Richemont UK Limited
Modern Slavery Statement
Financial Year 2022/2023

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (MSA). It sets out thesteps Richemont UK Limited (Company) has taken during the 2022/2023 financial year to prevent
slavery and human trafficking from taking place in its supply chains or in any part of its business. It also
sets out the additional steps we plan to take going forward.
The Company has published a modern slavery statement each year since 2016. Previous statements
are available on request.

1.

INTRODUCTION
The Company is committed to improving our practices to combat slavery and human trafficking
and to ensure that our business and supply chains are free from the same.

2.

ABOUT THE COMPANY
The Company sells jewellery, watches, leather goods, clothing, writing instruments and otherluxury goods (the Products) for the following Group Maisons: A. Lange & Söhne, Alaia, Baume &Mercier, Buccellati, Chloé, IWC Schaffhausen, Jaeger‑LeCoultre, Montblanc, Panerai, Piaget,
Roger Dubuis, Vacheron Constantin, and Van Cleef & Arpels. The Company markets, distributes
and sells the Products through the Maisons’ retail and e-commerce channels within the UK and
Ireland and acts as an agent for the distribution of watches to an authorised dealer distribution
network in the UK and Ireland.
The Company also provides after-sales care for the Products, offers a repair service for Maison
branded watches and jewellery in the UK.

3.

ORGANISATIONAL STRUCTURE
The Company is part of the Richemont group (the Group) and our ultimate parent company isCompagnie Financière Richemont SA, Chemin de la Chênaie 50, 1293, Bellevue, Switzerland. In
the UK, our immediate parent company is Cartier Limited. The Group owns a number of luxury
brands (Maisons) in the Jewellery, Specialist Watchmakers, Online Distributors and Other(primarily fashion and accessories) sectors. Whilst each Maison within the Group operates as anautonomous business, the Group provides certain centralised support services including in
relation to supply chain compliance, sourcing and procurement. Consequently, the Group works
with the Maisons and the Company to set the required standards and to implement requisite
policies and procedures which each Maison and each legal entity within the Group (i.e. theCompany) is expected to adhere to.
Locations and employees
The Company has a corporate office and a separate after-sales service centre, all of which arelocated in London. We also directly manage thirty seven boutiques within the UK and Ireland,
fifteen of which are presently located within department stores.
We currently have 349 employees.

4.

MANAGEMENT STRUCTURE
The business of each of the Maisons operated by the Company is separately managed by therelevant Maison/Brand Director. The Company itself is managed by an Executive Committee(ExCo) comprising key managers within the business. The ExCo serves to coordinate the activitiesof the individual Maisons, including in respect of their compliance with the Group’s policies andprocedures. There are three statutory directors, including the Company’s Chief Financial Officer.

5.

SUPPLY CHAINS AND PROCUREMENT
Sourcing of raw materials and indirect procurement within many businesses’ supply chains could
be susceptible of human rights impacts such as modern slavery. The Company sources all of its
Products intra-group. This means that we benefit from the various Group policies relating to
suppliers, procurement and sourcing which are in place. Strict rules are applied to theengagement of suppliers, procurement and the sourcing of raw materials by the Group.

Raw materials
The Company purchases Products ‘ready-made’ and because we are not involved in the
manufacture of the Products, we have limited need for raw materials. The only exception to thisis the use of very small quantities of gold, silver and other precious metals which are required toprovide repair services for Maison branded watches and jewellery.
At Group level, the responsible procurement of raw materials such as gold, diamonds, leather,and precious stones is a priority. By way of example, suppliers of gold, diamond-related products
and coloured gemstones are systematically encouraged to becomes certified members of the
Responsible Jewellery Council (RJC). Suppliers out of RJC scope, such as leather related suppliers
are regularly followed up and audited by third parties.
Raw Materials Sourcing Policy
The
Group
operatesaRaw
Materials
Sourcing
Policy(www.richemont.com/media/ilci5h3t/richemont-raw-materials-sourcing-policy-en.pdf)(Sourcing Policy) which describes the human rights impacts that can be associated with theextraction, transportation and trade of precious metals, diamonds and gems. The Sourcing Policy
clearly highlights the Group’s commitment to respecting human rights and complying with all
relevant UN sanctions, resolutions and laws as it states that the Group will neither tolerate nor
profit from any abusive act. This will be reinforced by the Group’s ongoing implementation ofhuman rights due diligence management systems based on the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance for Minerals – 5-Step Framework (5Step Framework): establish management systems, identify and assess risks, risk management,
third-party audit and annual reporting.
Neither the Company nor the Group tolerate any violations of human rights. This stance isconfirmed in the Sourcing Policy, which states that the Group will responsibly disengage with any
upstream supplier if there was a reasonable risk that they were committing human rights abuses
or were sourcing from, or were otherwise linked to, any party committing human rights abuses.
Responsible Sourcing Department
In order to tackle the challenges in terms of human rights, social and environmental sustainability,
the Group relies upon a team of internal experts in responsible sourcing which works across allcomponent supply chains. Whilst Maisons have autonomy in their procurement process, they are
required to apply the Group’s Supplier Code of Conduct policy and Group Procurement Policy(see below). The expert team’s mission is to dive deeply in the knowledge and understanding of
the strategic supply chains in order to:•

