As part of our commitment to the UK Modern Slavery Act 2015 we are sharing our Modern Slavery Statement for the financial year 2024 – 2025. The contents of this statement are aligned with the Home Office’s Statutory Guidance.

Human trafficking is a process of bringing a person into a situation of exploitation through a series of actions, including deceptive recruitment and coercion.

Forced labour is any work or services which people are not doing voluntarily, and which is exacted under a threat of some form of punishment. Bonded labour is demanded as a means of repayment of a debt or a loan.

Slavery is a situation where a person exercises (perceived) power of ownership over another person.

Whilst modern slavery exists in all sectors, we recognise that there are heightened vulnerabilities within our industry due to the complexity of supply chains and the labour practices within the industry and particularly in lower tiers of the supply chain. ME+EM does not tolerate any form of the above examples of modern slavery within our supply chains or direct relationships. We are actively committed to supporting our supply chain partners in the prevention and mitigation of modern slavery and through our own direct business relationships, as outlined in this statement.

1 | Organisation Structure and Supply Chains

2 | Policies

3 | Due Diligence Processes

Supplier Auditing

We are an engaged member of the Sedex community and use their globally recognised auditing methodology Sedex Members Ethical Trade Audit (SMETA) as the benchmark for monitoring and assessing our suppliers’ approach and performance to prevent human rights violations in their supply chains.

SMETA audits are governed by the standards contained in the Ethical Trading Initiative base code, specifically reporting on labour standards and health & safety. The audit reports for our suppliers are held on the Sedex database which is also used as an interactive tool for suppliers to upload appropriate information that gives us greater visibility of their ethical practices.

In the event that a supplier has an audit where non-compliances are found, they are given a summary of the action required to resolve the non-compliance and a time frame in which to satisfy the auditors recommendations. All active ME+EM suppliers must provide audit visibility every two years, or annually for sites in China and Turkey. We have been working with our suppliers to conduct SMETA audits as our preferred auditing methodology. We are pleased that 88% have achieved this, including our top 10 manufacturing sites.

Self-Assessment Questionnaire

All Sedex member suppliers are required to complete the Sedex Self-Assessment Questionnaire (SAQ). The SAQ gathers information about suppliers’ business practices, management systems, policies, and worker conditions to assess compliance with international labour standards. The questionnaire requests suppliers to confirm whether they have a modern slavery policy—including forced or involuntary prison labour—communicated to all workers, and whether they have evaluated modern slavery risks in their workforce and that of their suppliers, subcontractors, or business partners. In 2024–2025, 72% of our suppliers completed the SAQ, and we aim to increase this to 90% in 2025–2026.

Reporting

We have developed an internal reporting system to capture and monitor supplier audit outcomes, with a focus on identifying and addressing any non-compliances related to labour standards. Each issue is assessed for severity, and we apply our own scoring to ensure prompt and proportionate remediation with the supplier. While SMETA audits recommend timelines for resolution, we require faster action where there is a potential risk to workers. Audit outcomes are presented in a dashboard separated by supplier origin, enabling us to identify regional trends and systemic risks. Key findings and priority actions are shared with the leadership team monthly to ensure accountability and continuous improvement.

Whistle Blowing and Grievance Mechanisms

We provide a whistle blowing procedure in the employee handbook which explains how an employee can communicate their concern through internal escalation or contact details for an independent organisation where advice and support can be obtained. In addition to this we provide contact details for a dedicated modern slavery helpline. As part of our forward objectives we will be assessing grievance and whistleblowing mechanism options for our stock suppliers.

Commitment to Trade Union Rights, Freedom of Association and Collective Bargaining

Guided by the Ethical Trade Initiative (ETI) Base Code, ME+EM upholds the rights of all workers in our supply chain to freedom of association and collective bargaining. This commitment supports workers' opportunities to join trade unions, engage in related activities without fear of discrimination, and use parallel means of representation where union activity is restricted. We are committed to strengthening direct worker engagement and transparency, particularly in high-risk sourcing regions such as China and Turkey. Our steps include:

● Identifying Representation: Identifying suppliers that have established worker representation

● NGO and Trade Union Partnerships: Proactively seeking and strengthening links with NGOs and trade unions to enhance worker dialogue. In 2024, we worked with an NGO in Madagascar to gain a deeper understanding of local challenges and provide support to our sourcing partner.

