pg. 6

"POLICIES

SUPPLIER CODE OF CONDUCT

We have policies and procedures in place for our suppliers, business partners and our employees to ensure that our standards are being met and to help individuals raise issues and concerns. We are committed to launching our Human Rights Policy in due course which will set out our position on supporting and respecting human rights at a broader level.

Our Supplier Code of Conduct is based on the UN’s ILO Core Conventions and Fundamental Principles including the elimination of Forced Labour. The scope of the Code of Conduct covers our supply chain including goods for sale, services and goods not for sale (such as service providers, logistics and transportation) and forms part of Primark’s Business Terms and Conditions with its first-tier suppliers. First-tier suppliers are required to cascade the Code of Conduct to their suppliers.

The Code of Conduct is available on the Primark website in 44 languages (this year we added Greek and Slovenian) which reflects the languages spoken in the factories producing for Primark and is updated regularly following internal review and with input from external stakeholders.

Our Code was updated in early 2020. This update included strengthening sections on forced labour, living wages, freedom of association, child labour and health and safety, as well as a new clause requiring our suppliers to implement their own workplace grievance procedures.

Specifically, in the clause requiring that ‘employment is freely chosen’, the Code states:

1. There must be no forced or compulsory labour in any form, including bonded, indentured, trafficked, or prison labour and overtime must be voluntary.

2. Any fees associated with the employment of Workers must be paid by the Employer.

3. Workers must not be required to lodge any monetary deposits or their identity papers with their Employer.

4. Workers must be free to leave their Employer after reasonable notice.

The revised Code came into effect in September 2020.

Suppliers have a six-month implementation window (ending in March 2021) and we are providing training and guidance for suppliers during this period."

pg. 20

"We may also conduct worker interviews off-site if we deem it necessary and may use support from NGOs or other experts. Child labour is a zero-tolerance issue and strictly prohibited in the manufacturing of our products."

I added code of conduct includes modern slavery provisions because the supplier code of conduct includes forced labour, living wages, among other requirements related to preventing modern slavery in their supply chain (see above and p. 6)