Group Slavery &Human Trafficking
Statement
2023
MODERN SLAVERY ACTTRANSPARENCY STATEMENT
This statement is made pursuant to Section 54 of the Modern Slavery Act
2015. It constitutes Triumph Group’s slavery and human trafficking statement
for the financial year 20221

Modern slavery is a crime and a violation of fundamental human rights. It takes
various forms, such as slavery, servitude, forced and compulsory labour and humantrafficking. We understand that modern slavery is a global issue that may affect ourorganization and our supply chains alike.

TRIUMPH GROUPpossesses subsidiaries around the world covering significant activities of its value chain fromdesign to sales. Such a long period of success is only possible with a keen sense for fashionand excellent insights into the desires and needs of our consumers as well as with caring andengaging approach to its employees and stakeholders.
For over a century, Triumph continuously strived to recruit new talent, offering them one of
the textile industry’s most international working environment, excellent conditions and great
development opportunities in an ever-evolving company.

WE MANUFACTURE IN
SOCIALLY COMPLIANT

SINCE 2012, OUR
ORGANIZATION

and high tech production facilities, anumber of them owned and operated
directly by us, using environmentallyfriendly and energy-saving production
methods and the most modern and skinfriendly material.

has been and currently is a participant of
the Business Social Compliance Initiative(now called amfori BSCI), which supports
companies to drive social complianceand improvements within the factories intheir global supply chains.

We endorse the Triumph Code of Conduct and, as an amfori BSCI Participant, we endorse
the amfori BSCI Code of Conduct and its terms of implementation and cascade themthrough our supply chain. Therefore, Triumph Group does not tolerate any form of slavery,
servitude, forced, compulsory labour and human trafficking and commits strongly to theearly detection, monitoring and remediation of such issues in its supply chain. TriumphGroup remains open to constructive engagement with stakeholders who can help to combat
this phenomenon.

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ORGANIZATIONALSTRUCTURE
INTERNATIONAL
Triumph Group, one of the world´s leading intimate apparel companies, has beenfounded in Germany in 1886. Today, it is headquartered in Bad Zurzach (Switzerland)and continues to be a fully privately owned company. Triumph today enjoys apresence in over 120 countries all across the world. For its brands Triumph and sloggi
the company develops, produces and sells underwear, lingerie, sleepwear andswimwear. Globally, the company serves 40,000 wholesale customers and sells its
products in 4,050 controlled points of sale as well as via several own online shops.

UKTriumph Group runs a sales and marketing operation including supporting functions
to serve valued customers in the United Kingdom and Republic of Ireland. Thecompany operates across different sales channels including wholesale, distant retail,and e-commerce, which includes our own UK Triumph and Sloggi web sites.

SUPPLY CHAIN STRUCTURE
Many of our products are manufactured in Triumph own manufacturing facilities andthe rest is being produced by trusted and reliable partners with whom we havetypically collaborated for several years. Our third party finished goods suppliers arecontinuously evaluated on various criteria including compliance. We expect oursuppliers to comply with legal requirements as well as environment, social standards
and our Code of Conduct.

3INTERNAL POLICIES, PROCEDURES A
ND CONTRACTUAL CONTROLS
Triumph Group is committed to conduct our business in a legal, responsible andsustainable manner that is ethically sound and concerned with the welfare of ourpeople, communities, our stakeholder and the natural environment. Our Policy
Framework sets the context within which we wish to sustain our successful business.
It contains the principles and rules of corporate conduct to guide behaviour bothwithin and outside of our company.
As an amfori BSCI Participant, Triumph has developed the necessary management
systems, policies and procedures to effectively prevent and address any adverse
human rights’ impact that may be detected in its supply chains.

SOCIAL COMPLIANCE POLICYOur Social Compliance Policy was rolled out in April 2012 in order to increase
visibility, transparency and risk manageability for finished goods suppliers byproviding a single and structured approach to identify, evaluate and approve thesuppliers complying with our policy.
We have implemented governance and compliance standards to uphold ourcommitment accordingly. Simultaneously, Triumph joined amfori BSCI in 2012 inorder to drive sustainable improvement of labour and workplace conditions byadhering to both our own Code of Conduct as well as amfori BSCI’s Code of Conduct,
which includes prevention of servitude, forced, bonded, indentured, trafficked or
non-voluntary labour.

BUSINESS ETHICS GUIDELINES
Our values, principles and codes of conduct ensure that expectations around ethicalbehaviours are clear, monitored and that specific corrective actions areimplemented in case of any violations.

For more detailed information please visit:
GLOBAL_Triumph_International_Business_Ethics_Guidelines.pdf

4DUE DILIGENCE AND
REMEDIATION IN OUR OWN
BUSINESS AND SUPPLY CHAINSAs an amfori BSCI Participant, Triumph commits to act diligently in(a) assessing actualand potential adverse
impacts
ofourbusiness against thevalues and principlesof the amfori BSCI
Code of Conduct;(b)identifying
throughout the supply
chain where the mostsignificant risks forthese adverse impacts
may occur and(c) acting upon themwith the aim ofpreventingand/oraddressing them in linewith the BSCI Code ofConduct.

