Modern Slavery Act

Modern Slavery Statement 2021

This statement, agreed at the end of our financial year 2020-21, evidences how MandM Direct Limited (“MandM Direct”, “we”, “our”) seeks to comply with the requirements of the Modern Slavery Act 2015 (“MSA”). As such, this statement is fully aligned to both the MSA and the updated guidance that was issued by the UK Government in 2017, that challenges relevant businesses to be wholly clear and transparent about their practices across all six categories in section 54(5) of the MSA.

In summary, we at MandM Direct take extreme pride in our ethical approach to business, demonstrated by our keen and continued commitment to recognise and prevent all forms of modern slavery, human trafficking and human rights violations within our own Company and throughout our supply chain.

1. Organisational Structure and Supply Chain

   MandM Direct is one of the UK’s largest online off-price retailers, offering significantly discounted clothing and footwear for men, women and children. Our UK website is complemented by six European sites, supporting customers in Ireland, France, Germany, the Netherlands, Denmark and Poland.

   In 2014, MandM Direct was purchased by Danish fashion group Bestseller United A/S. We are now part of Heartland A/S.

   Our products are sourced from a wide range of international fashion and sportswear suppliers, in whom MandM Direct has no ownership interest. We also offer customers choice from a selection of own-brand products, which are purchased directly from UK importers.

   In 2021, MandM Direct established a Compliance Committee, with specific responsibility for internal oversight: this includes monitoring our adoption of, and adherence to, all prevailing laws, regulations and international best practice. Compliance with the MSA is one of the key areas of focus for this Committee, which reports directly to the Company’s Board.

2. Organisational Policies

   MandM Direct maintains a Slavery and Trafficking Policy, which was updated in June 2020. To further support this policy, in July 2021, we developed a Supplier Code of Conduct, to be distributed to, and signed by, all own-brand suppliers. This document re-emphasises our explicit requirement that all partners observe international standards in the prevention of forced or involuntary labour, working hours, the right to collective bargaining, the prevention of child labour / protection of young workers, adequate compensation, the prevention of discrimination and harassment, the protection of Vulnerable Groups, health and safety, environmental protection and ethics.

   For employees, we offer a Home Working Policy, Whistleblowing Policy, Bullying and Harassment Policy, Equal Opportunities Policy and Young Workers and Work Experience Policy. Similarly, there are departmental-specific Codes of Conduct, relevant to particular areas of operation. All policies that are written or updated by the Company, are submitted to the Compliance Committee for comment, ratification and approval, ahead of dissemination.

3. Due Diligence

   Within MandM Direct, there are clear processes and procedures aimed at identifying, preventing and/or mitigating any risk of adverse impact on human rights. These practices are articulated within a Human Rights Policy, currently at final draft stage.

   MandM Direct also proactively considers any potential impact on human rights that may be caused indirectly through our supply chain. Currently, we charge our UK-based importers with lead responsibility for undertaking regular factory audits in international territories, and thereafter providing us with all necessary assurance and evidence that there is no malpractice or violation of international standards within our supply chain: also, that all suppliers are acting compliantly with local legislation and regulations. Whilst we have no material concerns with this approach, we have nevertheless decided to complement this with our own enhanced processes. This is exemplified by the development of the Supplier Code of Conduct as referenced above, which will be rolled out in the new financial year, to be supported by additional due diligence checks on own-brand suppliers.

4. Assessing and Managing risk

   Based on our existing assessments, MandM Direct has identified that the highest risk of a breach of human rights lies within our supply chain, as opposed to within our own business. Therefore as described above, we are aiming to further build upon our due diligence practices in the coming year.

5. Performance indicators

   As part of the enhanced due diligence processes that are currently in development, we are working upon a suite of key performance indicators that will provide suitable, comprehensive and robust assurance that there is no violation of human rights, modern slavery, human trafficking and/or other international standards, anywhere within our supply chain.

6. Training

   In order to ensure a high level of understanding of the risks of modern slavery, human trafficking and human rights across our business, we have a training plan to ensure that all relevant staff receive appropriate learning. Additionally, we validate that our business partners and importers provide corresponding training to their staff, suppliers and providers.

Signed:

Damian Evans

Chief Executive, MandM Direct Limited

24^th August 2021