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pg. 6

"RISK ASSESSMENTS

RISK TRAFFIC LIGHT SYSTEM

JD’s approach to risk assessment comprises of self assessment and country research, supply chain mapping, 3rd party auditing with Qima (our 3rd party audit company) and stakeholder engagement.

Whilst we are mindful of the potential limitation of audits relating to modern slavery, and exposing the “hidden truth”, it is a critical enabler in the discovery and management of issues relating to the fundamental principles in our Code of Conduct, with particular relevance to modern slavery practices throughout our supply chain.

Audits identify risk at factory level against that Code of Conduct and local laws, enabling us to take immediate action and mitigate risk across our supply chain whilst identifying and addressing potential factors that may exist in the background.

On receipt, the factory setup is reviewed in detail by the ethical compliance team and any risk areas verified as required. The factory site is then graded using the traffic light format opposite.

Only Green, Amber and Yellow graded sites can be used. Sites graded Red (or ungraded facilities) cannot be used.

In certain countries sub-contracting is an accepted part of the manufacturing process, Turkey is an example of this with a large percentage of factories using sewing units outside of their factories or in-house."

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self assessment usually refers to questionnaires but this is not made explicit here so I have not made changes in this regard.

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Data copied from JD Sports Fashion plc for 2021