identify the risks;•assess impact; and•work closely with internal and external teams to develop prevention, mitigation, remediationand improvement tools.

Supplier Code of Conduct
All suppliers to the Group must comply with the Group’s Supplier Code of Conduct(www.richemont.com/media/ec3hryfn/richemont_scc_eng.pdf) (the Supplier Code). The
Supplier Code sets out the Group’s expectations of suppliers with respect to ethical businesspractices, labour conditions, employment practices, human rights and environment. It is alignedwith the MSA and with the main International Labour Organisation Conventions, the Universal
Declaration of Human Rights, Sustainable Development Goals set by the United Nations, andother internationally recognised labour and practice standards.

Suppliers with whom we contract directly will also be required to adhere to the Supplier Code. In
exceptional circumstances, suppliers may be permitted to adhere to their own internal equivalent
to the Supplier Code, but only where we are satisfied that the supplier’s own internal processes
are at least as robust as our own Supplier Code.
The Supplier Code reflects emerging best practice in the areas of business and human rights,
whistleblowing and grievance mechanisms amongst others. During the year, the Supplier Codewas updated to reflect the developed changes on the Speak-Up tool. The Supplier Code isavailable in 13 languages on the Group's website.
Responsible Jewellery Council
The RJC is the world’s leading standard setting organisation for the jewellery and watch industry.
The Group works closely with the RJC to improve its supply chain and Supplier Code.
The RJC Code of Practices is the global standard for responsible jewellery throughout the entire
supply chain – from mine to retail, covering all the primary minerals and metals used in the
manufacture of jewellery: gold, silver, platinum group metals, diamonds and coloured gemstones– and it focusses on business ethics. RJC became a participant of the UN Global Compact in 2009and since then, the RJC Code of Practices have incorporated its human rights and labour
principles. The RJC Code of Practices robust certification process is independently audited and
ISEAL accredited. The Group promotes the RJC’s code of practices certification to all of its
suppliers of gold, diamond and gemstones.
Certifications and Audits
The Group has implemented several tools, including risk analysis for some common supply chains,
pre-selected auditors, an audit referential and the organisation of audits for common suppliers.
For example, the Group became part of SEDEX Members Ethical Trade Audits (SMETA audits)
standard (an international referential) in 2021, and uses its methodology to check for alignment
with the Supplier Code.
6.

OUR PEOPLE POLICIES AND POLICIES ON SLAVERY AND HUMAN TRAFFICKINGThe Group is continuing to accelerate its efforts related to diversity, equality and inclusion (DEI)
by aligning its approach with the DEI Sustainable Development Goals 2030 set by the United
Nations in 2015. Across the Group we continue to build on our vision of ‘Diversity is Everyone’and live our mission is to ensure that DEI goals are in line with business needs, validate thestrategic DEI roadmap and foster dialogue between leaders and employees. The Group’s efforts
are supported by DEI Champions across our Maisons, regions and markets – and continue tobuild resources and offerings for more open conversations and knowledge around DEI.
The Company’s Board of Directors together with the individual Maison/Brand Directors are
responsible for compliance with the MSA and they are supported by the Group, and the Group
compliance and sustainability teams. Sustainability is firmly embedded at the highest governancelevel of the Group through the Governance and Sustainability Committee, which reports its
actions to the overall Board. Established in March 2021, this committee reviews all management
proposals regarding our sustainability roadmap, including those related to human rights.
As mentioned above, the Group operate various policies which work together to set out theGroup’s commitment to human rights. These include:

i.

Procurement Policy;ii.

