Modern Slavery Statement
2022/2023

Introduction

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Introduction

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Modern Slavery Act 2015 and Transparency
in Supply Chains Act 2010
2022/23 Burberry Group PLC Statement
This statement is made pursuant to Section 54 of the Modern
Slavery Act 2015 and California Transparency in Supply Chains Act
of 2010 (SB 657). It sets out the steps we have taken during thefinancial year 2022/23 (the “Year”) to prevent slavery and humantrafficking from taking place in our supply chains or in any part ofour business. Burberry’s definition of slavery and human trafficking
is aligned to section 54 (12) of the Modern Slavery Act 2015.
This statement is also made on behalf of the following subsidiaries
of Burberry Group plc (company number 3458224): Burberry
Limited (company number 162636), Burberry (UK) Limited (company
number 4288292), Burberry International Holdings Limited (company
number 4251867), Burberry (España) Holdings Limited (company
number 5265289), Thomas Burberry Holdings Limited (company
number 3509143), Burberry Haymarket Limited (company number
4868493), Burberry Holdings Limited (company number 4251948)
and Burberry London Limited (company number 4251951) andthe actions and operations set out below are effective across the
Burberry group.

Introduction

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Introduction

We are committed to doing well by doing right, from how we design,source and craft our products to how we support our communities.
Our latest Responsibility strategy, Burberry Beyond, consistsof four pillars – Product, Planet, People and Communities, andbrings together everything we do across our Company, our supply
chain and our communities to create a better world for the next
generation. We have set 12 targets across these priorities to embed
responsible business practices, supported by our ongoing policy
commitments. We recognise transparency is important, so we havein place metrics to measure and report on progress.
To positively impact people within and beyond our value chain,
we collaborate across our business to protect and nurture luxury
craftmanship skills, and drive progress towards our diversity, equity
and inclusion targets. Core to this agenda are; Respecting andupholding human rights, combatting the risk of modern slavery andincreasing transparency throughout our supply chain.
This is our eighth Modern Slavery Statement and provides an
overview of the progress we’ve made over the past year instrengthening our systems to prevent modern slavery in our supply
chain and operations and how we have addressed identified risks.
During this time, we have remained committed to supporting thepeople in our supply chain and our local communities through thecost-of-living crisis, increasing climate related issues as well as
the evolving geopolitical landscape. These are some of the biggest
challenges the world faces today, and we want to ensure that weare playing our part in addressing these, and mitigating associatedHuman Rights implications.
In FY 2022/23, we continued to adapt our due diligence programme
to focus on the key risk areas of our supply chain. In line with ourcommitment to ensure all key materials are 100% traceable, wehave set certification targets for the following key raw materials:

cotton, nylon, polyester, viscose, wool, leather and feather anddown. We have delved further into our raw materials supply chains
to identify new potential modern slavery risks and we have started
to develop a sourcing Country of Origin risk mapping tool that canbe utilised by our product teams to support them when making
sourcing decisions.
We expanded and strengthened our training programme for bothinternal teams and supply chain partners to build more effective
prevention and mitigation actions, specifically working with external
experts such as the International Organisation for Migration (IOM)
to support our supply chain partners in responsible recruitment of
migrant workers.
We have continued to collaborate with cross-industry groups,
such as the Business Against Slavery Forum and the BSR Human
Rights Working Group, to help target modern slavery. We continue
to monitor and assess our response to new emerging risk areas,
including those caused by the current global challenges.
As a responsible business, Burberry is closely monitoring theincreasing trends towards mandatory human rights and ethicaltrading due diligence legislation. We continue to raise awareness andsupport our supply chain partners’ compliance with such standards.

Our Business and Supply Chain

Our Businessand Supply Chain

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Our Businessand Supply Chain
Burberry is a global luxury brand, headquartered in London, UK.
We design, source, make and sell luxury products under the
Burberry brand and we put sustainability and the wellbeing of ourpeople and communities at the heart of our business decisions.
Our identity is intrinsically linked to our British heritage and the
167-year-old legacy of our founder. Thomas Burberry established
our brand as an outerwear pioneer driven by creativity. We buildon this today.

Over 9,000 employees
140 nationalities
Across 34 countries
413 storesOver 40 Responsibility specialists
FY 2022/23 revenues: £3.1 billion

We make our products at Burberry-owned sites in the UK and Italy,
as well as in collaboration with a network of global suppliers.
All our activities are underpinned by a commitment to responsible
craftsmanship.
We sell Burberry products through our directly operated andfranchised stores, as well as via wholesale partners
and online. We use the product and distribution expertiseof licensing partners for certain product categories, suchas eyewear and beauty.
Operating across the world, we contribute to local economies andsupport the communities around us. We add value to societies
both directly and indirectly through our business operations and by
partnering with NGOs on community programmes.

