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pg. 6

"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."

pg. 16

"AUDIT

Regularly audit all agency/contracted workers details and submitted documents. Increase the amount of audits undertaken for agency suppliers within the UK, this will involve documentation checks on random employee files within the workforce in relation to, checking the addresses, number of occupants at the same addresses, landlords details and tenancy agreements.

Due diligence checks are carried out by senior personnel quarterly. Red flags identified are checked immediately. The HR team will be working with the 3rd party system provider to implement a mandatory lock in the system each year to force an annual update of addresses, and tenancy agreements and next of kin and to produce exception reports on changes of key data for forensic examinations by the team."

pg. 17

"During 2020 JD Group partnered with Unseen, joining their on-line portal and sponsoring the modern slavery helpline. Audits are undertaken both on the global and UK supply processes. During 2019/20 the Group focused on the Rochdale warehouse site which during peak season can reach 6,000 employees on site. We are rolling this out to our retail operations during 2021 with related training on modern slavery."

...

"To extend the knowledge for all personnel from the development and sourcing teams we have formalised our Code of Practice Auditing Standards, which serves as a reference guide expanding on the core principles of the ILO standards enabling those visiting site, regardless of role or purpose of visit to assist in the evaluation process, further embedding our commitment to workers rights and good ethical behaviors to our overseas manufacturing partners."

pg. 18

"As a process, JD Group own label brand teams regularly visit the factories to check production and are ideally placed to spot any red flags that may be indicators of modern slavery and reinforce our code of practice and ethical behaviours in this particular area. However, with travel restrictions in place and many countries imposing internal restrictions, reliance has been on 3rd party auditors locally and at times audits had to rely on remote audits. This restricts personal interaction and on site visibility vital to identifying risk factors not clearly visible."

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Audits (self reporting): Due diligence checks are carried out by senior personnel quarterly (p.16)

Audits (independent): 3rd party auditing with Qima (our 3rd party audit company) (p.6)

Site visits (self reporting): As a process, JD Group own label brand teams regularly visit the factories to check production and are ideally placed to spot any red flags that may be indicators of

modern slavery and reinforce our code of practice and ethical behaviours in this

particular area. (p.18)

Evidence on page 17 (see above) refers to training.

No evidence of explicit on-site visits by third parties. Therefore, I have unchecked this.

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Data copied from JD Sports Fashion plc for 2021