Supplier Code of Conduct; andiii.

Raw Material Sourcing Policy.

In addition, the Group also operates a Standards of Business Conduct policy(www.richemont.com/media/ngadkqes/standards_of_business_conduct_eng.pdf) (Standards ofBusiness Conduct).
The Standards of Business Conduct sets out the Group’s commitment to diversity stipulating that
all aspects of the employment relationship should be free from any form of discrimination. The
Standard of Business Conduct also delineates specific standards of ethical behaviour expectedfrom employees. The business and human rights section of the Standards of Business Conduct
further highlights the Group’s commitment to respecting and promoting human rights as
described in the Universal Declaration of Human Rights, the United Nations Guiding Principles on
Business and Human Rights and the OECD Due Diligence Guidance for Responsible BusinessConduct. It also sets out the Group’s whistleblowing and grievance reporting line, the Speak Up
platform, that should be used to raise any concerns about unethical or illegal behaviour. The
Speak Up platform is a comprehensive reporting tool that ensures the Group’s values aremaintained and all reported concerns are taken seriously without any fear of retaliation. A
concern can be reported to the Speak Up platform through the online process or via telephone
and the status of an existing question or concern can be checked on the platform. The Speak Up
platform is accessible on the intranet for employees and will be made available on the Group’s
external facing website and can used by external stakeholders such as suppliers, clients, business
partners and the wider public. The aim is to empower our people to report suspicious activities
and foster an open culture where concerns can be raised. To ensure impartiality the reporting
system is overseen by the Head of Internal Audit, who is independent from management andreports to the Chair of the Audit Committee. The extension of the Speak Up Platform to external
shareholders took place in May 2023 and we are aware that this action is beyond the reporting
timeframe, but we consider relevant to mention it here.
The
Group
also
operatesaCorporate
Responsibility
Policy(www.richemont.com/media/hfzpaqu0/richemont_cr_policy_16052019.pdf) which serves as acommon framework for all business activities across the Group.
The Standards of Business Conduct sets out the rules and policies that apply to the Group, andexplains that its culture is based on the beliefs of honesty, integrity and respect.
Within its Sustainability Report, the Group publishes a Slavery and Human Trafficking Statement
which
contains
further
information
and
can
be
viewedhere:
www.richemont.com/media/hbzglng4/slavery_human_trafficking_statement.pdf
The Group is a founding member of the Transnational Alliance to Combat Illicit Trade (TRACIT). It
lobbies for legislation globally to tackle the sale of counterfeits and builds relationships withgovernments, agencies and commercial entities to fight illicit trade. The Group are also a memberof Unifab, the French anticounterfeiting association that conducts legislative lobbying, provides
training for law enforcement and fosters relationship building. Furthermore, the Groupparticipate in the Swiss Watch Federation and often collaborate in their joint actions on behalf ofmultiple members.
7.

DUE DILIGENCE PROCESSESAs mentioned, because the Company only sources its Products from within the Group, we benefit
from the Group policies which are in place. However, the Standards of Business Conduct
highlights that it is the joint responsibility of everyone within the Group to know, understand andfollow Group requirements. To this end, all employees of the Company are required to review
and acknowledge their understanding and acceptance of the Standards of Business Conduct.
In terms of human rights due diligence, the Group looks into its whole value chain in order to
identify any potential human rights risk, from the sourcing of raw material, to the relation withour clients.
In 2022 the Group conducted a human rights scan to complete our understanding of actual andpotential human rights impact along its value chain. Outcomes presented that activities withhigher exposure to human rights risks include: raw material sourcing, making and manufacturing,storage, as well as transport and distribution. As a result, we are adapting our due diligencemeasures in these areas. For instance, we have launched a specific assessment for our logistic
activities to develop risk mitigation plans.
The Group’s commitment to respecting human rights is reinforced by its actions in becoming amember of the International Labour Organisation Child Labour Platform, which aims to identify
obstacles and seek solutions in supply chains, and its participation in the Human Rights Accelerator
Programme, a United Nations Global Compact programme with the aim of applying instruments
to support its management on human rights.
Risk management process
The Group operates a risk management process that gives consideration to both strategic andoperational risks, including human rights risks. All identified risks are modelled according to theirprobability of occurrence and potential impact and subsequently prioritised by management. A
consolidated risk report, which includes action plans prepared by the Group executive directly
responsible for addressing the risk, is reviewed annually by the audit committee and the Group’s
Board of Directors. This report is confidential.
The Group performs due diligence on business partners to identify, assess and anticipate risks
and opportunities for improvement and to ensure in-depth knowledge of its partners. This
enables the Group to verify that the approach and performance of its partners are aligned with
the Group’s ethics, principles, policies, social and environmental practices and respect for humanrights. Risk mapping is also undertaken at Group level.
A senior team of internal auditors review all Group functions and Group companies in order tomake recommendations for strengthened principles and working practices where required.
Coloured Gemstones Working Group (CGWG)
The CGWG is a joint initiative by various companies including the Group. Its goal is to catalyse
positive change in the gemstones and jewellery industry. The CGWG was formed to better
understand the risks and opportunities for positive impact in the sourcing and production ofcoloured gemstones. The Company’s immediate parent is Cartier Limited and the Cartier Maison
actively contributed, in collaboration with other CGWG members, to the first coloured gemstones
supply chain responsible practices tool set which was made available in April 2021 for the firsttime. The Group actively encourages its suppliers to make use of the tool set where possible.
Kimberley Process Certification Scheme