Our Business and Supply Chain

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Our ProductSupply Chain
As a modern luxury brand, we are passionate about driving
positive change. We have clearly defined Principles aligned to
our Responsibility agenda for all external partners to comply
with, in order to ensure the wellbeing of people involved in the
manufacturing of all Burberry’s production processes; protect thebrand from human rights breaches; safeguard against modern
slavery and prioritise the wellbeing of all involved.
We have two Burberry-owned manufacturing sites in the UK and
two in Italy.
We also have a global network of supply chain partners that support
the production of our products. We have visibility of all finishedgoods vendors (including manufacturing sites, their subcontractors
and supporting facilities) and key raw material suppliers (including
raw material mills, tanneries and trim suppliers). There are also
many more indirect suppliers in our extended supply chain and forthis reason, we’ve introduced new targets to ensure all key raw
materials are 100% traceable by FY 2029/30 (back to country levelas a minimum) and for 100% of key raw materials in our products
to be certified. See our Annual Report FY 2022/23 for further details
on our raw material targets.

Supplier production sites – workforce profile FY 2022/23:

Total workforce

Avg workers per facility

56,073workers

88

Gender split

68% Female

Collective bargaining>70%
Supply chain partner production sites FY 2022/23:

32% Maleof the finished goods production
sites we source from are coveredby national and/or industrial
collective bargaining agreements

640 Production Sites

Asia
8%

Rest ofEurope

72%
20%

Italy

We have longstanding partnerships with many of our suppliers,
particularly in Europe, where some of our supplier relationships
extend beyond 15 years. We believe that strong relationships are
key to ensuring continuous improvement in supply chain working
conditions.

Our Business and Supply Chain

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

LICENSEESSERVICES AND GOODS NOT FOR RESALE

We license production of our beauty and eyewear products to Cotyand Luxottica respectively. We work with both licensees to ensure
they apply consistent standards which align with those adhered toacross the rest of Burberry’s supply chain.

We also work with suppliers that support our broader business operations. These include
logistics and waste contractors, and suppliers of goods not for resale such as packaging
and visual merchandising. We require all our supply chain partners to comply with our
Responsible Business Principles, including our Ethical Trading Code of Conduct. These
are incorporated into our contractual agreements with vendors and suppliers (see policies
section). We also carry out ethical trade audits to monitor compliance with our Ethical
Trading Code of Conduct (see due diligence section – page 12).

Coty published a new Human Rights Policy in 2022 and has taken
steps to mitigate risks in its supply chain. Coty is a founding memberof The Responsible Mica Initiative (RMI), a multi-stakeholder actiongroup aiming to establish a 100% responsible Indian mica supply
chain by the end of 2030. Since 2017, Coty has been a member of theRoundtable for Sustainable Palm Oil (RSPO) and is working towards theambition for all their palm oil to be RSPO mass balance-certified. For
further details, see Coty’s Modern Slavery Statement
Luxottica has several policies to address human rights and modern
slavery risks, including its Responsible Sourcing & Manufacturing
Principles (LRSM), Code of Ethics and Conflicting Minerals Policy.
For further details, see Luxottica’s Modern Slavery Statement.

Governance

Governance

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

GovernanceWe continue to implement and promote the management of modern
slavery risks within Burberry and externally.
We have a Responsibility team consisting of over 40 specialists
in key locations globally, with targets relating to our supply chain
owned and monitored by dedicated teams. Burberry employees who
are responsible for supply chain partner relationships and sourcing
have personal KPIs related to labour conditions, recognising thepotential impact of fair purchasing practices on labour conditions
throughout our supply chain.
Our Ethical Trading Programme is supported and monitoredinternally by several management committees. The programmeaims to ensure that the potential risks to labour and human rights
are considered at all appropriate levels and areas of the business.
Policies relating to human rights are reviewed and approved by
the company’s Ethics Committee which is chaired by the GeneralCounsel. If any labour or human rights risks are identified, the Vice
President of Corporate Responsibility will report on such issues tothe Ethics Committee as well as the Group’s Risk Committee.
The Risk Committee, which meets at least three times a year, ischaired by the Chief Financial Officer, who sits on the BurberryGroup plc Board. The Risk and Ethics committees report into theGroup’s Audit Committee which is chaired by an independent nonexecutive director.
Additionally, our sustainability strategies are reviewed by the
Sustainability Committee which is chaired by the CEO. The
governance structure chart below outlines the reporting lines ofeach of the committees.

