Agent Provocateur Modern Slavery And HumanTrafficking Transparency Statement

COMPLIANCE STATEMENT

This statement has been published in compliance with section 54(1) of the Modern Slavery Act 2015 (the “Act”). It seeks to outline the steps taken by Frasers Group plc and its subsidiaries (all together the Group)1 for the year ending 27 April 2025 to detect and prevent modern slavery and human trafficking within its business and supply chains.

INTRODUCTION

There are an estimated 50 million people globally being enslaved with approximately 17 million of these being exploited in the private sector under conditions of forced labour. Modern slavery exists in supply chains around the world, from the cotton in our clothes and the minerals for our electronics, to the manufacturing, warehousing, shipping, cleaning and catering services along the supply chain.

It has been acknowledged that there can be no guarantees of a slavery-free product, but we can and do make every effort to prevent slavery in our supply chains. We recognise that modern slavery is a growing global issue and we understand our responsibility to prevent and mitigate where possible the occurrence of human trafficking, child labour and forced or bonded labour in our business and supply chains.

We have adopted a zero-tolerance approach to modern slavery and human trafficking and take seriously any allegations of human rights abuse against people both within our organisation and within our supply chains. We have implemented and will continue to implement measures to seek to ensure that slavery and human trafficking does not exist at Frasers Group or in any part of our supply chain.

Our continued commitment to our customers and stakeholders means we will always aim to treat the people within our business and supply chains fairly and with respect. As such, we aim to continuously review and improve our practices and policies to ensure that we have the most effective safeguards in place to prevent and mitigate the negative impacts of modern slavery and human trafficking. This statement details how our approach to business and human rights is helping to tackle the risks of modern slavery in our business and supply chains. It provides an update on our previous statement and details of our future commitments.

ORGANISATIONAL STRUCTURE

Frasers Group Plc is a publicly listed company incorporated under company number 06035106, governed by the Companies Act 2006. The Group consists of over 550 subsidiaries which operate in over 20 countries.

This statement covers all subsidiaries which have an obligation to publish a statement under section 54 of the Act. A full list of the subsidiaries can be accessed in the Group's latest Annual Report.

In addition to our obligations under the UK Act, our European subsidiaries are subject to additional Human Rights and Modern Slavery reporting requirements depending on their local legislation.

OUR PARTNERS

The Group has partnerships with many well renowned brands who also act as a second line of safeguarding for the Group. Many of our partners also fall under s.54 of the Act and as such are required to have their own robust modern slavery policies and initiatives in place as well as publish an annual statement in line with the requirements of the Act. In order to fully assess how our modern slavery arrangements are complemented by our largest partners - it may be useful to visit their websites and access their modern slavery statements.

Our manufacturing partners who produce our textiles and clothing also adhere to strict protocols. We require our supplier factories to have valid satisfactory third-party social auditing factory reports from organisations such as Amfori (BSCI) or Sedex which include audits of workers involvement and protection, anti-discrimination, fair remuneration, Anti-child labour and other areas of concern for modern slavery. Our merchandising teams ensure our partner factories standards are maintained and no human rights violations occur, they do this by regular meetings, frequent visits and audits.

Our footwear partner is also committed to ensuring compliance with ethical trading procedures which also include seeking to eliminate human rights abuses within its supply chain and the factories it works with. It is also dedicated to ensuring that its factories undergo third-party ethical audits by recognised audit associations such as BSCI and SGS to ensure there are no breaches of local laws or human rights abuses. It also observes ethical behaviours and local laws such as paying the minimum wage and enforcing the limits on working hours. To demonstrate the measures taken to ensure compliance, our footwear partner publishes an annual ethical trading statement. If you would like more information or a copy of this statement, please get in touch.

PROCUREMENT

Frasers recognises that it has a responsibility and an opportunity to embed ethical procurement practices within both stock and non-stock operations. We aim to drive visibility, promote integrity and mitigate risk in our non-stock supply chain and business operations. In order to achieve this, we regularly review our due diligence processes and actively engage with our vendors. We also regularly review our Purchasing Policy and Procurement Procedures to ensure they incorporate the necessary safeguards to help prevent human rights abuses and that we select vendors that are aligned with the Group’s ethical values

GOVERNANCE FRAMEWORK

A strong governance framework including robust policies and procedures is key to effectively managing and mitigating the risks posed by modern slavery and other human rights issues. It is critical in ensuring we are meeting and exceeding our responsibilities as a responsible employer and retailer as well as the provisions of the Act. To ensure that we are strengthening our governance processes, the Group regularly reviews our governance arrangements to ensure we retain a robust policy framework to address existing and emerging risks. The Board is responsible for overseeing the policy framework and compliance measures whilst the Executive Team is responsible for communicating and implementing the appropriate measures outlined by the policies and ensuring the Group meets its human rights responsibilities. The Group also has a Sustainability Steering Group (as a part of our ESG strategy) and the executive sponsor, the Group CFO reports directly to the Board on behalf of the Group.