● Monitoring and Engagement: We track the presence of worker representatives and encourage their active participation during site visits as a key part of our due diligence process.

4 | Risk Assessment and Management

One of the key focuses of the CSR team is to assess our stock suppliers due to the higher risk to modern slavery in these supply chains. Through the creation of our internal dashboard we can understand risk by county and region which dictates our focus. We use multiple sources to identify risks in our supply chain, including the Sedex suite of risk tools that combines information from several sources including:

● ILO (International Labour Organisation)

● Walk Free

● UNDP (United Nations Development Programme)

● WEF (World Economic Forum)

● ITUC (International Trade Union Confederation)

● UNICEF

At ME+EM, we monitor and assess our supply chain through factory visits, social audits, Sedex Self-Assessment Questionnaires (SAQ), risk assessment tools, and our own supplier reviews. As members of the Ethical Trading Initiative (ETI), we engage with global issues affecting workers, such as displaced people from Ukraine and the 2023 earthquakes in Turkey. We prohibit sourcing from the Xinjiang Uyghur Autonomous Region and are part of the Coalition to End Forced Labour in collaboration with Anti-Slavery International.

We demonstrate our commitment to best practice and responsible sourcing through our collaboration with recognised industry bodies and adoption of their standards. To strengthen traceability and risk management, we have joined the Leather Working Group (2022) and Textile Exchange (2023), achieving the Responsible Animal Fiber certification. We are expanding our use of certified materials by pursuing standards such as the Good Cashmere Standard and GOTS. Furthermore, our Ethical Trading Initiative (ETI) membership enables us to share insights with other brands and promote industry-wide transparency.

We review auditing dashboards monthly at leadership level. Any evidence of human rights violations would be escalated to the board with recommended actions. Our priority is protecting workers—whether by working with suppliers on remediation or, if necessary, responsibly ending relationships.

We also strategically work with nominated stock suppliers, maintaining direct relationships and visibility into their production sites, and are actively mapping our supply chain beyond Tier 1 to enhance transparency and mitigate risks in lower tiers.

Risk Assessment

We conduct periodic risk assessments across our supply chain to identify, monitor, and mitigate inherent and supplier specific sourcing risks. Our assessments utilise the comprehensive Sedex risk reporting framework, covering Country, Region, and Sector risks, as well as Forced Labour Insights and Audit Indicator Details.

The CSR team analyses risk ratings for our main sourcing countries, based on a review of key labour issues including discrimination, forced labour, freedom of association, child labour, gender, employment, wages, and working hours:

Identified Risks and Steps Taken:

Forced Labour and other risks in the cotton supply chains

o We are aware that there is a risk of modern slavery in global cotton supply chains, specifically in the lower supplier tiers. We have adopted a strict cotton policy that prohibits suppliers sourcing from Uzbekistan, Turkmenistan, and China. This is due to credible concerns of forced labour and human rights violations in specific regions where cotton is grown in these countries. In addition to this policy, we have increased our use of certified, organic cotton, which provides traceability to the source of the cotton and therefore mitigates the risk of forced labour as these standards uphold strict social standards.

Migrant and Refugee workers

o We have identified the migrant risk in our top 5 manufacturing countries (Portugal, China, Italy, Turkey, India) We collect and analyse data on the number of migrant workers in these countries from social audits for our tier 1 manufacturing sites. From the audits we monitor worker representation and look for evidence of robust human resources to ensure migrant workers receive compliant wages and benefits and other example of good practice such as translated policies in the workers local language. We are looking to go beyond audit and engage with The Reassurance Network, who provide in country support to brands and manufacturers, promote responsible supply chains and protect human rights.

