Human Rights Policy
Reviewed: March 2024

CONTENTS
OUR COMMITMENT

03

DEFINITIONS03

SCOPE AND STANDARDS OF REPORTING

04

HOW DOES BURBERRY IMPACT HUMAN RIGHTS?

05

HUMAN RIGHTS STANDARDS

05ACHIEVING OUR COMMITMENT TO HUMAN RIGHTS

07

RESPONSIBILITIES AND REVIEW

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2

OUR COMMITMENT
We are committed to respecting and safeguarding the human rights of those
who are directly or indirectly impacted by Burberry. Our people are our greatest
asset, and we therefore strive to attract talent, provide continuous development
opportunities, recognise performance, ensure a safe working environment andpromote employee health and wellbeing. We also ensure we make meaningful
and lasting improvements to employment practices and workplace conditions
across our supply chain, while minimising our environmental impact. Finally,
we place the highest importance on customer safety, welfare and respect, fromtheir enjoyment of Burberry products or interactions with the company in ourstores or otherwise.

This Human Rights Policy (the “Policy”) details the procedures we put in place
to protect and uphold human rights wherever we operate. This includes thevarious mechanisms we use to identify and address any instances of potential
infringement that may arise in connection with Burberry’s operations andactivities.
We are committed to, and require all Business Associates to commit to,respecting and upholding the human rights principles set out in:• The International Bill of Human Rights (for example in relation to justand favourable conditions of work, the health and safety of workers andtheir right to water and sanitation);• The Universal Declaration of Human Rights;• The International Labour Organisation’s (ILO) Core Conventions;• The ILO’s Declaration on Fundamental Principles and Rights at Work;• The UN Guiding Principles on Business and Human Rights; and• The ILO Conventions on Labour Standards on Working Hours.
We are also a signatory of the UN Global Compact and its 10 responsible
business principles.
We recognise the importance of collaboration in driving long-lasting positivechange. We therefore work with Business Associates, civil society,governments and other businesses to inform our approach, share key insights,
help address root causes of human rights impacts and, together, work toachieve positive systemic change.
DEFINITIONS“Human Rights’’ are defined as all those rights set out in the Universal
Declaration of Human Rights, the International Covenant on Civil and Political
Rights, the International Covenant on Economic, Social and Cultural Rights andthe Core Conventions of the International Labour Organization’s Declaration on
Fundamental Principles and Rights at Work.

‘‘Our people’’ is defined as permanent and temporary employees, contractors,
consultants, agency workers and third-party partners working on site.

HUMAN RIGHTS POLICY / 20243‘‘Supply chain’’ is defined as local and international organisations involved in the
production of Burberry goods at all stages of manufacture, raw material
processing and production.
All references to ‘‘operations’’ include Burberry’s wholly or partially owned
entities.
Any reference to ‘‘communities’’ applies to those individuals and communities
who are either directly or indirectly impacted by their relationship with
Burberry or its extended supply chain.
“Business Associates” refers to any individual, entity, business, company,
partnership or any other body or group associated with Burberry including,
without limitation, any such individual, entity, business, company, partnershipor any other body or group supplying products, goods, raw materials,
components, services, real estate or anything else, directly or indirectly, to any
member of the Burberry Group or otherwise working directly or indirectly withor on behalf of any member of the Burberry Group. This also includes any
person (an “Indirect Supplier”) providing products, goods, raw materials,
components, services or anything else to (i) a direct supplier of Burberry or any
other member of the Burberry Group or (ii) any other Indirect Supplier.
Burberry Associates include, without limitation, the following:• finished goods vendors• raw material and/or component suppliers• people or entities who carry out any processing on any goods directly or
indirectly supplied to Burberry, including sites at which this processing
takes place• non-stock vendors• construction contractors (and their construction sites)• franchisees• licensees• joint-venture partners• consultants• contractors• wholesale customers• service providers, including circular business model service platforms• agents• landlords, and• any subcontractor of the above
All Business Associates must comply with the Responsible Business Principles
and such compliance is a condition of working with Burberry (whether directly
or indirectly).
SCOPE AND STANDARDS OF REPORTING
The Policy covers all our Business Associates. The Policy sets out the humanrights standards that Burberry strives to adhere to, as well as the mechanisms
for remedy.

