Associated British Foods : Primark Modern Slavery Act Statement

Primark Ltd. Modern Slavery Statement

2021

Our commitment (introduction from Paul Marchant) 2

Our company 2

Our response to Covid-19 3

Accountability 3

Our policies and approach 5

Addressing issues of gender in our supply chain 6

Due diligence to identify risks 7

Supplier selection 9

Training and awareness raising 11

Stakeholders and partnerships 15

Traceability and transparency of supply chains 16

Purchasing practices 17

Freedom of association and worker representation 18

Responsible recruitment 19

Helping workers and communities understand their rights 20 and the risk of modern slavery

Access to remedy and grievance mechanisms 26

Providing remedy and investigating allegations 31

Measuring our impact 31

Global risks within the garment sector 32

Our commitment

We are pleased to share our sixth Modern Slavery statement which covers our activities for the financial year ending 18th September 2021, in respect of the requirements under the UK Modern Slavery Act 2015.

Modern slavery is one of the most salient risks within global supply chains. Our commitment to our customers and stakeholders on this is very clear: it is a zero-tolerance issue at Primark. We take our responsibility to respect human rights extremely seriously and are committed to preventing and addressing any modern slavery risks that we identify in our operations and, where we can, in our supply chain. We do this in line with the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Supply Chains.

In this statement we outline how our commitment is put into practice through our wider risk and due diligence processes, highlighting areas of risk we have identified and steps we are taking to address these risks directly ourselves, with our partners and with stakeholders across the industry.

All our Modern Slavery Act statements can be found on our Primark Cares website, and we welcome feedback on our efforts from our stakeholders, our customers, and other interested parties.

This statement was endorsed by the board of Primark Limited in March 2022.

Paul Marchant

CEO of Primark

March 2022

Our company

Primark is an international retail company employing over 70,000 people. Our range includes womenswear, menswear, childrenswear, footwear, accessories, beauty, and homeware. We are headquartered in Dublin, Republic of Ireland and have over 400 stores in 14 countries including the UK, Republic of Ireland, mainland Europe and the USA. We work with hundreds of suppliers, and through them deal with over 900 factories across 26 countries. And while we don't own the factories that produce our goods, we recognise we have a responsibility to ensure our products are made in good working conditions and free from modern slavery.

suppliers

factories

582,918

countries

workers

321,193

261,725

female workers

male workers

1206

audits conducted in 20201

Primark is part of the Associated British Foods plc group of companies and, for the purposes of the UK Modern Slavery Act 2015, it is covered by theABF Modern Slavery Statement.

1All data is correct as of March 2022. Information is taken from thePrimark Global Sourcing Map which shows first-tier production sites which make Primark's products. The factories featured on the map are Primark's suppliers' production sites which represent over 95% of Primark products for sale in our stores. Production sites are included once they have worked for us for over one year.

Assured figure by auditors KPMG. This figure is lower than in previous years as we were prevented from conducting audits in line with our policy on auditing 100% of sites annually, due to Covid restrictions and lockdowns.Assurance statement.

Our response to Covid-19

The impacts of the Covid-19 pandemic on people's lives continue to be felt across our supply chain.

In response to the lasting impact of the pandemic for many workers, we have doubled down in our efforts to support their wellbeing and their access to decent work. Vulnerabilities that many workers already faced have been exacerbated as many were left to bear the emotional, physical, and economic scar from a variety of outcomes, from temporary to total loss of work and income, short or long-term illness and the loss of family members in countries with little or no public health care and social security. This has been particularly true for women who continue to be disproportionately impacted by the pandemic2. In addition to family hardship, their responsibilities for caring for family members affected by Covid-19 in the home has also grown.

Primark's Ethical Trade team has worked to support the welfare of workers and farmers in its supply chain since the onset of the pandemic. A short-term "wages fund" was established in seven key sourcing countries to support our suppliers' ability to pay wages at the same time as we were forced to close the majority of our stores. Garment orders that were cancelled at the outbreak of the pandemic were either subsequently reinstated in full; superseded with new orders; or where this was not possible, the fabric liabilities were paid for, meaning that all garments both finished and in production, as well as any fabric costs incurred for Primark prior to the stores closing, were paid for in full.

Alongside our work to uphold our ethical standards in line with ourSupplier Code of Conduct and international guidance and best practice, we also needed to re-evaluate our existing activities and partnerships given some of the challenges that Covid-19 presented in markets for workers and established new ones to provide support. This has evolved to look differently in each country dependent on differing needs, the nature of the pandemic across different countries and the availability of opportunities for partnerships and collaborations.