Governance

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Burberry Group PLC Board

CEOAudit Committee

Nomination Committee

Remuneration Committee

Risk Committee

Sustainability Committee

Ethics Committee

WORKING WITH OTHERS
We aim to collaborate and work in partnership with others
to identify and manage human rights and modern slavery
risks. We participate in several cross-industry groups andpartnerships including:We are committed to supporting the
UN Sustainable Development Goals (SDGs) and report on how
we contribute to the SDGs in our Responsibility Data Appendix
FY 2022/23.

••

The Business Against Slavery Forum, which is convened by
the UK Home Office, and brings together some of the UK’s
largest companies. Members share intelligence and bestpractice to help identify, tackle and prevent slavery in their
supply chains.
BSR Human Rights Working Group. We became members ofBusiness for Social Responsibility (BSR) in 2022 and joined
their Human Rights Working Group, which was established
to help companies implement the UN Guiding Principles on
Business and Human Rights (UNGPs). It supports companies
to share best practices, challenges, and experiences
implementing the UNGPs and to learn about both foundational
human rights approaches and emerging issues.

•

We are a long-standing member of the UN
Global Compact•

We are committed to supporting the UN Sustainable
Development Goals (SDGs) and report on how we contributeto the SDGs in our Responsibility Data Appendix FY 2022/23.

Policies

Policies

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Policies

We believe that respect for human rights is fundamental
to modern business. The prevention of forced, bonded andtrafficked labour is a core element of Burberry’s Human Rights
Policy and Ethical Trading Code of Conduct.

BURBERRY POLICIESThe Responsible Business Principles (the “Principles”) havebeen developed in line with our commitments and experience
over many years. They have been informed by our longstanding
membership of the United Nations’ Global Compact, and areunderpinned by the ETI Base Code, International Bill of Human
Rights and the Fundamental Conventions of the International
Labour Organisation. We review and update the Principles on anannual basis to ensure that they align to the latest best practiceguidelines and any emerging regulatory requirements. The
Principles apply to all our business associates, which include, but
are not limited to: raw material suppliers, finished goods vendors,
subcontractors, supporting facilities, non-stock suppliers,
construction contractors, licensees and franchisees.
The Principles are overseen by Burberry’s Ethics Committee,
chaired by our General Counsel, and are monitored by our
Responsibility and Supply Chain teams.
The Principles include Burberry Code of Ethical Business
Principles, Anti-Bribery and Anti-Corruption Policy and Global
Environmental Policy, and the following seven policies:

Policies

HUMAN RIGHTS POLICY
Burberry’s Human Rights Policy sets out the procedures wehave put in place to protect and uphold human rights, including
mechanisms in place to address any instances of potential
infringement, across four key stakeholder groups – our people,
workers in our supply chain, our customers and our communities.
The policy was developed with reference to the United Nations’
Guiding Principles on Business and Human Rights. We assess
human rights impacts and monitor labour conditions in both ourown operations and our supply chain on a regular basis to ensure
the policy is upheld.

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

MIGRANT WORKER POLICYThis is specifically intended to protect workers who may bevulnerable to exploitation during international and nationalmigration. The policy contains requirements including, but
not limited to, the prohibition of withholding passports andsimilar documents and the levying of recruitment fees.
During FY 2020/21, we updated this policy based on learnings
from partnering with Issara Institute, an NGO specialised on
recruitment journeys for migrant workers in supply chains.
We then recommunicated this policy to business associates
to provide more detailed guidance on implementation of thepolicy and meeting the standards within it.
The full Migrant Worker Policy is available here: Burberry
Migrant Worker Policy.

Further details of Burberry’s Human Rights Policy are available
here: Burberry Human Rights Policy.

ETHICAL TRADING CODE OF CONDUCTCHILD LABOUR AND YOUNG WORKER POLICYThis outlines requirements which all our business associates must
uphold in relation to their own employees, contracted labour andthroughout their own supply chain. The code includes, amongst
other standards, the following requirements: that employment isfreely chosen, child labour is not used, freedom of association isrespected and no harsh or inhumane treatment occurs.

We prohibit all forms of child labour in our own operations
and throughout our supply chain. In our Ethical Trading Codeof Conduct, we state that we will never use child labour andoutline provisions for young workers.

The full Ethical Trading Code of Conduct is available here:
Burberry Ethical Trading Code of Conduct.

Our Child Labour and Young Worker Policy expands on the
Ethical Trading Code of Conduct and includes standards relating
to implementation, monitoring and remediation procedures
which must be followed by all business associates.
Further details of the Child Labour and Young Worker Policy
are available here: Burberry Child Labour and Young Worker
Policy.

