27 October 2021

Respecting human rights is a fundamental part of how Superdry does business.

Outlined below is our position on slavery and human trafficking.

This is our FY21 Modern Slavery Statement and sets out steps taken by Superdry Plc (which includes its wholly owned subsidiaries C-Retail Limited, DKH Retail Limited and SuperGroup Internet Limited) to ensure modern slavery does not take place in any part of our business and supply chain. We have updated our statement with progress made for the full financial year, between May 2020 and April 2021; our overall modern slavery strategy remains on track.

We review our approach on a regular basis and seek to continually improve through ongoing risk assessment, raising awareness of issues and requirements, and by delivering training to our colleagues and working in partnership with our suppliers and partners..

About Superdry

We design, produce, and sell clothing and accessories globally under the Superdry brand.

We focus on high quality, contemporary products with a strong link between our brand values and our product attributes: sustainably sourced, design detail, quality obsession, end-to-end innovation and affordability. By 2030, our ambition is ‘to become the most sustainable listed global fashion brand’ and as such we are working closely across the business to optimise our operations and supply chains, while delivering on our SEVEN CORE SUSTAINABILITY KEY PERFORMANCE INDICATORS  (KPIs) . Our products are:

• Designed at our head office based in the UK.
• Manufactured by 83 third party suppliers, in 112 (Tier 1) factories globally and crafted from raw materials which are increasingly sourced back to farm/source.
• Sold globally through our stores, through Ecommerce sites and through our wholesale customers.

These activities are co-ordinated by a global team of 3,872 employees and a network of trusted suppliers and business partners.

More information about Superdry, our organisational structure, group relationships and sustainability programme is available in our FY21 Annual and Sustainability Reports at corporate.superdry.com.

About our supply chain

Superdry works with apparel, footwear and accessory suppliers based in the Far East, India, Sri Lanka and EMEA.

Our suppliers may choose to use subcontractors (also known as Tier 2) where specialist components are required, or services needed, which cannot be completed in Tier 1 factories. Our suppliers’ source branded trims and labels through a network of nominated and sourced suppliers (Tier 3).

We work with farm groups and raw material suppliers globally to source fully traceable organic cotton and recycled fibres into our supply chain – including over 1,800 farmers in transition in India during FY21, extending to over 6,500 farmers in FY22. Fully traceable routes are increasing alongside our ambitious sustainability strategy, in FY21 32% of our volume was certified to industry recognised standards to guarantee supply chain traceability - representing 100% of organic and recycled product.

We also have a network of suppliers providing services to support day-to-day business operations, examples of which include transportation, warehousing, and store ancillary services.

We operate sourcing offices in key source countries, which function to support our suppliers in manufacturing our apparel, footwear, and accessories in line with our standards – from quality standards, through to compliance with our ethical standards including our Modern Slavery Policy.

Our commitment to human rights and our Modern Slavery Policy

We actively seek to ensure that our business, business partners and all parts of the associated supply chain are free from all forms of slavery and human trafficking.

The term modern slavery covers forced and compulsory labour, indentured child labour, servitude, human trafficking, and similar violations. These are violations of human rights such as the right to be free from slavery, servitude or forced labour and the right to freedom of movement and other human rights, which are upheld by both international and national legislation.

Our Modern Slavery Policy applies to all colleagues, suppliers and business partners and requires them to implement effective due diligence processes to enable us to understand and identify the potential risks of slavery and human trafficking so that we can report actual and suspected cases to the appropriate law enforcement agencies.

Our commitment to human rights is re-enforced through our human rights policies, which are contained within our supplier manual, and in all contracts from 2016 onwards.

In January 2021, we published all policies on our website corporate.superdry.com including our, relevant to this statement are: -

1. Code of Practice which is based on international standards including the Universal Declaration of Human Rights and the International Labour Organization’s Core Conventions on Labour Standards.
2. Migrant and Contract Worker Policy and Guidelines which aim to protect vulnerable groups of workers by requiring ethical recruitment practices, appropriate conditions for accommodation, and effective communication of terms and conditions of employment.
3. Child Labour operating Procedures utilising industry best practice to enable remediation in the best interests of the impacted child worker.