RISK ASSESSMENT

The Group employs a traffic light system to categorise our risks. Our approach to risk assessment involves third-party auditing including ethical audits with third-party partners at our overseas warehouses as well as stakeholder engagement. Audits identify risks at factory level. These audits enable us to take immediate action and mitigate our risks across our supply chain.

Our risk framework is agreed and reviewed by the Audit committee whilst the Board reviews the effectiveness of these frameworks annually. Any significant matters that arise during the year outside the review period is reported to the Board.

Frasers has identified that the following Groups are more vulnerable to the risks of modern slavery in its most common forms:
- Migrant workers
- Young and child workers
- Agency, contract and temporary workers especially those subject to outsourced HR functions
- Female workers
- Minority Groups and refugees

Given the size of the Group as well as the geography over which the Group operates it is understandable that we are exposed to numerous risks. Many of the risks we face are embedded in our:
- Supply chains
- Outsourced activities
- Cleaning and catering suppliers
- Corporate Hospitality
- Agency recruitment partners
- General recruitment activities

POLICIES & CONTROLS

We regularly review our policies and policy framework with the aim of ensuring they remain robust and effective. Our policies are designed to help detect and prevent modern slavery and human trafficking within the organisation and currently cover the following areas:
- Procurement and Manufacturing
- Health and Safety
- Recruitment and Employment
- Whistleblowing
- Anti-Bribery and Corruption
- Governance

The following departments are responsible for the day to day implementation of our policies and procedures which support us in meeting our human rights responsibilities:

Human Resources
People and Employment including contracting with third- party agencies

Company Secretariat
Whistleblowing and Governance Framework

Group Legal
Contractual terms and conditions

Commercial
Procurement and Supply Chain Management

KPIs
We continue to develop the framework and implementation of appropriate KPIs to ensure we continue to meet and exceed our goals and commitments.

Due Diligence / Transparency
Moder slavery is a complex issue and takes many forms including: child slavery, human trafficking, forced labour, bonded labour, forced marriage and descent-based slavery. Many of these forms of modern slavery have the potential to impact the group. It is this potential impact that makes it a priority for the Group that we trade ethically and as such, we are committed to ensuring that we implement all the requirements of the Act and make every effort to safeguard the wellbeing of our people and that of the most vulnerable in society.

As part of our on-going drive to identify and mitigate the risks posed by modern slavery, we will continue to enhance our due diligence processes. We conduct due diligence within our supply chains and operations to understand where our risks lie, whether we have the appropriate controls in place and whether there have been instances of modern slavery issues detected within our organisation and supply chain.

The Group uses products and services which often have very complex supply chains and associated risks. We have taken steps to identify areas where there are risks of modern slavery occurring within our business and supply chains and we are working to eliminate that possibility.

We have embedded due diligence checks in our onboarding process for our suppliers as well as undertaking thorough background checks for our manufacturers and monitor third-party actors in our supply chain on an ongoing basis.

The ethical audits our third-party suppliers and warehouses in higher risk areas are subject to, ensure that we are also addressing the risks in the regions where they operate including risks such as forced or excessive overtime, accommodation tied to employment and no access to grievance mechanisms within their work environment.

KEY INDICATORS OF MODERN SLAVERY

We have identified the following as key indicators of modern slavery and have highlighted these to the workforce, so they can identify possible signs of modern slavery.

- Agency workers being asked to pay fees to obtain work
- Workers not having access to or control over their immigration or ID documents
- Salaries being paid into accounts not in the name of colleagues
- Colleagues living in overcrowded conditions
- Obvious signs of mental distress or fear of physical abuse
- Restricted movement at work or in an accommodation
- Obvious signs of physical abuse

In line with the Employer Pays Principle, we have made all colleagues aware that agency workers should NOT be required to pay recruitment fees or deposits for any work offered by the Group. We have also highlighted to our agency partners that deceptive recruitment practices will not be tolerated and may result in action being taken against them. Our partners are also aware that cash-in-hand, withheld or delayed payments are not acceptable, and our colleagues are encouraged to report any such instances of this practice.

