CODE OF CONDUCT

Harvey Nichols is committed to ensuring the protection and promotion of employee’s health, safety and basic human rights in the workplace.

In particular, we oppose the use and exploitation of slavery, servitude, any type of forced or compulsory labour as well as child labour and working hours that do not comply with local and national laws and trafficking for the purposes of exploitation (“forced labour”).

We expect our Associates and all those who work for us or on our behalf to share our zero-tolerance approach, regardless of their country of operation.

To promote human rights across our business and our supply chain, we require the following from our Associates:

• Associates must not use forced labour.
• Associates must have in place controls to mitigate against the risk of forced labour.
• Each Associate must strive to comply with all relevant local and national law and regulations, whilst upholding best practice principles in the following:
  • HR management systems and processes
  • Labour standards and human rights

• • No discrimination and equal opportunities
  • Decent working conditions
  • Health and safety
  • Terms of employment
  • Working hours and wages

If requested by us, Associates will complete a self-assessment questionnaire provided by us 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. Associates will provide us with a copy of the completed questionnaire.

If requested by us, Associates will allow us to audit compliance with this Code by inspecting their facilities, reviewing records, policies and practices and interviewing personnel. Associates are expected to provide prompt access to their facilities, records, documentation and personnel.

If we identify any non-compliance, Associates must prepare, permit us to review and execute an improvement plan approved by us to rectify matters.

Associates will place similar expectations to those set out above on their own Associates.

We define bribery to be the offering or requesting of a financial or other type of advantage with the intention of inducing or rewarding improper performance of a function or activity. This is with the knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity.

Our principles in respect of Bribery are as follows:

• We will carry out our business fairly, honestly and openly
• We will not make nor accept bribes, nor will we condone the offering or the acceptance of bribes on our behalf, so as to gain a business advantage
• We will continue to review all gifts and hospitality received and given to ensure that it does not jeopardise our principles
• We will keep to these principles even when it becomes difficult
• We will avoid doing business with others who do not accept our values and who may harm our reputation

Accordingly, we require that our Associates do not in any circumstances (directly or indirectly):

• Offer, promise or give a financial or other advantage, which would lead to an improper performance of a relevant function or activity. This being either for the benefit of the Associate, or for the benefit of Harvey Nichols
• Request, agree to receive or accept a financial or other advantage that might be considered to create an unreasonable obligation for our Associates
• Bribe another person intending to obtain or retain business or other advantage for Harvey Nichols
• Make or receive facilitation payments which might be considered unusual in order to speed up processes, which are ordinarily provided

As part of our on-going review of our corporate governance and social responsibly, Harvey Nichols has joined the Sustainable Luxury Working Group and adopted the Animal Sourcing Principles. Harvey Nichols is committed to sustainable and responsible practice across all areas of its business, and ethical sourcing is an important part of this programme. The Animal Sourcing Principles, set out the minimum requirements that a supplier must adhere to in order to trade with Harvey Nichols. We expect 100% compliance to these standards from our suppliers.

We believe that these principles should apply throughout the animal sourcing supply chain, including the catching, maintaining, breeding, raising, transportation, handling and slaughter of live animals.

• We are committed to ethical practices in the catching, maintaining, breeding, raising, transportation, handling, and slaughter of animals in our leather, fur and exotic skins supply chains. We believe that all such animals, while taking into account their species’ needs, should benefit from:
  • Freedom from hunger and thirst, by ready access to fresh water and a diet for full health and vigour
  • Freedom from discomfort, by providing an appropriate environment including shelter and a comfortable resting area
  • Freedom from pain, injury or disease, by prevention or rapid diagnosis and treatment
  • Freedom to express normal behaviour, by providing sufficient space, proper facilities and company of the animal’s own kind
  • Freedom from fear and distress, by providing conditions and treatment that avoid mental suffering
• We are committed to sustaining well-functioning and bio-diverse ecosystems in the regions where we source. This includes maintaining species populations of wild animals at sustainable levels as well as to source only material of animal origin that stem from legal sources. We believe that local authorities’ use of robust scientific assessment methodologies that ensure sustainable population levels, such as the non-detriment finding methodology promoted by the CITES agreement or the IUCN Red List Categories and Criteria assessment, is critical to achieve this objective.

• We believe that the capture, maintaining, breeding, raising, transportation, handling and slaughter of animals must be undertaken with minimal environmental impacts, and in compliance with applicable local animal welfare, social, and environmental laws and regulations as well as internationally accepted human and labour rights standards. In addition, internationally accepted standards for animal welfare such as the standards developed by the World Organization for Animal Health should be followed. Catching, maintaining, breeding, raising, transportation, handling, and slaughter of animals
• We believe that during the maintaining breeding, raising, and handling of animals, animals should have freedom of movement, be housed in clean and secure conditions, and provided with food, water and care as well as have appropriate lighting, temperature, humidity, air circulation, ventilation and other environmental conditions. Further, animals should not be given food or liquid in a manner which may cause unnecessary suffering or injury, and they should be treated in a manner respectful of its species’ nature and their physiological and ethological needs in accordance with established experience and scientific knowledge.
• We believe that animals should not be transported in a way that is likely to cause injury or undue suffering to them, including that all necessary arrangements have been made in advance to minimize the length of the journey and to meet animals’ needs during the journey in line with internationally accepted standards for transportation of animals in air, at sea and on land.
• We believe that animals should not experience suffering, pain or excitement during all stages of the process of slaughter, and that, as appropriate, effective stunning should be used in advance of slaughter.
• As a means to uphold these principles, we will work with our Associates to achieve these outcomes and encourage them to uphold these principles in their supply chains.
• We will commit to implementing appropriate guidelines, procedures, and resources to uphold these principles.
• We recognize that the ability to uphold these principles throughout our brands supply chains as well as across different types of species will vary, however we aim for continuous improvement towards realizing these principles. We will seek to source from countries that have well established and enforced legislation covering animal welfare, trade and biodiversity conservation.

Harvey Nichols is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas.

Harvey Nichols has a zero tolerance policy for the facilitation of tax evasion by its employees or persons acting for and on behalf of the Company.

The Management Board are committed to implementing and maintaining effective measures to prevent, monitor and eliminate tax evasion.

Accordingly, we require that our Associates do not in any circumstances and in any country (directly or indirectly) facilitate tax evasion whilst performing services for and on behalf of Harvey Nichols.