Policies

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

INFECTION MANAGEMENT CONTROL POLICYPARTNER NON-COMPLIANCE POLICY

Most of our supply chain has now returned to operating as they
were prior to the COVID-19 pandemic. To support our businessassociates in continuing to ensure a safe and healthy environment
for employees, customers, partners and visitors, this policy sets
out the minimum standards which Burberry requires its businessassociates to comply with.

Where breaches of our standards and policies are identified,
Burberry collaborates with local partners to find solutions
to address non-compliance. Where improvements are notmade within a given time or there is an unwillingness toaddress the issue, we may consider terminating a particularbusiness relationship. The policy is designed to allow partners
a reasonable amount of time to rectify non-compliances with
the Principles, to minimise any potential detrimental impact
on workers’ livelihoods, while always reserving the right toterminate contracts and take any other legal action possible,
depending on the nature of the breach.

The policy covers infection controls such as social distancing,
Personal Protection Equipment (PPE) requirements and cleaning
programmes that must be observed on site. In addition, Burberryrecognises, within its supply chain, that there are many different
countries each with their own laws and therefore all businessassociates must ensure that, in addition to compliance with thispolicy, it continues to comply with local regulations, laws andindustry best practices.
Looking ahead, we will also support our partners and theiremployees that are facing any longer term effects of thepandemic, by providing psychological guidance through our NGO
sponsored worker hotline, and additional assistance through ourhealth and wellbeing programmes.

Further details of the Partner Non-Compliance Policy areavailable here: Burberry Partner Non-Compliance Policy.

Human Rights Due Diligence

Human Rights
Due Diligence

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Human Rights Due Diligence

ASSESSING OUR HUMAN RIGHTS IMPACT
Every two years, we conduct a Human Rights Impact
Assessment (HRIA) of our operations and activities and those of
our extended supply chain. If a forced labour risk is identified,ethical trading assessments 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.
We have implemented this process since 2014 and continue to
evolve and develop our human rights diligence approach, as wellas our Ethical Trading Programme. As part of this, over the last
two years we have implemented several mitigation action plans
focused on the three highlighted areas from our FY 2020/21
assessment:

Diversity, Equity and Inclusion
Worker voice
Modern Slavery

On diversity, equity and inclusion, we have strengthened ourpartnership with cultural mediators and provided migrant
workers with tools to expand their awareness about public
services and facilitate access to them. In relation to worker
voice, we have continued to sponsor our hotlines, which remaina key tool to capture workers’ needs. Over the last year, wehave also expanded the hotlines’ reach to new countries andmore workers within our raw material supply chain. Finally,in response to modern slavery risks, we monitor our policies
to ensure they remain relevant, we strictly implement our due
diligence process at onboarding and we keep refining our audit
tools. We also conduct training for both internal teams andsupply chain partners to raise awareness and provide tools toprevent and mitigate this risk.

Human Rights Due Diligence

Our latest impact assessment took place in Q4 of FY 2022/23,
where in addition to our standard assessment, we conducted a
supplementary analysis with a specific lens looking at where
migrant workers’ human rights may mostly be affected. This
assessment also included considerations related to the UNGA’s
recognition of the Right to a clean, healthy, and sustainable
environment, under international law. We used this opportunity to
explore what this could mean for the workers throughout our supply
chain, who carry out a variety of manufacturing processes, in manydifferent environments across the world.
These assessments identified the following salient key areas where
human rights violations are more likely to be identified across ourfinished goods and raw materials suppliers.
These are:Working and living conditions, including accessto health services
Worker voice – specific to providing remedy
Diversity, equity and inclusion
Modern slavery

As we move into the next year, we will continue to build out ouraction plans to further address these risk areas, as well as drivinga clear focus on ensuring our business practices have a positive
impact on workers in the supply chain.
To ensure our HRIA methodology remains comprehensive andcontinues to provide us with a material assessment of Burberry’s
operational Human Rights footprint, we are working closely with an
external consultant, to revise and enhance our methodology.

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

TRACEABILITY
We are developing a traceability programme for raw materials. This
will enable us to more closely assess and manage the social impactsof raw material sourcing. As part of the programme, we have
implemented a traceability pilot project with some of our key cotton
suppliers, using a third-party traceability tool which tracks thecotton back to the farm and country of origin. We will extend thistrial in the coming year, with an aim to have full traceability of key
raw materials by FY 2029/30. This is also aligned with our existing
raw material and traceability targets, which we are currently on
track to achieve by FY 2029/30. See our Annual Report FY 2022/23
for further details of our targets and progress on raw material
traceability and certification.