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4All Business Associates are expected to comply with all applicable laws andhuman rights standards included in this Policy.
The eight fundamental Convention areas are as follows:
1. Freedom of Association and Protection of the Right toOrganise Convention, 1948 (No. 87);
2. Right to Organise and Collective Bargaining Convention, 1949
(No. 98);
3. Forced Labour Convention, 1930 (No. 29);
4. Abolition of Forced Labour Convention, 1957 (No. 105);
5. Minimum Age Convention, 1973 (No. 138);
6. Worst Forms of Child Labour Convention, 1999 (No. 182);
7. Equal Remuneration Convention, 1951 (No. 100);
8. Discrimination (Employment and Occupation) Convention,
1958 (No. 111).
HOW DOES BURBERRY IMPACT HUMAN RIGHTS?
To identify the principal human rights risks that might arise during our businessactivities, we have conducted a review of our operations and activities (direct
and indirect) and the impacts they may have on human rights. This is known asa Human Rights Impact Assessment. As part of this assessment, we haveidentified the human rights of four key stakeholder groups to be where
Burberry’s principal duties lie:
• Our People• Supply chain workers• Communities where we operate• Our customers

Through the implementation of policies and tools, such as our Ethical Trading
Programme in our global supply chain, we are aware that human rights risks
may be disproportionately found within groups of vulnerable workforces. We
therefore developed tailored policies to address the rights and needs of our
supply chain workers, including migrant and homebased workers. In addition,in terms of our people, we have diversity and inclusion, and global parental
leave policies in place across our operations.
More information can be found in Burberry’s Ethical Trading Code of Conductand our Migrant Worker Policy.
HUMAN RIGHTS STANDARDS
1. Core Standards
1.1 Burberry and its operations will take all necessary steps to respect the humanrights of its stakeholder groups, including its people, supply chain workers,
communities where Burberry operates and Burberry customers, by establishingand embedding relevant policies and tools.

1.2 Burberry will take the necessary steps to respect human rights through theeffective and consistent implementation of the Burberry policies and tools.
1.3 Burberry will put in place grievance mechanisms that are legitimate,accessible, predictable, equitable, transparent, rights-compatible, a source of

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continued learning, and based on engagement and dialogue, in order that humanrights violations can be identified, addressed and remedied wherever they may
occur.
1.4 All grievance mechanisms will be tested against the above standard.
1.5 Burberry will educate its people on human rights and support them in theircompliance with this Policy.
1.6 Burberry will engage, where relevant, in multi-stakeholder dialogue on theissue of human rights. Burberry is committed to engaging with potential oraffected stakeholders and their representatives through its Human Rights
Impact Assessments and Ethical Trading Programme.
2. Monitoring, reporting and assessment
2.1 Burberry will conduct a Human Rights Impact Assessment every two years
of its operations and activities and those of its extended supply chain including
raw material suppliers, to ensure its approach remains relevant, effective andcaptures any emerging risks in relation to new operations and projects. As partof this process, Burberry will develop and implement action plans to address
our most salient human rights impacts.

