pg. 20

"Audit programme

Our audit programme is one mechanism we use to identify and address risk, including modern slavery risks. In September 2019, we increased the scope of our audit programme to include 100% of tier 2 factories globally, as well as 100% of tier 1. This means that, from September 2019, 61% of tier 1-3 factories involved in the manufacturing and any processing of our final products are now audited on an annual basis. We are committed to the ongoing improvement of transparency in our supply chain and addressing the associated risks.

While we’re mindful of the limitations of audits, our audit programme is a critical enabler in the discovery and management of modern slavery risks throughout our supply chain.

We use a combination of our own in-country teams and third-party audit providers to identify risk at factory level against our policies and indicators of modern slavery (see diagram 2). This enables our head office and in-country teams to take immediate action and mitigate risk across our supply chain. Our audit methodology also assesses modern slavery risks under the heading ‘employment is freely chosen’, one of the clauses of the Ethical Trading Initiative base code."

pg. 28

"We work with The Re-Assurance Network (TRN), which carries out full on-site audits of our returns centres in Poznan and Swiebodzin in Poland. These audits include:

• Policies and procedures

• Site tour

• H&S/working conditions

• Wages and working hours

• Interviews with workers

• Environmental checks

• Agency policies/procedures and accommodation standards, including verification of agency management systems, and accommodation visits."

I unchecked On-site visits (Self-reporting) and checked On-site visits (independent) as the visits are undertaken by TRN (see above p. 28)