MOUNTAIN WAREHOUSE 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 Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation Businesses in your industry or sector

Social audits

Third party audit arranged by your supplier Announced audit Unannounced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

We monitor performance using SEDEX analytics as well as our own risk trackers and industry reports to score our supplier risk. Where high risk is identified our ethical team engage and train suppliers

Actions addressing ILO indicators

Change in training

Demonstrated progress

We use the following KPI metrics: - SEDEX non conformity statistics, we focus on reducing non-conformities prioritising the highest risk. In this year we reduced non-conformities by 20%. Example of NC: excessive overtime or grievance policy not communicated to employees. - SEDEX Management scores, we focus on improving scores to near the best practice level. - Hidden factories are drawn out through engagement and cross checking reports, we have identified 14 hidden factories in this period.

Reported risks and mitigations

• Risk: Forced labour in Cotton supply chains: China, Uzbekistan, Turkmenistan, India, Brazil, Pakistan, Benin, Egypt, Burkina Faso, Tajikistan, Azerbaijan, Argentina, Kazakhstan, Kyrgyzstan, Zambia, Mali
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Migrants Refugees Children
• Location: Argentina Azerbaijan Burkina Faso Benin Brazil China Egypt India Kyrgyzstan Kazakhstan Mali Pakistan Tajikistan Turkmenistan Uzbekistan Zambia
• Mitigation: We ban Cotton from high risk countries. We predominantly source our Cotton from Bangladesh and India and ensure Cotton from these regions is used. All Cotton suppliers declare the Cotton country of origin seasonally including full supply chain mapping and chain of custody (proof) down to the farm.
• Risk: Excessive overtime in factories in China.
• Tier: Tier 1 suppliers
• Group: Women Migrants Refugees
• Location: China
• Mitigation: If excessive overtime is identified through the third party audits, the factory is required to send a corrective action plan within a reasonable time frame which is identified in the audit. These plans are reviewed by our dedicated ethical team who personally engage with the supplier to ensue actions are completed, providing training where required. A follow up 3rd party audit then verifies these actions. We also review worker number verses order volume to draw out risk before we place orders.
• Risk: Insufficient management processes related to forced labour indicators in tier 1 manufacturing factories.
• Location: Bangladesh China India Cambodia Vietnam
• Mitigation: We monitor the SEDEX management control score report which uses supplier questionnaires to score risk for freely chosen employment, freedom of association, children and young workers, wages, working hours, discrimination, regular employment, discipline and grievance. If a supplier scores poorly our ethical team personally engage with the supplier management to align expectations and agree timely corrective actions, only closing the risk when scorecard is updated to be acceptable.