If a forced labour risk is identified within our supply chain, ethical tradingassessments are conducted by our internal teams or by a local NGO, where local
expertise is needed, to identify any labour rights issues and remediation
required.
2.2 We recognise that systemic labour rights issues exist within global fashion
supply chains, which is why we have developed a robust monitoring system of
our supply chain Our monitoring commitments are outlined below.
Burberry will monitor human rights impacts on an ongoing basis, e.g. throughthe implementation of Burberry’s Ethical Trading Code of Conduct through thecompany’s Ethical Trading Programme. This consists of risk assessments which
cover all finished goods manufacturing facilities, their subcontractors and key
raw material suppliers. If any concerns are raised during our risk assessments,
audits and other monitoring activities will be carried out. These audits,announced or unannounced, consist of worker interviews, document reviews
and site tours, and are repeated periodically to confirm ongoing compliance andcontinuous improvement. The frequency of audits depends on the level of
performance in previous audits – better performing factories are audited lessfrequently. Worker interviews are always conducted confidentially and workers
are selected at random with fair representation of the workforce, including, forexample, union and worker representatives, first aiders and migrant workers.
Our audit methodology prescribes that we interview at least 10% of the workers
in each factory. Between audits, the Burberry Responsibility team works closelywith facilities to implement systems to prevent human rights risks and ensurethat any non-compliance is managed effectively. Our Partner Non-Compliance
Policy is designed to give a Business Associate a reasonable amount of time torectify the critical issues to minimise any potential and/ or detrimental impact
on workers’ livelihoods.

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2.3 Burberry will review the findings of the Ethical Trading Programme andHuman Rights Impact Assessments to evaluate the effectiveness of this Policy
and to update the Policy and the tools and processes referred to herein as
required.
Key areas of risk will be reported to the Burberry Ethics Committee as theyarise. If there are any changes in risk levels or new and emerging risks
identified, these will be reported to the Burberry Audit Committee on a half
yearly basis.
ACHIEVING OUR COMMITMENT TO HUMAN RIGHTS
Through Human Rights Impact Assessments conducted with the support of a
specialist human rights consultancy, we have found that to uphold human rights
we need, firstly, robust operating policies and tools, secondly, a mechanism toensure consistent implementation and adherence, and thirdly, appropriate
grievance mechanisms to remedy human rights infringements and prevent any
further incidents. Together, these mechanisms represent the system we havein place to uphold human rights across our operations.
1. Policies and Tools
We have the following operational policies, tools and programmes in place toprotect the human rights of the four stakeholder groups identified on page 3:
To protect
our people

To protect workers
in the value chain

To protect
our communities

To protect
our customers

Code of
Ethical Business
Principles

Ethical Trading
Programme andEthical Trading
Code of Conduct

Local Stakeholder
Engagement Policy

Customer Welfare
Incident Policy

Code of Conduct

Migrant Worker
PolicyCommunity Investment
Programme

Burberry Customer
Experience training for
Burberry employees

Global Diversity andInclusion Policy

Partner
Non-Compliance Policy

Global Environmental
PolicyProduct safety policies
and appropriate productlabelling

Global and Local Human
Resources Policies

Homeworker Policy

Traceability systems

Global Health and Safety
PolicyGlobal Health and Safety
PolicyChild Labour and Young
Worker Policy

Equal Opportunities
and Anti-harassment
Policy for store staff

1Resolution Hub,
including Burberry
Confidential

Model Wellbeing Policy

Grievance processes

Anti-Bribery andAnti-Corruption Policy

Confidential, NGO run
worker hotlines2

Customer Services

Infection Control
Management Policy

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2. Implementation and Adherence
The implementation of these policies and tools is supported by specific training
modules as well as effective disciplinary procedures.
Our People
The human rights of our people are protected through the activities of our global
and regional Human Resources and Health & Safety teams. These teams are
responsible for the implementation, review and governance of those policies
outlined above, and support leaders in ensuring that the policies are followedby their teams.

Policies are kept centrally and can be accessed at any time on Burberry’s
intranet. Key departments and individuals will be supported in their roles bymembers of the Responsibility team to ensure compliance with the Policy.
Supply chain workers and communities
To uphold human rights across our supply chain, we require our network ofBusiness Associates and extended supply chain partners to comply with our
Principles.

