Yes and further in development:

YES: "We have several policies in place relevant to Modern Slavery, all of which are signed off at Director level. This includes our Human Rights policy, our Code of Ethics & Behaviours, and our Whistleblowing Policy (aimed principally at our employees but also available to others working in our supply chain.) Our Global Sourcing Principles (GSP) have applied to product suppliers since 1998, and as of May 2016, have been extended to all suppliers and franchise partners – including goods not for resale. We updated our standard supplier contractual terms for new suppliers in 2016 and 2017 to include obligations on Modern Slavery Act risk assessment, controls, and notification of Modern Slavery findings and to further reference our wider Global Sourcing Principles. In 2018 we have further strengthened our Global Sourcing Principles, this included clarifying position on non- payment of recruitment fees, expectation on Supplier transparency and requirement for additional due diligence if operating or sourcing in High risk locations. For goods and services not for resale procurement we introduced Supplier management policy which includes Global Sourcing principles to ensure all businesses are captured." (Page 4)

DEVELOPING: "In 2017-18 we consulted suppliers on a new Global Labour Provider Policy, as a result of these consultations we deferred launching this to undertake further work on responsible recruitment practices. We will continue to evolve this work and plan to report this in the upcoming year. During 2016-17, we conducted a critical review of grievance mechanisms available both for our employees and for the supply chain, and the extent to which issues are effectively raised within our business. In 17/18 we have been working through the implementation plan to improve the understanding of what channels are available within the business, and unifying the way we handle and follow-up on grievances. This year we introduced an independent external facility for employees in UK, internationally and supply chain to raise Human rights concerns." (Page 4)