DUE DILIGENCE AND ASSESSMENT OF OUR SUPPLY CHAIN
Our due diligence model includes and combines the activities weput in place to identify and manage social risks in our productsupply chains. We review our due diligence model regularly toensure it meets the expectations of our external stakeholders suchas consumers, investors and governments and to ensure ongoingalignment to legislation.

SUPPLY CHAIN PARTNER ON BOARDING
All our supply chain partners and their supporting facilities arescreened and assessed at the onboarding stage to identify any
human rights and modern slavery risk. We require all our partners to
acknowledge and sign Burberry’s Responsible Business Principles toensure mutual agreement that any form of modern slavery, included
forced, bonded or involuntary prison labour, is not permitted under
any circumstances.
Adherence to the Principles is included in our contracts with
suppliers. They sign a letter of undertaking confirming, amongst
other matters, their commitment to the Principles and responsibility
to cascade the Principles within their own supply chains. Right fromthe onboarding stage, they are also required to agree that we may
visit and assess their own compliance and that of their suppliers at
any time. Before any new supply chain partner is approved, they
are risk assessed for social compliance and any indication of forced,
bonded or trafficked labour. For raw material suppliers, if during
this risk assessment a vulnerable workforce or geographical location
risk is identified, a full audit will be completed and the results andthe remediation plans (if any) will be evaluated before a decision
on providing approval is made. Should remediation be unsuccessful
at any stage and a supplier not meet our strict criteria, we do not
pursue any working relationship with them.

Human Rights Due Diligence

Burberry Group PLC

New raw material suppliers onboarding process:
1.

2.

3.

New Raw Material
Supplied onboarding
request submitted

Raw Material Supplied
to fill in onboarding
documentation, sign
Burberry RBPs and toacept Burberry audit

Raw Material supplierrisk assessment
conducted by Burberry
Responsibility Team4.

5.

In case of modern
slavery or other social
complience risk
being identified, audit
conducted

RMS approved
only if no severe
non-conformity isidentified

New finished goods suppliers onboarding process:
1.

2.

3.

New finished good
supplied onboarding
request submitted

Finished good supplierto fill in onboarding
documentation, sign
Burberry RBPs and toaccept Burberry audit

New finishedgoods supplierrisk assessment
conducted by Burberry
Responsibility Team

4.

5.

Audit conducted

Supplied approved
only if no severe
non-conformity isidentified

2022/23

Modern Slavery Statement

Burberry Group PLC

AUDITS AND ASSESSMENTS
We continually assess human rights risks and labour conditions
across our global supply chain through monitoring and verification
activities as part of our Ethical Trading Programme, which wasestablished in 2004.
Before a new supply chain partner is approved to work with
Burberry, we assess its compliance with the Principles andapplicable local laws and commitment to uphold them. Suchassessment includes an Ethical Trading Audit. We have a team of
ethical trading experts within our Responsibility team who carryout ethical audits across our supply chain, and are supported
by interpreters and cultural facilitators where required. External
accredited auditing agencies are also appointed to conduct audits
in some cases. Audits, announced or unannounced, consist ofworker interviews, document reviews and site tours, and are
repeated periodically to confirm ongoing compliance and continuous
improvement. The frequency of audits depends on the level of
performance in previous audits – better performing factories areaudited less frequently, whereas facilities where more severe nonconformities are identified are audited every three to six months.
Between audits, our Responsibility team works closely with facilities
to support the implementation of required improvements and to
implement systems to prevent modern slavery, as well as to improvethe management of human rights and health and safety risks.
During the FY 2022/23, we conducted 449 audits and 19
engagement activities across our finished goods and raw material
supply chains. All our partners are provided with an approved
corrective action plan that is closely monitored and supported by ourteams, who work with the facilities on a continuous improvement
plan. This year, the main areas of non-conformance with ourstandards related to health & safety and working hours, and we willcontinue to work with our partners to identify the root cause of
these issues, and implement actions to address them.
Our audits also address the risk posed by unauthorised
subcontracting. As a global organisation, we accept our
responsibility to support and guide our partners by raisingawareness of associated risks of modern slavery at subcontractors.
Our partners have extended the no-tolerance policy of unauthorised
subcontracting to all of their partnerships and in some cases
implemented digital tracking systems to prevent outsourcing.

Human Rights Due Diligence

We have also continued to extend the scope of our ethical audit
programme to cover logistics and distribution centres, service
providers and suppliers of GNFR, where we identify risks based on
location, worker demographic or processes carried out at the facility.
In FY 2022/23, we carried out ethical audits at gifting and marketing
vendors, suppliers of packaging and visual merchandising suppliers,
and we will continue to enhance our risk mitigation in this area of
our supply chain.

