Page 7: Supplier Code of Conduct (based on UN's ILO Core Conventions and Fundamental Principles inc. the elimination of Forced Labour) - 1. there must be no forced or compulsory labour in any form, including bonded, indentured, trafficked or prison labour and overtime must be voluntary.

page 19-20: policies that strengthen freedom of association and worker representation are in development. 'Our supplier code of conduct sets out the standards we expect of our suppliers in relation to freedom of association and collective bargaining agreements' - unclear in actual code of conduct on page 7; also strengthened through the Action, Collaboration, Transformation on Living Wages (ACT), but currently only operates in four key countries: Bangladesh, Cambodia, Myanmar, Turkey

page 21: 'We support the ‘employer pays principle’ which means that no worker in our supply chain should pay for their job, and that any costs associated with their recruitment must be paid for by the employer. This is stated in our Supplier Code of Conduct.'

pg. 7

“The Code forms part of Primark’s Business Terms and Conditions covering all suppliers of finished goods. This states the supplier is responsible for compliance with the Code in its supply chain and that audit rights are granted with unfettered access.”

“The most recent update to the Code was in 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 suppliers to implement their own workplace grievance procedures.”

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

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

Pg. 19

“Our Supplier Code of Conduct sets out the standards we expect of our suppliers in relation to freedom of association and collective bargaining agreements.”