Supply Chain and Modern Slavery Act Statement

This statement is drafted and published in accordance with section 54 of the Modern Slavery Act 2015, transparency in supply chains. The statement is a summary of the steps taken during the financial year ending 28th January 2023 to ensure slavery and human trafficking is not taking place in any part of our business or in our supply chain.

Founded in Wimbledon in 1990, LK Bennett is a British accessible luxury brand defined by a love of vintage eccentricity, functionality, and tradition with a desire for beautiful design and considered luxury.

We recognise the continued complexity of a global supply chain and understand the risks and severity of modern-day slavery and human trafficking. We take our responsibility seriously, making every effort to protect the rights and well-being of all those involved.

The parent company of LK Bennett Fashion Ltd. is Ying Ling Kam Trading Company Limited (based in Hong Kong), a Chinese luxury apparel group.

LK Bennett Fashion Ltd. is a multichannel global retailer with over 70 stores, concession partners, and branded locations worldwide. Our vision is to be a Global leader that inspires modern, confident women through luxurious British Design. We employed c. 230 people with an annual turnover of c.£49 million for the year ending January 2023.

LK Bennett Fashion Ltd. remains true to the origins of L.K. Bennett, offering exceptional quality in all we do. We are respectful of what is expected of us; a stable supply base and well-established relationships with suppliers and manufacturers who share our business values. Our unique selection of clothing, shoes and accessories is designed in our London-based head office and beautifully crafted across Europe and the Far East.

We are proud of the long-term relationship we have with our suppliers. In 2022, LK Bennett worked closely with 42 primary suppliers, with 52 nominated (Tier 1.) manufacturing sites located in 9 territories worldwide; Bulgaria (1.2%), China (18.8%) (manufacturing site locations in provinces: Guangdong, Hong Kong, Inner Mongolia, Jiangsu, Shandong, Zhejiang), Italy (20%), The North Republic of Macedonia (6.7%), Portugal (4.8%), Romania (2.4%), Spain (42.7%), Turkey (3%), U.K. (0.4%).

The Top 10 suppliers across all product categories account for 87% of our total purchasing volume, with manufacturing sites in across Europe producing 78.2% of our collections, Asia 18.8% and Eurasia 3% of the purchasing volume.

Quality

We deliver an unrivalled and consistent level of excellence in everything we do, across all of our products, customer touchpoints and interactions.

Respect

We respect our customers by delivering what they want and expect from us and even more. We respect employees by encouraging an open and motivating work environment.

Authenticity

We articulate authenticity through genuine people, real design, honest service and by staying true to our values.

Inspire

We want to inspire our customers and create an emotional connection with them. We want to inspire our employees to want more and go further.

Modern Slavery Definition

• Slavery: Dehumanised, treated as a commodity or bought and sold as ‘property’
• Forced Labour: Work or service that is taken from a person under menace of a penalty and for which the person has not offered themselves voluntarily.
• Human Trafficking: The act of recruiting, transporting, transferring, harbouring, or receiving a person, through any coercive means (such as threat, use of force, deception, or abuse) for the purpose of exploitation.
• Debt Bondage: A worker pledging their labour or the labour of others under their control as security for a debt; when either the real value of the work undertaken is never applied to repayment of the debt, or the length and nature of the work that has to be undertaken is never fully defined or limited.
We continue to be committed to working in collaboration with suppliers, encouraging continual review, development, transparency, working to achieve best practice in all our business operations.
We require all our final goods manufacturers to adhere to our comprehensive (contractual) Supplier Manual in which we confirm the importance of ethical business policies and working practices both in our own business and within our supply chain.
Our sourcing principles are based on the Ethical Trading Initiative (ETI) base code founded on the conventions of International Labour Organisation (ILO) an internationally recognised code of labour practice, designed to be fair and achievable, covering the principles of International law for best practice in rights at work: no child labour, no forced labour, no discrimination, the right to freedom of association and collective bargaining, wages, working hours, communication of employment, health and well-being setting a minimum requirement for suppliers and associated manufacturing sites to demonstrate Corporate Responsibility wherever in the world we are operating.

We recognise the greatest exposure to slavery and human trafficking lies within the lower tiers of our supply chain. During 2020 to mitigate and manage the risks during the COVID­19 pandemic, our teams continued to focus on transparency and component traceability, adapting to working with suppliers through virtual meetings. We continued to evaluate and monitor supplier practises with open communication and transparency across our supply base, mapping supported by our primary supplier declarations: self evaluation documentation.

