Supply Chain and Modern Slavery Act Statement 2024/2025

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 1 st February 2025 to ensure slavery and human trafficking is not taking place in any part of our business or in our supply chain.

Introduction

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.

Our Business

The parent company of LK Bennett Fashion Ltd. is Ying Ling Kam Trading Company Limited (based in Hong Kong).

LK Bennett Fashion Ltd. is a multichannel global retailer with over seventy (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. From time to time, we use the services of freelancers and contractors, and work with a third-party warehouse in the UK.

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 in becoming the socially and environmentally responsible brand we can be, with 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 Asia.

We are proud of the long-term relationships we have with our suppliers. In 2024, LK Bennett worked closely with 45 primary suppliers, with 76 nominated (Tier 1.) manufacturing sites located in 11 territories worldwide; Bulgaria (3.4%), China (27.4%) (manufacturing site locations in provinces: Guangdong, Hong Kong, Inner Mongolia, Jiangsu, Shandong, Zhejiang), Greece (0.1%), India (3.9%), Italy (14.2%),Mauritius (0.1%) Portugal (7.1%), Romania (7.2%), Spain (33%), Turkey (3.3%), UK (0.4%).

The Top 10 suppliers across all product categories account for 80.6% of our total purchasing volume, with manufacturing sites across Europe producing 65.4% of our collections, Asia 31.3%, and Eurasia 3.3% of the purchasing volume.

Our Brand Values

Quality

We deliver an unrivalled and consistent level of excellence in everything we do, across all 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.

Policies and Contractual Obligations

LK Bennett Fashion Ltd. seeks to ensure that not only our business but our business partners and those within the supply chain operate a zero-tolerance approach towards slavery and human trafficking, recognising it is complex with multiple layers within a Global supply chain.

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 must be undertaken is never fully defined or limited.

We recognise all our business relationships are important acknowledging that modern slavery can occur in any element of the supply chain, including the workforce of contractors and service providers. We continue to be committed to working in collaboration with our suppliers whether of purchased services or those who are integral to the manufacture of our collections. We encourage continual review, development, transparency, working to achieve best practice in all our business operations.

We require all primary (tier 1) suppliers of our final goods, where we have a direct relationship 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.

In addition to our code of conduct we require our suppliers to comply with our Human Rights Policy. We identify Uzbekistan, Turkmenistan, Myanmar as banned countries where goods are permitted to be manufactured, in addition to the Xinjiang Uyghur Autonomous Region (XUAR) in China, due to ongoing concerns of forced labour and violations of human rights.

Due Diligence Processes

At LK Bennett, our robust recruitment process includes our own due diligence checks to validate original documentation such as passports and rights to work, as appropriate, and where we work with recruitment agencies, we request visibility of their modern slavery policies and processes. Our employment contracts and polices are written to protect worker rights and to promote a safe and fair work environment for everyone.

We recognise the greatest exposure to slavery and human trafficking lies within the lower tiers of our supply chain. During 2024, we conducted our risk assessment by reviewing the country of source and industry, taking account of the risks to workers by sector, nature of work and type of worker.

Our product development teams continued to focus on our suppliers where we have a direct relationship enabling transparency and component traceability. We continued to evaluate and monitor supplier practices with open communication and transparency across our supply base, mapping lower tier suppliers supported by our primary supplier declarations: shared Ethical and Social compliance audit reports with a focus on labour standards and health & safety in the workplace. Primary suppliers also completed self-evaluation documentation.

Our product development teams conducted in-country site visits in Spain, Italy and Turkey with our primary suppliers and the associated manufacturing sites, raising the topic of social compliance as a priority during these trips; working closely to understand any concerns raised during social & ethical audits and actions taken against corrective plans in place, encouraging continual improvement acknowledging challenges in the supplier location and nature of worker activity in the workplace.

• Employment Ethics inc. Anti-Modern Slavery and Trafficking, Human Rights, Fair Treatment & Complaints, Equality and Diversity, Anti-bribery, and Corruption
• Health & Safety Practices
• Environmental Practices
• Animal Source Material Ethics

We understand that any genuine and thorough assessment will inevitably reveal incidents of non-compliance and where breaches are identified in the coming year, we will continue to work closely with our primary 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. Our product development teams will continue to conduct in country visits to support developing the close supplier relationships that are important to us.

Strengthening Supplier partnerships

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

1) All proposed Suppliers must be met in person at LK Bennett Fashion Ltd. Head Office &/or virtually. Where possible an in the country meeting will involve senior members of the nominated site of manufacture.

2) 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 practices, working environments and general health and safety practices 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.

3) 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 practices, encouraging shared learning.

4) Suppliers are required to sign that 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 collaborate 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 practices.

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.

LK Bennett recognise the associated pressures on suppliers in a shortened lead time, our product development teams work openly with our suppliers to ensure flexibility to avoid situations where excessive overtime may be required in producing our orders and we believe that our actions in-turn continue to provide job security within our supply chain., our aim is to ensure that all workers are protected from excessive pressure and duress in the work place.

Our plan for the future We have mapped our primary suppliers and their associated manufacturing sites (Tier 1.) We are committed to improving our internal systems to support the transparency of 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., with a focus on fabric mills, yarn spinners, and tanneries.

In 2025 LK Bennett will complete a re-assessment program for renewal of the Butterfly Mark accreditation working closely with the team at Positive Luxury, identifying gaps and actionable steps for improvement against Ethical, Social, Governance (ESG+) goals, providing a detailed report with insights into the workforce’s current position.

With continued support from our CEO and Leadership team, we work to strengthen our systematic management of policies and working practices, raising awareness of Modern Slavery risk and the role our business takes in prevention, 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 continues to be complex and acknowledge 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 [email protected].