- features several instances of unjust recruitment fees and their intention to audit but no solid prohibition of suppliers due to huge network

- emphasized monitoring and supporting supplier but does not define policy or code of conduct, just goals for supplier involvement in future

-  Require all direct supplier sites (known as ‘Tier 1’ sites) in high-risk countries to have a human rights audit before they start supplying Tesco, and then on an annual basis. This represents around 30% of our total Tier 1 suppliers

- beyond first tier use a number of selected certification schemes to provide additional assurance of our

The company does not explicitly report code applies beyond tier 1 hence not considered.

pg. 3

"Policies in relation to modern slavery.

At the heart of our approach to human rights are a number of important internationally recognised declarations, standards and codes. These are the foundations for how we work across the Tesco Group, and include:

• The UN Universal Declaration of Human Rights.

• The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work.

• The UN Guiding Principles on Business and Human Rights.

• The UN Global Compact.

• The Base Code of the Ethical Trading Initiative (ETI).

Our approach to addressing modern slavery sits within this wider human rights agenda. Our strategy is supported by our Code of Business Conduct and Human Rights policy, which applies across the Tesco Group and sets out our obligations to customers, colleagues and communities in our own operations and supply chain.

We take any breach of our policies or allegations of labour abuse extremely seriously. We provide independent and confidential ‘Protector Lines’ that enable our colleagues, suppliers and their staff around the world to raise concerns.

As part of our membership of the Consumer Goods Forum (CGF), we are one of the companies leading collaborative efforts to combat forced labour in the consumer goods sector. Such collaboration is particularly important in lower tiers of supply chains where we do not have direct commercial relationships. We helped to develop and strongly support the CGF’s Priority Industry Principles shown below:

Every worker should have freedom of movement.

No worker should pay for a job.

No worker should be indebted or coerced to work.

As members of the Institute of Human Rights and Business Responsible Recruitment Leadership Group, we also actively support the Employer Pays Principle that: ‘No worker should pay for a job - the costs of recruitment should be borne not by the worker but by the employer.’"