ADDITIONAL SUPPLY CHAIN ACTIVITES
Burberry understands that utilising an auditing approach alone todue diligence, does not always lead to sustainable change. Therefore
we have implemented several additional programmes to support ourpartners’ capabilities to identify, manage and prevent social risks
within their own facilities and extended supply chains.

ETHICAL TRADING CAPACITY BUILDING PROGRAMME
In order to promote ethical audits through further tiers of our supply
chain, we continue to extend our capacity building programme,
named the Vendor Ownership Programme. This supports key supply
chain partners in the EMEIA region to adopt their own ethical audit
programmes across their own supply chain.
Thanks to our vendors’ continued engagement, along withextensive support and training, the programme is a key pillar
for ensuring Burberry’s Ethical Standards are met in our supply
chain. By developing a collaborative and mutually supportive
approach with our vendors, we have achieved a hugely positive
impact in identifying, assessing, preventing and mitigating risks
within our supply chain. Regular audits focused on human rights
as well as health and safety are conducted both by our vendors’
appointed resources and our internal Responsibility team, against
the Ethical Trading Code of Conduct. Based on the results of theaudit, improvement action plans are developed, and shared with thevendors’ support facilities, who work on bridging the gaps identified.
We ensure a continuous in-depth analysis and investigation of supply
chain related issues through training sessions, which are facilitatedby Burberry and delivered both by the Burberry Responsibility Teamand external consultants – designed upon vendors’ needs and torespond to external challenges.
The programme is now in place at 22 vendors (21 in Italy and 1
in UK) reaching over 16,500 workers across 252 subcontractors,
covering 47% of our EMEIA product supply chain.

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

WORKER WELLBEING PROGRAMME
We aim to engage our supply chain partners in programmes that
support the wellbeing of workers across our supply chain. In FY
2022/23, eight key finished good vendors in Italy and seven key
manufacturing facilities based in China, Vietnam and Thailand
participated in our worker wellbeing programme, which we firstlaunched in 2018. This has covered over 5,000 workers in our
supply chain during FY 2022/23. By focussing on worker wellbeing,
we aim to help our suppliers to improve employee satisfaction andattract and retain talent.
The programme has included:•

Training sessions and workshops for site managers to increaseknowledge about worker wellbeing.

•

A survey to measure worker wellbeing, which was originallydeveloped in partnership with Oxfam and adapted over time.
This covers topics such as happiness at work, job satisfaction,
personal and professional development, and physical wellbeing.
An additional section was added for the APAC region focusing on
how the COVID-19 pandemic has affected workers wellbeing.

Our Corporate Responsibility team has worked with the participatingsites to review survey results and encourage them to develop
specific action plans (in consultation with workers) to drive
improvement. We also monitor implementation of the action plans.
In response to the feedback, our suppliers have made various
improvements over the past year such as development of worker
and supervisor training programmes and initiatives to promoteinternal dialogue.
Next year we plan to extend the programme to cover more supply
chain partners and will encourage participants to cascade the projectacross their own supply chain where applicable.

Wellbeing programme reached over

5,000
workersHuman Rights Due Diligence

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

DUAL CAPACITY BUILDING INITIATIVE FOR MIGRANT WORKERS

LIVING WAGE

We have started a new dual capacity building initiative to support
the ethical recruitment, employment and integration of migrant
workers across our European supply chain. This aims to botheducate management across our vendors as well as build awarenesswith workers.

Burberry is committed to the promotion and adoption of a living
wage in our own operations and supply chain and is proud tobecome the first luxury retailer and manufacturer to achieve
accreditation as a UK Living Wage employer. In 2016, Burberryjoined the Global Living Wage Initiative, which works to address
in-work poverty across all sectors and multiple geographies,
as part of a unified, global approach with multi stakeholder
participation.

