HELA BRANDS LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents

Training described

Your front line staff Human resources Executive-level staff Procurement staff

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Professional auditors Workers within your organisation

Social audits

Audit conducted by your staff Third party audit arranged by your organisation Third party audit arranged by your supplier Announced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Other monitoring

We have consolidated our supply base by 30% which has enabled us to work closer on standards and policies with our Tier 1 partners and to embed our code of practice into their operations.

Demonstrated progress

We do not disclose our findings of specific concerns relating to labour exploitation or modern slavery in our statement. The company has worked with the GLAA and Unseen on specific areas of concern. As members of Unseen, public disclosures, where relevant are published on their site and where required first responders have reported to the required authorities. Within our organization training and awareness is paramount to the success of our commitment and this is embedded in the Group.

Reported risks and mitigations

• Risk: GBVH in our India supply chain. We are working with AWFA to implement a Safe Circle MOU with all our partners in India including their value chain to educate and to work to eradicate this practice,
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Women
• Location: India
• Mitigation: Working with AWFA to implement a Safe Circle programme in all of our India facctories, starting with Tier 1 and cascading down the value chain. Education of women is key for us to promote their rights and to have support from those they work with and requires long terms committment. Because of this situation we have frozen the addition of Tier 1 in this region and will build closer and more economically balanced relationships
• Risk: The company recognise , as a large UK company operating in retail and warehousing, the ongoing risk of labour exploitation and modern slavery within our direct operations.
• Area: Within your own operations
• Group: Women Migrants Refugees
• Location: United Kingdom
• Mitigation: The company has a modern slavery committee who meet 1 x month and includes our on site labour providers for our DC . Procedures are checked and amended and risks identified with transparency being key. Training is given to Welfare champions as stated in our report and this training has proven to be effective in spotting concerns and responding to information given by staff in a safe and secure environment following an escalation process .
• Risk: Cambodia - as a new territory for us and it is important that we work to understand the risks specific to this country and focus our attention on that risk in addition to our standard risk analysis.
• Tier: Tier 1 suppliers
• Group: Women Migrants Children
• Location: Cambodia
• Mitigation: We follow the ILO risk matrix and will further enforce our checks on forced and bonded labour with trafficking being the high risk. We have carefully selected a very small number of factories , working with UK agents who have an existing relationship with our company and understands our concerns and the risks. No factories in high risk countries can be onboarded as a supplier without 3rd party audits and full risk assessments.