In this context, we have undertaken the following due diligence steps:

MAPPING AND MONITORING OUR SUPPLY CHAINS
We have gathered and assessed reliable information about our business partners’
responsible behaviour, among others by using regular social compliance audits. In
2022, all 99 finished garment factories supporting Triumph business across 18
countries were monitored for social compliance.
87 factories located in ‘High Risk’ countries were selected and audits were organized,out of which 68 were audited under BSCI audit protocol and 19 factories wereaudited based on other audit schemes like WRAP, Better Works, SMETA and ICSetc.
Remarks:
Factories that are exempted from audits are located in low risk countries as per‘amfori’s Risk Country Classification’.
5GRIEVANCE MECHANISM AND
WORKER’S INVOLVEMENT
Our organisation has put effective grievance and whistle blowing mechanisms inplace as per amfori BSCI Code of Conduct for individuals and communities who may
be adversely impacted by our organization’s activity, including potential or factualforced labour.
We have set up an integrity hotline (integrity@triumph.com), which is anindependent and confidential channel for receiving information relating to improper
business conduct and open to both Triumph employees as well as third parties.
In addition, being an amfori BSCI Participant, any third party can lodge a grievanceabout our BSCI implementation activities through the amfori BSCI Grievance
Mechanism [system@amfori.org].

INCIDENTS OF FORCED LABOUR AND REMEDIATION
Through BSCI audits and other social compliance audit schemes, we have not
identified any case of unacceptable performance under the heading of bonded labour.
This concludes that our business partners have better management systems as below:(a) assessing actualand potential adverse
impactsofourbusiness against thevalues and principlesof the amfori BSCI
Code of Conduct;(b)identifying
throughout the supply
chain where the mostsignificant risks fortheseadverse
impacts may occur
and(c) acting upon themwith the aim ofpreventing
and/oraddressing them inline with the BSCI
Code of Conduct.

STAKEHOLDER ENGAGEMENT AND
INDUSTRY COLLABORATION
Being an amfori BSCI Participant, we are part of an industry-wide network that weuse to work collaboratively and exchange lessons learned and solutions on a precompetitive basis

6ASSESSMENT OF
MODERN SLAVERY RISK WITHINOUR BUSINESS AND SUPPLY CHAIN
To understand where we have the biggest risks, Triumph Group has undertaken thefollowing risk assessment steps both in our own organization and in our supply chains:With the help of the tool from amfori BSCI, we have identified the severity of the risk
in different countries for sourcing. For countries with high risk like China, India,Vietnam and Cambodia etc, apart from arranging the social compliance audit
regularly (in general at least once a year), with due diligence and if the situation
allows, our social compliance team would also arrange regular on site visits for an
on-site evaluation to better understand the social compliance status of the factory
which includes the evaluation on the human resource policies and recruitment
practice etc.
Country Risk Classification:
http://duediligence.amfori.org/countryRiskClassification

ASSESSMENT OFOUR EFFECTIVENESS IN
PREVENTING AND COMBATTING MODERN SLAVERY
We understand that forced labour, human trafficking and slavery risks are not static,
therefore we regularly track, measure and evaluate our internal due diligenceprocesses to better understand our performance, progress, effectiveness, remaining
risks and impact of our own operations and those of our business partners.
Triumph defines overall goals and targets to assess our progress in achieving them.
With regards to combatting Modern Slavery, we recognize the following key targets
to be monitored:

OUR OWN STAFF

increased awareness of forced
labour and human rights risks,

OUR SUPPLY CHAINS’ BUSINESS

partners show continuous improvement,
particularly with regard to the areas inrelation to recruiting practices.

Assessing the effectiveness of our measures on a regular basis helps Triumph
maintain efforts that have proven to be successful and allows the exploration of
innovative solutions when needed.
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TRAINING AND
FURTHER STEPSAt Triumph, our employees are introduced to our Codes of Conduct,
trained on our values and principles and asked to familiarize themselveswith our corporate policies.
In addition, every finished goods supplier is introduced to our Code ofConduct. Factories, which are audited, are further expected to cascade
amfori BSCI’s Code of Conduct down their supply chain to further drive
awareness beyond the first tier. We also encourage our factories topartake in one of the many amfori BSCI workshops to further reinforce
amfori BSCI’s Code of Conduct.
Training sessions on Social Compliance and Modern Slavery have also
been provided this year by our global sourcing team within the Group.
Going forward, we are planning to instil the concept of human rights andmodern slavery more specifically into our business partners down thesupply chain.

This statement has been approved by the Global Head ofSupply Chain on 2023.05.11 and constitutes Triumph Group'scommitments to avoid slavery and human trafficking for thefinancial year ending 2022.

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