The development of the Principles has been informed by our longstanding
membership of the United Nations Global Compact. The Principles areunderpinned by the United Nations Universal Declaration of Human Rights andthe Fundamental Conventions of the Internal Labour Organization, and arealigned with the Ethical Trading Initiative Base Code.
To promote human rights across our direct and indirect operations, we require
our network of Business Associates and extended supply chain to comply with
Burberry’s Ethical Trading Code of Conduct as part of the Principles, which
includes, amongst others, a requirement to provide safe working conditions, notto discriminate workers on any grounds, the right to freedom of association andthe right to regular employment.
The Burberry Responsibility team, in partnership with commercial teams, areresponsible for monitoring compliance with the Burberry Ethical Trading Codeof Conduct through the Ethical Trading Programme, which is in place to ensurethat the human rights of people working in our supply chain are respected. We
recognise this responsibility globally and especially in locations where humanrights, labour and environmental standards are absent, weak, or poorly
enforced. We also acknowledge and respect different national cultures, with
their own laws, norms and traditions.
Our Ethical Trading Code of Conduct applies throughout the supply chain, fromfinished goods vendors to raw material suppliers and we continue to map our
supply chains and increase traceability to address, amongst other things, humanrights risks further upstream in the supply chain.

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Customers
Customers interact with several Burberry departments, both directly andindirectly. Burberry staff are trained to protect customer safety and welfare ina professional manner. Teams responsible for product safety follow strict
company policies.
3. Grievance Mechanisms
Grievance mechanisms should be legitimate, accessible, predictable, equitable,transparent, rights-compatible, a source of continue learning, and based on
engagement and dialogue.

Grievance mechanisms are used to inform and implement future policy, toensure developments are relevant and appropriate and to ensure that humanrights violations are not replicated nor deteriorate. We prohibit retaliation
against anyone raising a complaint and will respect the rights of any otherstakeholders raising human rights related concerns including human rights
defenders. We also expect all our Business Associates to respect the rights ofhuman rights defenders.
Our People
Our people are entitled to seek remedy in the case of any perceived
infringements of their human rights.

We have a Resolution Hub which sets out the different ways in which ourpeople can raise concerns, both informally and formally.
The Resolution Hub includes details of a confidential helpline “Burberry
Confidential” which is available to all our people. This is communicated to ouremployees on commencing employment with Burberry, as part of their
onboarding programme and details of the number to call are available on all
employee identity cards as well as on our intranet site.
Any concerns raised through Burberry Confidential are logged with outcomes
formally recorded and reviewed regularly by our Ethics Committee to identify
any trends or areas of concern.
The effectiveness of the hotlines is continuously reviewed with internal andexternal stakeholders.
Our people are entitled to the right and freedom of union membership and theright to collective bargaining.
Supply chain
Through our Ethical Trading Programme, we uphold the right of workers in our
supply chain to freely join a trade union. We also require factories to provide agrievance mechanism that is communicated to, understood by and applied fairly
to their employees. This is verified as part of our Ethical Trading Programme,with audits conducted at finished goods manufacturers, subcontractors,
supporting facilities and key raw material suppliers on a regular basis.

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In countries where grievance systems, such as independent trade unions orcollective bargaining, are not permitted or supported, or in the case where
vulnerable workers may not have access to effective systems of recourse, wesponsor a free, NGO-run, confidential hotline.
Any grievances made through Burberry sponsored systems are logged andprocessed, with outcomes formally recorded. Through our Ethical Trading Codeof Conduct we work with our suppliers to support them in ensuring theirgrievance mechanisms are legitimate, accessible, predictable, equitable,transparent, rights-compatible, a source of continued learning, and based on
engagement and dialogue. The effectiveness of the hotlines is reviewed withinternal and external stakeholders, including workers. We expect our suppliers
and Business Associates to prohibit any retaliation against workers and otherstakeholders for raising human rights related concerns.
Communities
We are committed to respecting the human rights of the people in the local
communities in which we operate, such as those surrounding our stores, offices
and distribution centres. Our Local Stakeholder Engagement Policy sets out theprocedure to be followed when a local stakeholder reports an issue or risk thathas arisen associated with Burberry operations or activities.

