pg. 5

"IDENTIFYING RISKS OF MODERN SLAVERY

We recognise that globally, the apparel industry carries inherent and complex risks of modern slavery throughout all tiers of the supply chain. Operational functions of the retail industry carry their own varied and distinct risks and require additional consideration and assessment of risk."

pg. 6

"RISKS IN OUR OPERATIONS

In Australia, New Zealand, Canada, EU and Singapore, we have determined the risk of modern slavery in our retail and head office operations to be low.

A preliminary assessment has identified our warehouses and franchise operations as necessitating further due diligence to understand any potential risks of vulnerable worker groups including temporary and migrant workers. This will commence in 2021.

Concession staff based throughout department stores in the United Kingdom are usually hired directly and are employed on Forever New contracts. The use of recruitment agencies is minimal.

RIS KS IN OUR SUPPLY CHAIN

Merchandise suppliers

Across our merchandise supply chain, our preliminary assessment has identified the following potential modern slavery risks as our most salient: • forced labour • bonded labour • the worst forms of child labour; and • deceptive recruitment practices.

We also recognise the following risk factors in the apparel sector as indicators of the potential for modern slavery to occur: • unauthorised subcontracting • excessive overtime • the use of migrant, low skilled workers • lack of freedom of association • temporary labour contracts; and • lack of access to effective grievance mechanisms

We acknowledge the following categories of workers as the most vulnerable in the garment sector: • female workers • migrant labour • subcontracted labour • agency and temporary/contract labour; and • young/child workers.

Non-merchandise suppliers

We source non-merchandise goods and services from approximately 1,000 suppliers covering 30 industry categories. Given their broad nature and locations, risks in this area of our supply chain are unique and varied. In the 2021 reporting period, we will commence detailed risk mapping by sector, region and spend to identify specific risks and prioritise areas of due diligence.

We recognise that industries which make use of short term contract, migrant labour and labour hire agencies such as cleaning, third party warehousing, freight and logistics pose greater risks and as such will be a focus of our efforts."

The company states having identified specific types of risk as the most salient after their assessment (see page 5 merchandise suppliers). However, the company does not state identifying the rest of the risks mentioned in the statement. For example, the company says " we recognise the following risk factors in the apparel sector" or "we acknowledge categories of workers as the most vulnerable in the garment sector" but does not link it to its supply chain. Therefore, I have unchecked Geographic and Industry.

Left checked In development as the company states working on risk mapping non-merchandise suppliers (see above) and workforce as the company states: 

Whilst a preliminary risk assessment of our operations highlights workers hired via our franchisees and third party labour contracts as a priority due to the lower visibility of these arrangements, further assessment is scheduled to determine the specific nature and degree of potential risks relevant to each function and region (p. 6)