We have developed a grievance mechanism for migrant minorities,
which has been designed with the support of experts in modern
slavery. This provides a confidential channel for migrant workers to
identify, report and address potential instances of modern slavery.
We plan to pilot this with nine supply chain partners in FY 2023/24.
A training programme has been developed for our supply chain
partners, in collaboration with the International Organisation for
Migration (IOM). This is designed to help educate our vendors andraw material suppliers on how to ensure the protection of migrant
workers, with a specific focus on their recruitment journey. It
includes a deep dive on diversity and inclusion best practices inorder to support the integration of migrant workers into the local
workshop population.
In total, this training reached 77 supply chain partners and impacted
9,500 workers in FY 2022/23. This included 37 of our first-tierpartners in Italy and eight direct partners of our Italian owned
manufacturing facility, Burberry Manifattura and 100% of first tierand second tier partners in Poland, Romania and Moldova. Acrossour supply chain partners, attendees included managers, humanresources teams and internal auditors. In addition, 100% of ourVendor Ownership Programme auditors (21), as well as Burberry
auditors, have been trained to identify red flags and deep dive into
recruitment dynamics.
Based on the positive feedback received by attendees, we are
currently exploring new opportunities for creating a longer-term
partnership with IOM on enhancing due diligence and migrant
workers voice on a more permanent basis, across the whole
impacted value chain.

Training reached9,500
workers

77
partners

In 2022, we brought forward the new UK real Living Wage pay
rates as defined by the Living Wage Foundation by more than six
months. Several of our UK suppliers are Living Wage Employers,
including our longest standing partner Johnston’s of Elgin,
manufacturers of Burberry’s Heritage Cashmere scarves.

Human Rights Due Diligence

WORKER GRIEVANCE MECHANISMS
We seek to ensure that employees and workers in our supply
chain have access to confidential support and advice. We provide
grievance mechanisms for our employees, including a global
helpline which is managed by an independent company. We alsosponsor confidential hotlines run by NGOs for workers in our supply
chain, which provide advice on workers’ rights and wellbeing andconfidential support.

>27,000 workers
are able to access worker hotlines
in place across our supply chain.

During FY 2022/23, Burberry sponsored hotlines received 502
calls (467 calls in FY 2021/22). These included 18 complaints, 464
consulting requests and 20 psychological support requests. All calls
have either been responded to by the NGO that operates the hotline
and/or the factories to address the workers’ concern. Grievanceresolution is monitored by the Responsibility team. Next year, we
will continue to look for opportunities to expand hotline support.
Our Ethical Trading Code of Conduct also recognises the right for
employees to join trade unions and collective bargaining. Over
70% of the finished goods facilities we source from are covered bynational and/or industrial collective bargaining agreements and many
have established union representation, enabling workers to remain
informed and involved in discussions about their rights.

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

The below is an example of a case received from hotline in FY
2022/23 and how the concern was resolved:

MIGRANT WORKER DOCUMENTATION CONCERN
A worker contacted the hotline and raised a concernthat their working Visa documentation had expired
for some time, but their factory management was
yet to help them renew it. The hotline facilitator
communicated with the factory representative andnoted that the queue of renewal application was
significant, due to the local embassy having beenclosed for more than 2 years during the COVID-19
pandemic and had only recently re-opened. The hotlinetransferred the message to the worker explaining
the reasons of delay and reassured them about theirconcerns. The Factory management also conducteda meeting with all their migrant workers to explain
the situation and regularly reported the progress of
the renewal status of their documents. To date, all
the documents have been renewed and the worker’s
concerns have been resolved.

Training and Resources

Training andResources

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Training and Resources

Burberry’s employees and supply chain partners are essential
in helping to identify and prevent modern slavery in our supply
chain.

BURBERRY INTERNAL TEAMS TRAINING
Burberry employees are introduced to Burberry’s responsibility
policies and programmes during their induction training toensure a general understanding of Burberry’s responsibilities inthis area.
Raising awareness and conducting training on the risks
associated with modern slavery is critical for those making
sourcing decisions. In FY 2022/23, 89 members of our internal
supply chain, sourcing, internal manufacturing and productteams received either introductory or refresher training. The
targeted training helps those who have close contact with
our extended supply chain to be familiar with the risk areas,
likely indications of human rights abuses (including instancesof modern slavery) and possible actions to take if an incident
of modern slavery is identified. The training also has a module
on responsible buying practices, to explain the link between
purchasing practices, potential impact on working conditions
and risk of Human Rights violations. This training has helped
embed respect for human rights and a policy of zero tolerance
for modern slavery throughout the business.
We regularly review training needs across our business
operations to ensure all relevant employees are included. In
FY 2023/24, we will continue to extend our offering of online
resources and continue to conduct trainings to reach a wider
audience of employees and further embed awareness and risk
mitigation into our culture.

Introduction

SUPPLY CHAIN TRAINING
Training our supply chain partners, including vendors and key raw
material suppliers, on understanding, identifying and managing modern
slavery risks, is a key component of our strategy as our partners play
an integral role in helping us to identify and prevent modern slavery in
our supply chain.
As part of our onboarding process, we conduct training with all of our
new suppliers to ensure they have a clear understanding of our ethicaltrade requirements before an audit takes place. We highlight theimportance of being transparent during an ethical audit, and clearly
explain what our critical issues are.