Temporary workers and the use of subcontracting

o The use of temporary and subcontracted workers presents a heightened risk of modern slavery. Seasonal production peaks and smaller production runs also undermine regular and consistent contracts for workers and encourage reliance on sub-contracting for flexibility. We recognise the need to engage with suppliers to ensure our ways of working are conducive with our supplier’s ability to responsibly manage their capacity and commitment to their workers. We have begun supplier engagement to map subcontractors beyond Tier 1 and we are investing in traceability platforms to hold this data. We request that all suppliers seek permission prior to using a site that is not approved by ME+EM and we plan to engage with The Reassurance Network to support our teams with visiting new sites.

Mitigating Risk

We manage risk through a structured and proactive mitigation strategy. Our immediate priority is a rigorous follow-up process with suppliers after audit publication, ensuring they promptly acknowledge findings and provide mandatory updates on all non-compliance actions. We maintain strict control over our supply base, including carefully managing the number of sites and suppliers we use in China, and requiring annual audits for factories in both China and Turkey.

Our operational oversight is robust, with our Product and CSR teams incorporating mandatory risk follow ups during every trip. We ensure continuous senior management oversight through monthly risk updates and maintain transparency and engagement by regularly communicating with all suppliers, conducting supplier feedback surveys, and continually monitoring regional news to anticipate and address emerging risks.

We are committed to continuous process monitoring, with mitigation actions adapted specifically to regional and supplier risks. For the 2025-2026 financial year, we will further strengthen our risk assessment and mitigation strategy, including investing in external expertise, to ensure the robust protection of all workers from modern slavery. Our specific objectives are outlined in Section 7.

Our programme in action

To date we have not received any reports through our grievance mechanism or whistleblowing procedures from direct employees of ME+EM.

We achieved 100% audit visibility in 2024/2025 for our active supplier base and we have not been informed or discovered any evidence of modern slavery through the auditing process. Over the course of the next financial year we will aim to set additional KPI’s to monitor the effectiveness of our modern slavery efforts. Such KPI’s will cover areas such as training and supplier engagement.

As part of our ongoing commitment to visibility and identifying risk, we have supported our valued suppliers by covering the cost of audits when needed and assisting them through the remediation process, demonstrating our dedication to continuous improvement and partnership.

5 | Training & Communication

Responsible Purchase Practice Training

In September 2024, we partnered with the Ethical Trading Initiative (ETI) to deliver Responsible Purchasing Practices training for our buying team. The session explored the link between purchasing decisions and human rights, highlighting how these dynamics play out within ME+EM. The session identified key areas for improvement, introduced relevant frameworks, and outlined practical approaches to help shape an effective action plan.

We recognise the impact our purchasing practices can have on suppliers and the potential pressure this places on workers—particularly those most vulnerable to exploitation. As part of our ongoing commitment to responsible sourcing, we are currently reviewing training options for 2025–2026 to further empower our teams. Our goal is to ensure our teams fully understand their influence and keep ethical considerations at the forefront of their decision making.

Preferred Materials Tool

We launched a Preferred Materials Tool for our buying and design teams to facilitate the selection of certified materials. This initiative has significantly enhanced our understanding of traceability and verified sources, and we are committed to continuously building upon this framework to further improve knowledge across the business.

Communication

Effective communication and training are central to embedding our zero-tolerance approach to modern slavery. Our updated supplier manual and CSR policies set clear expectations, and in 2023 we extended enhanced requirements beyond Tier 1 to include key fabric and trim suppliers.

Internally, our CSR team shares audit results, remediation actions, and risk alerts to ensure human rights considerations are part of everyday decision making. Externally, we engage suppliers through regular updates, performance reviews, and in-person visits, which also serve as training opportunities to share best practice and address risks.

We are committed to building supplier capability through open dialogue, guidance, and recognition of strong practices. 10 of our supplier relationships span over 15 years, highlighting our strong relationships with suppliers. We continue to prioritise open, honest engagement, supported by regular site visits to strengthen partnerships and assess conditions firsthand.

6 | 2025-2026 Objectives and Targets