Kurt Geiger Modern Slavery Act Statement

The below statement is published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Kurt Geiger Ltd ("Kurt Geiger”) to prevent modern slavery and human trafficking in its business and supply chains during the 12-month financial period ending 1 February 2020.

OUR BUSINESS

Kurt Geiger is a multi-channel retailer of Kurt Geiger, KGL, Carvela and other luxury branded footwear and accessories. Kurt Geiger is committed to providing quality products and service to its customers with the support of its suppliers.

Kurt Geiger and its wholly owned subsidiaries are committed to ethical business practices in all of our operations worldwide. We choose suppliers and contractors who we believe share that commitment. We require our suppliers and contractors to comply with all applicable laws and regulations of the country, or countries, in which they are conducting business.

MANAGING RISK

We require our partners within our supply chain to comply with our Code of Conduct. Supplier relationships are critical to achieving our goals. We work with an established supply base and strive to build long-term, strong and mutually beneficial partnerships.

Within our business, we consider the risk of exposure to modern slavery to be greatest in our product supply chain. Kurt Geiger own label products are predominantly sourced from Europe, the Far East and South America.

CONTRACTUAL COMMITMENT TO ETHICAL STANDARDS

All suppliers producing Kurt Geiger own label products must agree and sign up to the procedures set out in our Supplier Manual as well as our Terms and Conditions of Purchase prior to any orders being agreed or issued. We communicated our updated Supplier Manual to all our existing own label product suppliers in autumn 2018 and when we start working with new suppliers we share our Supplier Manual with each of them. As part of their on-boarding they sign up to it and link with us on Sedex (see further below).

The Supplier Manual includes our Code of Conduct for Suppliers which incorporates our ethical business policies and practices, standards for Labour and Welfare and Modern Slavery provisions. The Labour and Welfare standards are based on those set out in the Ethical Trade Initiative Base Code and the eight fundamental conventions of the International Labour Organisation. As part of our supplier acceptance procedures, suppliers producing Kurt Geiger own label products must also complete a questionnaire which reflects the key elements of our Labour and Welfare standards including forced labour. Our key external brand partners have similar Codes of Conduct and processes of their own in place.

Our policies mandate that Suppliers must ensure compliance with the Code of Conduct by sub-contractors, and that sub-contractors must follow the same signed acceptance procedures as the Supplier.

If we identify non-compliance with the Supplier Manual we will work closely with our suppliers, and if necessary external experts, to execute an improvement plan to rectify matters. Whilst we have a contractual right to terminate supplier relationships in the event of non-compliance, our preferred approach is to support our suppliers and their workforce, to put remedial actions in place.

MONITORING

Kurt Geiger is a member of Sedex (Supplier Ethical Data Exchange) and we continue to work with suppliers to enhance our due diligence and monitoring procedures. As well as our suppliers complying with our Supplier Manual, we also require them to become members of Sedex. We have been pleased to find that many of our suppliers were already Sedex members and most of those who were not have welcomed joining Sedex. We support any supplier locations that are still working on joining Sedex. We review suppliers’ audits on Sedex periodically. Where we have identified non-compliance, we have raised this with the supplier in question and have been pleased to find that often remedial action has already been taken.

Kurt Geiger Buying and Design teams continued during the course of the financial year to make regular visits to key own brand suppliers and their factories to deepen our working relationships and enhance the transparency of our supply chain.

INTERNAL POLICIES, TRAINING & GOVERNANCE

In addition to our Code of Conduct for Suppliers, Kurt Geiger has a number of internal policies including our Business Ethics policy which supports our commitment to high ethical standards across our business. We also operate an anonymous and confidential Whistleblowing Policy, aimed principally at our employees, to report any suspected wrongdoing.

Upon launch, these policies were communicated to all employees and are maintained on our intranet. They also form part of our mandatory induction process.

Our strategy to address the risks of Modern Slavery and monitor Supply Chain compliance with ethical standards is monitored by our Environmental, Social, Governance steering committee, which includes members of our Board and leadership team.

CONTINUAL IMPROVEMENT – FUTURE PLANS

As a business Kurt Geiger is committed to continually improving our processes and policies to identify and minimise the risk of modern slavery and human trafficking. It is a collaborative and evolving process.

As our initiatives advance, we will continue sharing the progress in future statements.

Approved by the Board of Directors and signed on its behalf by:

Neil Clifford, CEO