Ann Summers Ltd Modern Slavery Statement 2023/2024

Introduction

We, Ann Summers Limited, 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 year ending 30 June 2024 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 improve our relationships with existing product suppliers (of both own-brand and third party branded products), and to improve transparency through conducting regular due diligence.
• Reviewing due diligence procedures for new suppliers, including requesting information about their modern slavery and human trafficking controls, and taking responses into consideration as a factor in deciding whether to work with new suppliers.

Organisation structure, business, and supply chains

Ann Summers (UK) Holdings Limited is the immediate and ultimate parent company of Ann Summers Limited. Ann Summers Holdings Limited is parent of a group of companies whose principal activities are supporting the business activities of Ann Summers Ltd.

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.

Ann Summers’ head office is based in Whyteleafe, Surrey where we select, design, source and create our product range. We employ around 1100 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 62 factories to design and manufacture Ann Summers branded products. We also source and sell third party-branded products from around 18 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.

• Dedicated in-house compliance team – We have dedicated sourcing and compliance team to manage supplier compliance and accountability.
• 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.
• Closer monitoring of product suppliers – Once it became possible, post-pandemic, we visited the Chinese factories used by our key suppliers, to see and assess their working practices first-hand. We have scheduled further visits and intend to visit our suppliers’ factories with greater regularity.
• 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.
• Product Supplier Code of Conduct – We have developed and distributed a 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. All our product suppliers are required to sign up to our Code of Conduct as part of their product supply contract.
• 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 and audits of suppliers and supply

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. 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), internal team feedback, and independent auditing.
• Communication and escalation – The results of each audit and review are communicated to the business and serious concerns are escalated to the relevant Board member so they can be managed in accordance with this Policy.
• Supply Chain Mapping – We have conclusively mapped our Tier 1 Supply Chain, and we aim to expand this visibility out into Tier 2 (Material Production) and Tier 3 (Raw Material Processing) within the next 5 years.

Assessment of effectiveness in preventing modern slavery

We have established a newly appointed Risk Committee which, includes the CEO, and which 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 Ann Summers Ltd.