Our Local Stakeholder Engagement Policy can be found here.
Customers
Customers can report any issue regarding product or customer experience to
our global, 24-hour customer service team.

Any grievances made are logged and processed, with outcomes formallyrecorded.
HOW THIS WORKS IN PRACTICE
Example of Grievance Mechanisms in relation to Discrimination
The table below gives an example of the policies and processes in place for
dealing with cases of discrimination.

Potential
human rights
violation

Applicablepolicies andtools

Our People

Supply chain

Communities

Customers

A Burberry
employeefeels they are
being
discriminatedagainstWorkers in the
supplychain feel
discriminatedagainstA local stakeholder
feels they arebeing discriminatedagainstA customer
faces
discrimination in
store by retail
staff

Local Stakeholder
Engagement Policy

Customer
Welfare Incident
PolicyDisciplinary
PolicyCode of
Conduct
Diversity andInclusion Policy
Resolution Hub:
including the
Global Steps to
Resolution

HUMAN RIGHTS POLICY / 2024

Ethical Trading
Code of Conduct(nodiscrimination
standard)
Partner NonCompliance
Policy, applied aslast resort to non-10

Framework andBurberry
Confidential
Disciplinary
policies or local
employeehandbooks,
whereapplicable

Implementation

Grievancemechanism

All workers are
made aware of
the above
policies andtools and they
are madeavailable via
Burberry’s
online intranet
Resolution Hub,
including theSteps toResolution
Framework andBurberry
Confidential

complyingfactories
Migrant Worker
PolicyAll factories
Burberry follows its
commit to
Local Stakeholder
compliance to the Engagement Policy andEthical Trading
separate Procedure
Code of Conduct, document and logs themonitored
issue on its internal
through Ethicaltracking andTrading
monitoring system
Programme
Internal factory
grievancesystems
Ethical Trading
Programme(interview during
audits)Non-profit
Confidential
worker hotline

Corporate
Responsibility email
contact availableonwww.burberryplc.com
Customer Services

Regular training
tostore staff(including
sales associates
and security
teams) of
policies andprocesses

Customer
Services

4. Remedy
We are committed to remedying any adverse impacts on individuals, workers
and communities that we have caused or contributed to and recognise thisshould not obstruct access to any other remedies. Additionally, we arecommitted to working with our Business Associates to remedy adverse impacts
which are directly linked to our operations, products or services and throughcollaborating with third-party NGOs or civil society to remediate any issues. The
affected stakeholders of any human rights concern will remain our foremost
priority.
RESPONSIBILITIES AND REVIEWOverall approval and responsibility for this Policy resides with Burberry’s Chief
Executive Officer, who is an Executive Director on the Board of Burberry Groupplc.

The implementation of human and labour rights is overseen by the Chair of the
Ethics Committee, who has operational responsibility for human and labour
rights and reports into the CEO and the board.
Our General Counsel and Global Human Resources team are responsible for
ensuring our Human Rights Policy is upheld in our direct operations. Our Chief
Supply Chain and Industrial Officer and VP of Corporate Responsibility are
responsible for overseeing human rights and upholding human rights policies inour supply chain.

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We seek the advice of the Ethics Committee on a quarterly basis. Burberry’s
Ethics Committee oversees human rights risks and due diligence and reports to
the Audit Committee twice a year.
This Policy sets out our commitment to respect and safeguard the human rightsof our extended global community including our people, people in our supply
chain, our communities and customers. It also sets out the procedures we havein place to protect and uphold human rights. However, we remain vigilant,
informed and regularly review new forms of best practice to be included in thisPolicy.

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