pg. 8

"Supply Chain Audit It is a requirement that all new direct suppliers to Food and C&H have due diligence checks in place in the form of an 100% completed self-assessment questionnaire and an ethical audit, conducted by approved third parties. If issues are identified, appropriate investigative and remedial actions are taken. In C&H, once a supplier is onboarded, we operate an audit policy that requires an annual social compliance assessment to take place within a 3-month window. This audit cycle is then augmented by our regional compliance team, based in our sourcing offices, who support factories with implementing a corrective action plan. In Food, suppliers are risk assessed and the audit programme is designed around the results of those assessments."

pg. 9

"We have sought expert independent third-party advice on how to manage these new types of relationships from a modern slavery perspective, to ensure we can be confident the ways of working of any new brands align with those of M&S. We have created a self-assessment questionnaire scoring tool for new brands so that our minimum requirements are clear from the outset, even prior to contract stage."

I checked Desk Research because:

ASSESSMENT OF MODERN SLAVERY RISK WITHIN OUR SUPPLY CHAIN

As referenced above, the annual modern slavery risk assessment approach is aligned with the M&S Group risk register method, considering external and internal changing risks and how these are mitigated. The manifestations of modern slavery are complex and hidden, so our risk assessment includes the following to enable us to prioritise activity;

• detailed mapping of supply chains and operations;

• desk-based research;

• supplier surveys;

• supplier engagement; and

• discussions with expert stakeholders (p.5)

use of tool: We have therefore partnered with a third party provider to assess our supply base covering, among other areas, Ethics and Human Rights....The first phase of the Ecovadis Programme has focussed on suppliers where we spend in excess of £500k per annum... (p.6)