BLACKS OUTDOOR RETAIL 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 whole organisation Your front line staff Human resources Executive-level staff Procurement staff

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation Law enforcement, such as police, GLAA and other local labour market inspectorates Businesses in your industry or sector

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

Supply chain traceability mapping & in-country visits. In our UK operations, welfare champions, & confidential reporting mechanisms provide oversight of potential indicators of exploitation.

Actions addressing ILO indicators

Change in training Referring potential victims to government services Supporting victims via NGO Supporting investigations by relevant authorities

Demonstrated progress

We set KPIs on: 1)Number of collegues trained globally & regular meetings with Welfare sponsors who are 2nd level trained with regular check-ins 2)Transparancy on non-compliances open & closed & the classification of the root causes We do not set KPIs on the number of cases we investigate - our policy is "if we dont find any, we are not looking in the right places" Success comes from reports in direct operations. Our policy is Victim led - we are unable to disclose some statistics.

Reported risks and mitigations

• Risk: Forced labour risks in global manufacturing supply chains, particularly relating to recruitment practices, wage payments, social insurance, overtime & documentation in high-risk sourcing regions.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Migrants
• Location: Bangladesh China Egypt India Turkey
• Mitigation: Prior to onboarding any Tier 1 supplier, risk assessments & audits must be in place along with CAP reports. Transparancy of the value chain and supplier engagment beyond common risk is on key areas : Freedom of Association / Living wages/Benefits to ensure a valued workforce. Working in partnership with suppliers and identifying root causes is key to engagment and progress. Suppliers should be long term partners and shared values embedded in the relationship.
• Risk: Retail employees often face heightened risks of exploitation due to poverty, migration, discrimination, cultural norms and limited access to education. https://www.neighbourly.com/jdfoundation
• Area: Within your own operations
• Group: Women Migrants Other vulnerable groups
• Location: Australia Spain France United Kingdom Greece United States
• Mitigation: Global Modern Slavery Training rolled out to all employees to ensure that risks are understood, red flags can be spotted and the reporting is safe and robust within a process that is victim led at all times. We have strong DEI programmes and ensure inclusitivity across all areas of our direct business where everyone has value. Our charity work across the group supports our demographic within retail and our communities in which we operate. https://www.neighbourly.com/jdfoundation
• Risk: Goods Not for Resale (GNFR) These workers include cleaning, logistics & catering within our operations, is high risk. We work with UnSeen to ensure risks are identified across our peer groups.
• Location: United Kingdom
• Mitigation: Workers within these sectors may be at increased risk of modern slavery due to factors such as low-paid & temporary employment, the use of labour agencies, migrant labour, subcontracting arrangements and limited visibility beyond first tier of the supply chain. Through the Procurement Team we upload all of the contractors to the UnSeen webstie and collaborate with other businesses on issues which are reported on the platform, operating a combined approach to resolution with the relevent company