If members of staff are subject to or have knowledge of a colleague having restricted movement at work or in an accommodation they are encouraged to speak to a senior member of staff or make a confidential report using our whistleblowing procedures.
We also encourage our employees to report any harsh or inhumane treatment they may have experienced or have knowledge of, occurrences of worker documentation being withheld as well as any instance of poor working conditions through our ‘your company, your voice’ initiative.

RECRUITMENT & ONBOARDING

We aim to attract a diverse workforce who are passionate about what they do and reflect our values. We recruit, promote and reward people on merit, and do our best to promote equality, diversity and inclusion in all our working practices. Although we directly employ many of our colleagues, we on occasion partner with agencies to fill the gaps that arise. We are clear with our recruitment partners about our policies which set expectations of behaviour and give clear paths of escalation and whistleblowing (for employees, contractors and suppliers). We ensure we only partner with reputable agencies and we do not use nor permit recruitment fees . We always aim to operate in a legal and ethical manner with our recruitment practices and ensure:
- Legal right to work within the given country is checked
- Suitable references are received
- Suitable identity documentation is available to the candidate (i.e. they have access to their passport or other similar legal document in their name). We do this by requesting that these documents are presented by the candidate
- Identity confirmation checks are also to be carried out during the recruitment process.

Our full Recruitment Policy is available internally to our colleagues.

Our Equality, Diversity and Inclusion policy also sets out our commitment not to discriminate on the basis of a person’s age, disability, gender or gender reassignment, pregnancy or maternity, race, religion or belief, sexual orientation or marriage/civil partnership and national or ethnic origin. To make sure we meet this commitment, we ask candidates to voluntarily complete a (confidential) recruitment monitoring questionnaire when they apply for a vacancy. The information provided is separated from the application, so those involved in selection do not have access to it.

TRAINING

We have a range of tools in place including videos and literature to educate colleagues about their rights and a number of communication channels, including an internal telephone hotline and comments boxes on site, for reporting any feedback or concerns. Anyone making a report can remain anonymous if they choose. We also continue to review and develop our colleague training, monitoring processes and evaluation of outcomes, and work with our employment agencies and other relevant bodies, including the Gangmasters and Labour Abuse Authority and the police, to support our training and knowledge.

Is part of our elevation strategy, the Group has refreshed its training initiatives including our induction training which covers our expectations for colleague behaviour, colleague rights, what colleagues can expect of us as well as avenues they can utilise to provide feedback on the Group's employment practices. It also introduces new colleagues to essential policies such as
- Equality, Diversity and Inclusion
- Whistleblowing
- Anti-Bullying, Harassment and Victimisation
- Anti-Bribery and Corruption
All other Policies are available to colleagues on the intranet.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

To assess the effectiveness of the policies an controls we have in place, we will consider
- the number of reports received from colleagues, the public, or law enforcement agencies which have identified modern slavery practices; and
- the awareness and understanding of modern slavery across the business, its supply chain and the distributor network.
The Group is not aware of any human rights breaches in the 2025 financial year.

ONGOING COMMITMENTS AND FUTURE COMMITMENTS

The Group commits to:

- continue to raise awareness around modern slavery and forced labour
- continue to promote transparent recruitment practices including:
- ensuring all payments are made to bank accounts belonging to colleagues
developing and maintaining more robust recruitment policies
- ensuring contracts are in place for all workers
- Continued ethical audits for our partners and risk assessments of our relevant operations

We will also assess ways in which to enhance our supply chain transparency including:
- Supply chain mapping
- Undertaking a GAP analysis of our supplier contracts to ensure the terms reflect the requirements of the Act as well as the Group's commitments around modern slavery
Further strengthening our supplier governance

The Group will also assess the value of a partnership with anti-slavery organisations that will able to provide expert advice and guidance on how best to protect our workforce and ensure the policies and procedures we have in place are robust enough.
We will also look at additional training initiatives to enhance training and awareness for managers and other colleagues who are directly involved in supply chain management and HR roles.
The Groups also commits to having a Board appointed person who will be responsible for modern slavery.

RESPONSIBILITY & ACCOUNTABILITY

We recognise that everyone in our business and supply chains has a duty to be alert to he risks that modern slavery and human trafficking present. We encourage staff to report any concerns and are given the support to do so, and the, Board and the Executive team are expected to respond to those concerns accordingly.
Our Executive Team led by our CFO, Chris Vootton, takes responsibility for ensuring adequate resources are in place to ensure compliance with the requirements of the Act, including the implementation and oversight of the measures set out in this Statement.

The Company Secretariat team is responsible for gathering the necessary information to draft the statement and present it to the Board for approval prior to its publication.
This statement was approved by the Board of Directors on 4 July 2025.

As part of the Group's commitment to transparency, this statement will also be published on modernslaveryregistry.org