"Assessment of Modern Slavery risk within

our supply chain

In the past year we have increased our focus on Modern

Slavery within our wider business operations, and the supply

chains of our goods not for resale, including the formation of

internal governance structure on Modern Slavery and Human

Rights at both operational and leadership levels; Human

Rights Practitioner Committee and our Human Rights Director

Steering Group.

We have mapped our supply chains to assess particular

industry/sector and geographical risk. These assessments

cover the entire scope of our business, encompassing Retail

Operations, Property, Logistics, HR, IT and International, as well

as product supply chains. We have worked with external experts to undertake a detailed risk analysis of our sourcing countries and product areas so we have a clear idea of where the biggest risks lie and where our actions can have a positive impact. Further detail on how we carry out our human rights risk assessment is included in our Human Rights report.

In terms of understanding our greatest risk, there are well

known reported instances in the food Industry of forced or

trafficked labour, ranging from Eastern European workers in

the UK meat and poultry processing industry to enslaved

migrant workers several tiers down the shrimp supply chain in

Thailand. Our human rights risk assessment process has also

highlighted the possibility that in service industries, particularly

construction and procurements of goods not for resale there

could be potential for workers to be put at risk of forced

labour. In the clothing industry India arguably represents the

biggest risk, because the apparel industry encompasses many

different sectors such as cotton, ginning and spinning mills and

manufacturing sites. Turkey also has increased in risk given the

significant number of foreign migrants.

This has enabled us to prioritise our supply chain due diligence

on Modern Slavery, which has included working with leading

experts on visits to second and third tier sites in our supply

chains in Indonesia, Vietnam, Malaysia and the Philippines and

working with GLA to carry out due diligence assessments of

non-food suppliers."