pg. 11

“One of the key risks that can lead to modern slavery breaches is that of subcontracting, where a supplier may choose, without permission, to move production to a factory that is neither compliant nor approved for production.”

“Production audits are conducted by ELEVATE and allow the Just Group to randomly and retrospectively review production records at factories. By doing so we are able to verify that orders have only been made in approved factories. Evidence of subcontracting may result in disqualification or significant penalties depending on the circumstances.”

p13

"‘Effectiveness’ is determined by initially putting measures in place to potentially gain insights into the incidence of high risk Modern Slavery indicators in the supply chain and then, if cases are found, remediating issues accordingly. In order to do so, multiple activities must be in place simultaneously to provide a range of methods of assessing factory due diligence and for workers’ voices to be communicated up the supply chain."

"Non-compliance remediation

To ensure issues raised in audits that may be indicators of modern slavery are remediated appropriately

• Tracking number of issues closed and open. For those issues that are open there is further detail on remediation plan timelines"

"Worker surveys To create avenues for workers’ voices to be heard and communicated to the Just Group

...Track and report number of issues remediated"

Remediation unclear