Prior to March 2020, our product development teams visited our primary suppliers and associated manufacturing sites regularly, working closely to follow up on corrective action plans that were in place, encouraging continual improvement acknowledging the challenges in the workplace during the global pandemic. We continue to review and to add details relating to shared practises within the nominated manufacturing sites demonstrating minimum standards set out in our Code of Conduct:

• Employment Ethics inc. Fair Treatment, Equality and Diversity, Anti-bribery, and corruption
• Health & Safety Practices
• Environmental Practices
• Animal Source Material Ethics

With the restrictions on travel and the absence of third party social compliance audits being conducted during 2020, we know that any genuine and thorough assessment will inevitably reveal incidents of non­compliance and where breaches are identified in the coming year, we will continue to work closely with our supplier and/or the manufacturer to support and improve standards recognising a continual need for education and self assessment both in our business and those who supply us with goods and services. We hope our teams will be able to resume site visits in the future developing the close supplier relationships that are important to us.

Our established process for introducing a supplier/manufacturer follows our sourcing principles below, encouraging transparency:

• All proposed Suppliers must be met in person at LK Bennett Fashion Ltd. Head Office or alternatively in the country of manufacturer.
• All proposed Suppliers are to be registered into our supplier database and accounts systems for transparency. Suppliers are required to complete a New Supplier Set-up form, a Supplier Declaration - Factory self-evaluation form; stating minimum standards and provide a copy of a recent independent IRCA social compliance audit report which has been conducted in compliance with the legislative requirements wherever in the world the manufacturing operates. These documents collate key information on labour practises, working environments and general health and safety practises within the nominated supplying business. All documentation received is read by a senior member of the LK Bennett Fashion Ltd Technical team and discussed with our Buying director and the proposed supplier.
• All suppliers receive the LK Bennett Fashion Ltd Terms and Conditions during initial discussions outlining the conditions of engagement including the code of conduct and business policies underpinning our minimum expectations of business practises, encouraging shared learning.
• Suppliers are required to sign they have read and agree to meet the minimum standards of our responsible sourcing code of practice (please refer to the Code of Conduct), prior to the confirmation of production commitment.

When beginning a relationship with a supplier, our Design, Buying and Technical teams will work closely with the supplier/manufacturing site to build a strong and trusting working partnership. We maintain an on-going dialogue and process to remedy any identified breaches and improve business policies and practises.

In March 2020, our business adapted to new ways of working, with many of our employees working with flexibility from home. We recognise the value of communication and involvement; it is important for us to provide a forum for our employees and our suppliers to discuss where they find it difficult to implement improvement projects; during the global pandemic it was no different. In November 2020 we released a short survey to review how the pandemic was affecting our suppliers and those involved in the production of our products, helping us to understand and address root causes of recurrent issues rather than walking away where concerns are raised. We recognised the need to support by making payment in full for goods ordered, even on the occasions where goods were delayed due to global restrictions. We created flexibility within our business critical path to avoid situations where excessive overtime may be required in producing our orders and we believe that our actions in turn provided job security within our supply chain. Our aim is to ensure that all workers are protected from excessive pressure and duress.

We have mapped our primary suppliers and their associated manufacturing sites (Tier 1.) and we continue to improve our internal systems to support the mapping of our component suppliers i.e., materials, yarns, dye & print houses, buttons, and trims (Tier 2 and 3), increasing the transparency further through our supply chain with the use of certified raw materials through the fabric mills, yarn spinners, and tanneries.

With the continued support from our CEO and Leadership team to strengthen our systematic management of policies and working practices, we are committed to raising awareness of Modern Slavery risks, to enhance our ability to identify key indicators within our supply chain and promote effective remedial actions. We recognise that preventing slavery and human trafficking is complex and appreciate that the risks are not static; the responsibility for our prevention strategies sits with the Board of Directors and the execution with the Head of Technical. We will continue to assess the efficacy of our current actions and measure progress on an annual basis.

This statement has been approved by the Board of LK Bennett Fashion Ltd. and its Chief Executive Officer, Mr DARREN TOPP.

If you have any concerns or questions regarding our MSA statement, please contact LK Bennett Fashion Ltd. Head of Technical and Creative Development, Lynette Bradford: [email protected]