We currently deliver such activities across several of our sourcing countries, with most of the activities locally designed and delivered through our Ethical Trade and Environmental Sustainability teams located in the countries we source from. In India and Bangladesh our teams' efforts to educate workers and management in our supply chain on COVID-19, including the vaccine, were successful at scale.

Accountability

Our organisation and structure

We have established clear responsibilities and accountabilities for the implementation of our policies and programmes within Primark:

• - Primark is part of the Associated British Foods plc group of companies and for the purposes of the UK Modern Slavery Act 2015 it is covered by the ABF Modern Slavery Statement.

• - Responsibility and accountability for risk management, including in relation to modern slavery due diligence, sits with the chief executives of each ABF business, and the board of ABF provides continuous oversight and support.

• - The board of Primark Limited oversees the strategy around the due diligence of modern slavery risks that are specific to the Primark business and supply

  chain, and it reports on this process to the ABF

  board on a regular basis.

• - The ABF Group Corporate Responsibility Director has oversight of the development of Primark's policy relating to modern slavery due diligence. The Primark Ethical Trade and Environmental Sustainability Operations Director is responsible for operational implementation. Both report to ABF's Director of Legal Services and Company Secretary.

• - Primark's Ethical Trade and Environmental Sustainability (ETES) team of over 130 local experts based in ten major sourcing countries manages the due diligence within the factories that produce our products. This team engages directly with workers in our supply chain and our external partners and experts on the ground, and reports on the results of the due diligence.

Potential and actual risks of modern slavery within the supply chain are managed by the Primark Ethical Trade and Environmental Sustainability Operations Director and are reported to the ABF Group Corporate Responsibility Director. Severe risks are reported to the Primark Leadership Team and the Primark Business Risk Committee and escalated to the boards of Primark and ABF as necessary.

2https://www.ilo.org/global/about-the-ilo/newsroom/news/WCMS_813449/lang--en/index.htm

Policy and legislation

Communicating our progress

Government policy and legislation to address modern slavery and wider human rights risks continues to develop and we are supportive of such measures.

Our engagement in 2020-21 has included:

• - UK Modern Slavery Transparency in Supply Chains. As a founding member of the Business Against Slavery Group (BAS) we have participated in discussions with UK Government on addressing modern slavery throughout the supply chain, and with the Home Office in respect of our support for the Modern Slavery Registry.

• - EU legislation on mandatory human rights and environmental due diligence. Primark is a member of the Sustainable Apparel Coalition (SAC) and we provided input into the SAC Policy Hub submission to the EU on the EU Directive on Sustainable Corporate Governance.

• - Garment Industry Call to Action.

  Primark endorses the Call to Action convened by the IOE, ITUC and ILO which aims to protect workers' income, health and employment and social protection.

• - Myanmar. Discussions with the Foreign, Commonwealth and Development Office (FCDO), the Department for International Trade (DIT), the Department for Business, Energy, and Industrial Strategy (BEIS) and the Home Office have informed

  our on-going human rights due diligence approach

  to sourcing from Myanmar.

• - Issues concerning the Xinjiang Uighur Autonomous Region. We have engaged with BEIS and FCDO in respect of sectoral allegations of forced labour in the Xinjiang Uighur Autonomous Region (XUAR) in China. Our written submission to the Foreign Affairs Select Committee can be readhere.

• - Gender-based Violence and Harassment. Through our partnership with Care International to address gender-based violence and harassment in supply chains, we support efforts to advocate for better policy and legislation.

Communicating our progress is important if our industry is to have an impact in addressing modern slavery and we aim to be transparent in our efforts and to share our learnings.

We report on our progress through our Modern Slavery Act statements and welcome the launch of the UK Government Modern Slavery Registry to provide an accessible repository for company statements. The ABF Group is considering how best to represent the diversity of its businesses in the Registry, and we will submit in line with the Group's proposals. We will also continue to publish our statements on ourwebsite which includes our previous statements from 2016 onwards.

KnowTheChain benchmarks our performance on disclosure of our efforts to address the risk of modern slavery and we welcome their feedback which can be readhere.

We communicate our programme and performance through the Primark Careswebsite and theABFResponsibility Report.As members of the Ethical Trading Initiative (ETI) and the German Partnership for Sustainable Textiles, we are assessed regularly on our due diligence. We also provide regular updates directly to our shareholders and stakeholders.