The Sourcing Policy makes it clear that the Group only sells or purchases diamonds that are fullycompliant with the Kimberley Process Certification Scheme. The Kimberley Process is acommitment to remove conflict diamonds (that is rough diamonds used to finance wars against
legitimate governments) from the global supply chain. The Group’s commitment to the Kimberley
Process demonstrates that it will not tolerate direct or indirect support to non-state armed
groups with consequent human rights abuses/modern slavery implications.
8.

MONITORING COMPLIANCE
The Group has been tracking the progress of Supplier Codes signed by its suppliers since 2015.
Progress is tracked on a category-by-category basis and overall implementation is at 76% ofsuppliers in March 2023. This is an increase from 71% of suppliers in March 2022.

The Group targets to progressively increase the usage of SMETA as its primary audit referential
for suppliers of indirect goods and materials. An example of it are the leather suppliers which
undergo social audits under this methodology. In 2023 there was an increase in the percentage
of suppliers from Tier 1 and 2 being audited as it can be observed in the below table:

9.

TRAINING
All new Company employees are asked to read and acknowledge the Group’s Standards ofBusiness Conduct mentioned in this statement. The Group deploys a range of effective training
resources and in financial year 2022/2023 Group launched a training on Modern Slavery and
Human Trafficking. The training is available to all employees worldwide and it is mandatory foremployees located in the United Kingdom, amongst other countries. Alongside generic training
for all staff, risk mapping helps to direct the content of tailored training programmes and theidentification of specific teams or groups of staff who will receive training on specific risks.
10. LOOKING AHEAD
The Group will continue its work collaboratively with industry organisations and business partners
to promote best practices across its full supply chain and continue to ensure an ethical supply
chain.

In its annual Sustainability Report, the Group states its intention to continue to prioritisetransparency in its supply chains as well as due diligence and risk mitigation measures. The Grouphighlighted by the appointment of the Group’s first Chief Sustainability Officer in 2022 who
jointed the Senior Executive Committee in 2023. The Group is conducting regular materiality
assessments to proactively engage with internal and external stakeholders and continue tomonitor sustainability reporting framework.
Taking this into consideration, looking ahead the Group will strengthen its management systems
and human rights due diligence processes in order to prioritize our focus areas in the field andaccordingly develop strategies that will allow us to prevent, mitigate and in case it is necessary
remediate any potential human rights risk.
The deployment of the Speak-Up platform and of other product social impact assessments will
be valuable tools that will assist the Group in this journey, as it will be the collaboration andengagement with the Group’s main stakeholders.
Consequently, the Group is working on developing different ways of training both its employees
and other relevant stakeholders in order to raise awareness on human rights. Also, a being
member of SEDEX (Supplier Ethical Data Exchange) since 2021 and its ongoing implementation
has meant having additional risk mitigation tools that will assist us in this journey. The SEDEX
membership will help to reinforce ethical supply chain practices through the application of the
SMETA audit standard.
More information about future plans at a Group level can be found in the Sustainability Report,
and in the Group Slavery and Human Trafficking Statement.
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes
the Company’s slavery and human trafficking statement for the financial year ending 2023. It wasapproved by the board on 20 December 2023 and the information contained in this Statement isaccurate as of that date.

………………………………………..
Olivier Percetti
Director, Richemont UK Limited
20 December 2023