MODERN SLAVERY STATEMENT

FOR FINANCIAL YEAR ENDING 2 APRIL 2016

We have prepared this statement for the purposes of the Modern Slavery Act 2015. References in the statement to “forced labour” means any conduct which is an offence under Part I of the Act including slavery, servitude, child labour and any type of forced or compulsory labour and traf cking for the purposes of exploitation.

OUR PRINCIPLES

According to the International Labour Organisation, there are some 21 million people worldwide subjected to forced labour. We do not tolerate forced labour either within our business itself or within our supply chain. We expect our supply chain (whether direct suppliers or those that directly or indirectly supply our direct suppliers) to share the same values.

OUR BUSINESS

Harvey Nichols is a premier luxury fashion retailer, selling fashion, accessories, beauty, food and wine products across its 8 stores and online within the UK and Ireland. All UK stores have luxury Foodmarkets and Restaurants, Cafés or Brasseries. Harvey Nichols also owns and operates OXO Tower Restaurant, Bar and Brasserie on the South Bank in London.

Our product supply chains are extensive and global, numbering thousands of direct suppliers, agencies and concessions (“Associates”). Our Associates operate and manufacture globally.

MANAGING RISK

We have taken the following steps to assess, mitigate and manage any risk that our supply chain may use forced labour:

1. Code of Conduct

We have issued a Code of Conduct to all members of our supply chain.

This Code of Conduct rejects the use of forced labour. We expect our Associates to comply with the Code of Conduct and to place similar expectations on their respective supply chain. Please refer to the Corporate Responsibility section on www.harveynichols.com for the Code of Conduct issued to our Associates.

The Code of Conduct sets out our right to audit compliance by inspecting Associates’ facilities, reviewing records, policies and practices and interviewing personnel. We reserve the right to request our Associates to complete a questionnaire regarding the use of forced labour and the steps they have taken to ensure that neither they nor their supply chain make use of it. This will facilitate our due diligence process and allow us to identify red ags.

On focusing on responsible and ethical sourcing, the Code of Conduct also incorporates our animal sourcing principles, environmental responsibility and Bribery Policy.

If we identify or suspect non-compliance with the Code of Conduct we will work with our Associates to execute an improvement plan to rectify matters. Failure to address non-compliance in an appropriate manner will lead us to cease trading with the Associate.

2. Contractual commitment

We have amended our standard supplier contractual terms to include obligations on our Associates to: comply with our Code of Conduct: warrant that their business and, to the best of their knowledge, their own supply chain do not use forced labour; implement appropriate controls to prevent forced labour and to notify Harvey Nichols immediately if they become aware of forced labour within their supply chains.

3. Best practice measures

n working with our Associates, we employ best practice measures. This prevents putting undue pressures on our Associates which could increase the risk of forced labour. Such measures include: paying market prices; not withholding undisputed payments; and avoiding applying unnecessary pressure for the early delivery of products.

4. Policies

Harvey Nichols’ internal policies cover recruitment, basic pay and the use of contractors. These support our commitment to zero tolerance of the use of forced labour within any part of our business.

We also operate a Whistleblowing Policy, aimed principally at our employees but also available to others working in our supply chains which encourages individuals working with us to report any suspected wrongdoing, including human rights violations such as forced labour.

5. Internal Training

To raise the awareness of our zero policy stance on forced labour, we have issued an internal memorandum on modern slavery to all members of staff, and included as part of our induction programme to new starters.

LOOKING FORWARD

Our commitment to prohibiting the use of forced labour is an ongoing process.
The steps taken so far form part of a long term programme to tackle the issue of forced labour.
Future plans include: training and additional due diligence steps.

Approved by the Board of Directors on 27th September 2016 and signed on its behalf by:

STACEY CARTWRIGHT
Chief Executive Officer

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