Methods Adopted:

(a) Independent research assessing risk.

(b) A risk management database or tool (collating secondary data relevant to risk)

1. "Our risk assessment includes detailed mapping of supply chains and operations, desk based research, supplier surveys, supplier engagement and discussions with expert stakeholders." (Page 4)

2. "We developed a High Risk policy document and issued High Risk Country List for each Business area to work on gaps in effective Due diligence." (Page 4)

3. "Products and services were mapped by country where the most relevant human rights issues were scoped, this then produced a risk assessment that ranked risks by sourcing countries. Areas of focus were identified and next steps/ mitigating actions were recommended and fed back to Property and Retail Human Rights Practitioners" (Page 4)

4."Our Global Sourcing Principles (GSP) have applied to product suppliers and have been extended to all suppliers and franchise partners – including goods not for resale. We updated our standard supplier contractual terms for new suppliers in 2016 and 2017 to include obligations on Modern Slavery Act risk assessment, controls, and notification of Modern Slavery findings and to further reference our wider Global Sourcing Principles." (Page 4)