The company has talked about monitoring and audits, however, it does not report information relating to how it assesses the risks of modern slavery and trafficking in its supply chain.

pg.1

"saks monitors foreign vendor orders that are being produced in high- and medium-risk regions of the world. For these orders, Saks requires vendors to participate in our social compliance program, which may include but is not limited to disclosure of factories, submission of a third party audit report conducted by an accredited audit standard or participation in a social compliance inspection through an independent third party auditing firm. Auditors are required to use a pre-defined, specific and detailed audit checklist which is based on the Hudson’s Bay Company’s Supplier Code of Conduct (the “Code”) when inspecting a factory. The Code is based on the Universal Declaration of Human Rights and the International Labor Standards, which includes a focus on monitoring for child, indentured and/or forced labor as well as harsh and inhumane treatment at the factories. Auditors are required to have appropriate training and credentials to ensure that generally accepted auditing principles are utilized. Audits are completed on an annual basis unless determined that more frequent intervals are appropriate.

Agree - no mention of risk based analysis.