Ann Summers Ltd Modern Slavery Statement 2024/2025

Introduction

Ann Summers Limited (“Ann Summers” or “we”) are committed to prioritising and improving our practices to combat slavery and human trafficking in our business and supply chain. This statement sets out the steps we have taken during the financial year ending 30 June 2025 to prevent slavery and human trafficking in our business and supply chains.

Key Focus Areas

We recognise that the activities we undertake can impact the livelihoods of a significant number of people. To ensure that we can continue to protect the welfare and rights of employees in our organisation, and the workers throughout our supply chain, our focus this year has been across the following areas:

• Continuing to strengthen our relationships with existing Tier 1 product suppliers (of both own-brand and third party branded products), while enhancing transparency through consistent, annual due diligence reviews.
• Reviewing and improving due diligence procedures for new suppliers, including assessing their controls on modern slavery and human trafficking, and incorporating their responses as a key factor in supplier approval decisions.
• Initiating efforts to strengthen engagement with Tier 2 suppliers to enhance supply chain transparency and support our goal of expanding visibility over the next four years.
• We regularly undertake risk assessments relating to the presence of modern slavery and continue to improve our approach to the risks of modern slavery and to enhance Modern Slavery Policy, which is approved by our board and cascaded across our organisation and supply chain.

Organisation structure, business, and supply chains

Ann Summers (UK) Holdings Limited is the immediate and ultimate parent company of Ann Summers Limited, and parent of a group of companies whose principal activities are supporting the business activities of Ann Summers Limited. Ann Summers Limited trades through two key brands: ‘Ann Summers’ and ‘Knickerbox.com’.

The principal business activity of Ann Summers is the retail, wholesale and marketing of lingerie, apparel, adult toys, and related accessories. We sell through around 80 physical stores in the UK and Republic of Ireland, a UK based web channel that serves both UK and international customers, a well-established third-party sales channel, and a network of direct selling consultants.

The principal business activity of Knickerbox.com is the online retail and marketing of lingerie and apparel.

Ann Summers’ head office is based in Whyteleafe, Surrey where we select, design, source and create our product range. We employ around 970 people across the UK and Republic of Ireland. Our main distribution centre is based alongside our head office in Whyteleafe, and our goods-in warehouse is at a separate location in Paddock Wood.

We work with around 40 suppliers across 63 factories to design and manufacture Ann Summers branded products. We also source and sell third party-branded products from around 30 branded suppliers. Our product supply chain is global, with factories based across Asia and Europe, as well as the UK.

Policies and controls

As a responsible retailer and employer, we have appropriate measures in place to address risks of modern slavery in our supply chain. We review these regularly to ensure we are constantly developing our processes, avoiding any gaps in compliance.

• Integrated Compliance and Legal Team - In order to improve governance and avoid any conflicts of interest, we have separated our Compliance Function from our Buying Function and moved it to sit within a newly integrated Legal and Compliance Function.
• Continued partnership with SEDEX - We became a SEDEX member in 2023 to provide us with comprehensive ethical audit information of the manufacturers and factories that form part of our product supply chain, including information on wages, working hours, and ethical practices. We continue to use SEDEX to help us assess and manage modern-slavery risks within our supply chain. Each year, more of our Tier 1 suppliers join the platform, improving the accuracy and coverage of data across the majority of our supply base.
• Closer monitoring of product suppliers - In June 2024, we spent a week in China walking our Factory floors, building our relationships with the China teams, and addressing any areas of concern. This was a proactive visit, and we have another booked in for November 2025. These visits are now conducted annually, prioritising our most direct suppliers to assess their working practices first hand.
• Contractual Controls - All of our product suppliers, and the majority of all suppliers, are contractually obliged to comply with the requirements of the Modern Slavery Act, and Ann Summers has the right to terminate its relationship with its suppliers if they are found to be non-compliant.
• Modern Slavery Policy - In December 2024 we published a new Modern Slavery Policy and distributed this throughout our business and supply chain. This policy expressly prohibits any form of forced labour, child labour and slavery, educates on the signs of spotting modern slavery within the workplace, and outlines a procedure for reporting any concerns of a possible breach of this policy. A training pack was also distributed to equip our teams with the knowledge to identify potential warning signs and help mitigate associated risks.
• Product Supplier Code of Conduct - In February 2025 we updated and distributed our Supplier Code of Conduct which expressly prohibits any form of forced labour, child labour and slavery, demands lawful, safe and healthy conditions for workers, and encourages workers to be provided with fair wages, employment security, respectful treatment and freedom of association and the right to collective bargaining to include further detail and referencing our new Modern Slavery Policy. All our product suppliers are required to sign up to our Code of Conduct as part of their product supply contract.
• Awareness and training -
We identified our UK Warehouses were an area of our workforce that could be at risk. We produced and delivered training to our warehouse staff, to make them aware of the signs to look out for that might suggest a colleague was subject to modern slavery and encouraged them to report any suspicions via our Whistleblowing services.
• Whistleblowing service - We offer an independent Whistleblowing hotline service that both our employees and the workers throughout our supply chain are invited to use to report any suspected human rights violations (including slavery and people trafficking) directly to a designated member of our Board.
• Whistleblowing Policy - Use of the whistleblowing service is encouraged by a Whistleblowing Policy that provides a clear and practical reminder to employees and workers of their right and responsibility to raise concerns they may have around perceived wrongdoings. This Policy expressly provides for the protection of such whistleblowers.

Due diligence of suppliers

We recognise that it is within our product supply chain where we have the highest risk of encountering practices that could amount to modern slavery.

As part of our initiative to identify and mitigate this risk we undertake due diligence on our product suppliers. We predominantly sell own-branded products, manufactured and marketed under the Ann Summers brand as well as our new ‘KBX’ that launched in July 2024, and that is sold through Knickerbox.com. Our relationships with our Supply Base are built on trust and shared goals.

• New suppliers - We have a sourcing and onboarding procedure that is followed by our teams to ensure that we can appropriately assess the practices of a supplier to aid our final decision of onboarding and mitigating risk. We complete extensive risk assessments through desk-based research, independent auditing, supplier self-assessment forms, financial checks, and their review and agreement of our manuals, policies, and terms and conditions. This ensures or suppliers are aware of, and agree to adhere to, recognised business standards and regulations.
• Existing suppliers - Annually, we conduct extensive risk assessments of our supply base to allow us to quickly identify, investigate, and address any areas of concern. We complete extensive risk assessments of each of our product suppliers and their factories through desk-based research, supply chain mapping, supplier self-assessment forms (substantiated with evidence of practices, processes, and procedures) and independent auditing. We review and update our self-assessment form each year to ensure alignment with the latest standards and legislative requirements.
• Communication and escalation - The results of each audit and review are assessed using a RAG (red, amber, green) methodology and communicated to the business with serious concerns being escalated to the relevant Board member so they can be managed in accordance with our internal Policies.
• Supply Chain Mapping - We have conclusively mapped our Tier 1 Supply Chain and have started to map our Tier 2 (Material Production) Suppliers. We aim to continue to expand this visibility on Tier 2 and include Tier 3 (Raw Material Processing) within the next four years.

Assessment of effectiveness in preventing modern slavery

We have an established Risk Committee which, includes the CEO, that meets quarterly to identify and discuss risks which affect our business. We recognise the need to keep modern slavery risks under review on the Risk Committee’s agenda and will continually assess our policies, controls, and training (both internally and in conjunction with our suppliers) to ensure that this risk is effectively mitigated.

This statement was approved by the Board of directors of Ann Summers Ltd.