Page 2 - 734 SMETA audits were carried our at John Lewis sites to demonstrate that basic working conditions are in line with the Responsible Sourcing Code of Practice (Page 39 - "In 2021, John Lewis was able to close 65% more non-conformances identified during the SMETA audits at sites supplying our Partnership".)

Page 7 - Factory audits of Tier 1 sites demonstrated that there is room for improvement in the management of factory compliance

Page 11 - Ethical audits to determine site's compliance with ETI Base Code, founded on the Conventions of the International Labour Organization (ILO)

Page 18 - 'Deep Dive' audit conducted in the UK demonstrated that the country carries a high risk due to being a key destination for victims of trafficking

Page 33 - Ethical Compliance Policy

Page 39 - To promote ethical compliance, John Lewis "committed" to implementing internal reporting (in development)

Pg. 10 (Audit – self reporting)

“As set out in our 2020/21 Human Rights Report, in early 2021 we undertook our biennial worker welfare self-assessment within our livestock supply chains. Thanks to this self-assessment we can identify areas where improvements have been made, support continuous improvement and highlight risk areas that may require further investigation.”

Pg. 13

“During 2022/23, Partners in our Hong Kong sourcing team will begin to conduct on-site assessments at these Tier 2 sites. We will directly address any issues that are uncovered during these site visits and the learnings from undertaking these assessments will be used to develop the due diligence programme for sites below Tier 1.” (In development)

“Spot checks: To test the effectiveness of the due diligence within our Ethical Compliance Programme, we conduct spot checks using audit (namely SMETA two-pillar audits) or tailored methodologies at relevant sites and farms in our global supply chains.” (Onsite - Independent)

Pg. 17 (Audit – Independent, Onsite - Independent)

“Verisio

‘Deep Dive’ audits With a focus on conducting a greater number of impact assessments, we trialled ‘Deep Dive’ audits, developed by Verisio, with three UK mattress suppliers. We chose to focus the audits in the UK because it’s commonly misconceived as a low risk country, but in fact carries high risk due to it being a key destination for victims of trafficking.

The Verisio ‘Deep Dive’ audit methodology combines a desktop assessment of company documents, such as policies, and a two-stage, on-site unannounced audit consisting of an initial audit and a follow up at roughly six months at which all nonconformances will be reviewed. By completing the desktop assessment beforehand, auditors are able to dedicate more time to the on-site visits.”

Pg. 26 (Onsite - Independent)

“Our team at the Hong Kong Sourcing Office (HKSO) suggested the factory engage with a consultancy service to understand the root causes of the overtime hours, and to develop a plan to address all of the issues systematically. This independent advisor visited the factory approximately once a month (six visits in total) between April and November 2021 to give advice and check the progress on the open issues.”

Pg. 40

“In 2022, we will be supporting management teams and production workers by conducting webinars, site visits and training for suppliers.” (In development)