Our supply chain ASOS Supplier Compliance Guidelines: due for launch in June ASOS Migrant Worker Policy: sets out supplier requirements to 2021, these encompass universally recognised best practice guidelines for safeguard the rights and welfare of migrant workers, a group that has been suppliers, to support them in the implementation of and compliance with all identified as vulnerable to exploitation and modern slavery. In 2019, we of our policies. developed more detailed guidelines to accompany the policy for suppliers employing migrant workers. ASOS Homeworker Policy: developed in 2019, this outlines our positive recognition of the role homeworkers play in our supply chain and sets our supplier requirements to protect and respect homeworkers engaged in the manufacture of our products. ASOS Freedom of Association and Collective Bargaining Policy: newly developed in 2021, this policy expands on the freedom of association requirements outlined in our Supplier Ethical Code and recognises the role of freedom of association and collective bargaining as being fundamental for the realisation of other labour rights, setting out supplier requirements to ensure this right is protected. 8 Third-party brands Procurement Other products from third-party brands are available for sale Our Responsible Procurement programme covers non-stock goods on our website (‘third-party brands’). and services, including outsourced customer deliveries, logistics, technology, marketing, property, cleaning and catering. There are 850+ brands, which make up approximately 60% of our total business. The vendors are grouped under three main categories: • Logistics & Supply Chain Our Head of Sourcing and Branded Engagement oversees our strategy • Property & Facilities Management to ensure the implementation of our five minimum requirements, which we • Services expect all ASOS third-party brands to comply with. Last year we transacted with 1,74 4 non-stock suppliers, while our These five minimum requirements are: top 20 non-stock represent 77% of our total spend. See page 28 Our supply chain • Brands to have an Ethical Trade Policy, which is for further information on our Procurement programme. implemented across their supply chain. • Brands to have Visibility of ‘tier 1’ (Cut Make Trim) factories and be willing to share a factory list with ASOS Governance and collaboration if required. • Brands to comply with all the relevant regional chemical Procurement plays an instrumental role in our day-to-day business operations regulations in the countries they