All policies have been developed in consultation with organisations including the Ethical Trading Initiative (ETI), global experts in due diligence including Bureau Veritas, The Reassurance Network (India, Sri Lanka and Turkey) and Social Compliance Service Asia (Far East). Their ongoing development is managed by our Sustainability and Ethical Trading team, which is overseen by our Executive Committee and Superdry Plc Board of Directors.

In October 2018 we moved from ‘Improver’ to ‘Achiever status with the Ethical Trading Initiative, which recognises our ongoing commitment to human rights and continued advances in our Ethical Trading programme.

How we implement the Modern Slavery Policy

If at any point we suspect or identify any cases of modern slavery, we commit to support the remediation of any victims – working with business partners, other brands, governments, and NGOs as applicable.

We also commit to assisting law enforcement agencies with the investigation, identification and prosecution of any party that knowingly engages in or facilitates slavery or human trafficking.

1. Raising awareness for colleagues, suppliers, and business partners

Our rolling training programme continues to support our cross-business risk assessment and roll-out plan of our Modern Slavery Policy.

In FY22, we will be launching our new online portal covering 100% of colleagues in interactive training on their roles and responsibilities in preventing Modern Slavery. We have continued to prioritise training with all local sourcing office colleagues.

2. Embedding human rights across our business

Superdry has a well-established global team focused on human rights and wider sustainability. This team manages our ethical trading programme as well as progress towards environmental targets.

We have established several mechanisms across our organisation to ensure human rights continue to be embedded in day-to-day business practice:

• We risk assess human rights impacts within our business and supply chain annually and adapt our programme to ensure any issues are addressed. Our saliant issues are available at corporate.superdry.com.

1. Risk assessing new markets: Operating a sourcing office model, we only source from approved locations within the immediate purview of local office teams to help maintain visibility of conditions, risk and to effectively manage due diligence and remediation.
2. Risk assessing supply chain complexity: Recognising that the risk of forced labour is often undetected in complex supply chains, we are utilising our commitments to certified materials, and where possible tracing back to source to validate that we are not sourcing from regions known as high risk of state sponsored forced labour.

Our suppliers are further required to commit to this policy as part of our supplier manual and provide validation and proof on request to ensure appropriate checks are completed to adhere to this policy.

1. Risk assessing potential business partners: All business partners are required to comply with Superdry’s Code of Practice. We have established robust ethical pre-approval processes for suppliers to ensure they comply.

• Annual due diligence throughout our supplier relationships: We audit 100% of Tier 1 and 2 factories on a semi-announced and unannounced basis in all territories. In the last 12 months, we have extended our audit processes to nominated or preferred trims and label suppliers (Tier 3) in key source territories.
  
  
• Continued localise risk assessment: We have employed dedicated ethical trading experts, working directly with all suppliers across our Sourcing regions – with full global coverage and visibility of factory conditions. This structure allows us to respond to risks quickly as they emerge and is critical in negotiating and facilitating transparent risk assessments with factories by building partnerships locally.

• Continuous improvement: Our dedicated ethical trading experts provide training and support to factories to help remediate issues identified during the risk assessment process. This year we launched our intensive care process, focussed on 20% of our factory base struggling to maintain compliance with our Code of Practice following a prolonged challenging period during COVID-19, providing in-factory experts and linking business incentives to associated improvement.

• Termination for continued noncompliance: Termination for continued noncompliance. We will terminate our relationship with any partners in breach of this policy, including any partners that fail to remedy any issues – transparently, sustainably, and in the best interest of impacted victims.  For more information on our approach to factory exits please refer to our corporate website (corporate.superdry.com).

We continue to collaborate alongside other Ethical Trading Initiative members, the Brand Ethics Working Group (BEWG, India) and SORPOS (Turkey) to support the development of best practice guidelines where industry-wide risk has been identified.

3. Measuring the effectiveness of our human rights programme

We report to our Audit Committee, Executive Committee and Superdry Plc Board of Directors regularly to provide continued oversight. For more information on our Governance processes, please refer to corporate.superdry.com.

We continue to update/ set new targets and monitor ongoing impacts of targets achieved since our first report.

Please note that as we are now in our sixth year of reporting we have updated the below table to include FY21 and FY22 only.

Previous targets are available in our archived statements.