page 9: ". Our process aligns with the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Supply Chains and is the result of in-depth benchmarking and consultation with human rights organisations. Our process to identify human rights risks consists of the below four main components."

"Country risk assessments: We conduct research using existing external reports and sources of

publicly available credible information to build an assessment of every

country we source from. This includes political, economic, social,

and legal analysis and risk-mapping including modern slavery risks.

Assessments consider both the garment and footwear sector and

additional relevant sectors and industries." (p9)

Analysis of internal audit data; "Primark’s local ETES team is one of our most important resources.

The team of over 130 local experts are our ‘eyes and ears’ on the ground. Based in ten of our major sourcing countries, they have been recruited from a range of different organisations including other

companies, development agencies and civil society.

We conduct unannounced audits on all Tier 1 factories and are increasingly assessing Tier 2 sites in our supply chain which provides us with information on risks at a site level. Further information on our audit programme is on page 10. At a macro level, we are also able to draw from intelligence and analysis of over 37,400 audits conducted on Primark’s suppliers since 2007 which allows us to conduct risk analysis." (p9)