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

This year, we focused our training efforts on ethical recruitment,
employment and integration of migrant workers, across ourEuropean Supply Chain, which is where the majority of our partners
are located.
We have developed and started to roll out a training programme
for our supply chain partners, in cooperation with the International
Organisation for Migration (IOM), to support the ethical recruitment,
employment and integration of migrant workers across our EMEIA
supply chain (see due diligence section – page 12). In total, thistraining reached 77 partners and positively impacted over 9,000
workers.
Next year, we plan to further roll out the migrant worker training.
We also plan to conduct training on risks associated with sourcing
from different countries, and ways we can mitigate risks fromentering our supply chain at the very initial stages of onboarding.

Training reached9,000
workers

77
partnersEffectiveness of Measures and Our KPI’s
Introduction

Effectiveness of Measuresand Our KPI’s

Burberry Group
BurberryGroupPLC
PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Effectiveness of Measures and Our KPI’s

Our
commitment/KPI

Progressduring
FY22/23

Plannedactions for
FY23/24

Burberry internal teams training
The Burberry
Responsibility teamtrains key internalteams working
with our businessand product supply
chains. This
includes sourcing,supply chain andlogistics, productdevelopment, HR,legal, construction,
procurement andworkplace services.

In FY 2022/23, 89
members of ourinternal supply chain,sourcing, internal
manufacturing
and product teams
received either
introductory or
refresher training

We will continue toextend our offering of
online resources andcontinue to conduct
trainings to reacha wider audienceof employees andfurther embedawareness and risk
mitigation into ourculture. We will also
conduct specialised
training on Countryof Origin (COO)
associated risks, andprovide the tools to
help mitigate risks
from entering our
supply chain at thevery initial stages of
onboarding.

Introduction

Burberry Group PLC

Ourcommitment/KPI

Progressduring
FY22/23

Plannedactions for
FY23/24

Supply chain training
We regularly train
our finished goods
suppliers, their key
subcontractors andkey raw material
suppliers on theidentification ofmodern slavery andbuilding systems
to prevent theoccurrence of modern
slavery.

In collaboration
with the IOM, wedeployed a training
on the responsible
recruitment of
migrant workers, to
key partners across
our EMEIA supply
chain. In total, thistraining reached
77 partners andimpacted over 9,000
workers.

We will continue toexplore opportunities
with external experts
such as the IOM, toprovide our supply
chain with theknowledge and tools
to mitigate risks intheir own supply
chains2022/23

Modern Slavery Statement

Our
commitment/KPI

Burberry Group PLC

Progressduring
FY22/23

Plannedactions for
FY23/24

Audits and assessments
Our audit andassessment
programme covers
all our finished goods
facilities and theirsubcontractor supply
chains as well as
key raw material
suppliers, to ensurecompliance with
the Burberry Ethical
Trading Code of
Conduct

In FY 2022/23, we
conducted 449 ethicaltrading audits and 19
engagement activities.
The majority ofthese activities wereconducted by ourinternal Responsibility
team who endeavour
to build trust in our
ongoing partnerships
and drive continuous
improvement.

We will continue
to conduct ethicaltrading audits acrossour supply chain,
where risks are mostprevalent, and review
our due diligencemodel to ensure it
meets the heightened
expectations of ourexternal stakeholders
such as consumers,
investors andgovernments and toensure alignment toglobal legislation.

Introduction

Ourcommitment/KPI

Burberry Group PLC

Progressduring
FY22/23

Plannedactions for
FY23/242022/23

Modern Slavery Statement

Our
commitment/KPI

Worker voice
We seek to ensurethat employees
and workers in our
supply chain haveaccess to confidential
support and advice.
We provide grievance
employees, including
a global helpline
which is managed
by an independentcompany. We alsosponsor confidential
hotlines run byNGOs for workers
in our supply chain,
which provide advice
on workers’ rights
and wellbeing andconfidential support

During FY 2022/23,
Burberry’s worker
hotline received 502
calls, categorised as
18 complaints, 464
consulting requests
and 20 psychologicalsupport requests.

Burberry Group PLC

Progressduring
FY22/23

Plannedactions for
FY23/24

Wellbeing
In the coming year,
we will continue tolook for opportunities
to provide hotline
support to morefactories prioritising
suppliers with
migrant workers,
continue toimprove workplacecommunication
channels and lookafter the wellbeingof workers andmanagement.

We aim to engage
our supply chain
partners inprogrammes that
support the further
advancementof wellbeing,
livelihoods,
inclusivity andworker voice acrossour supply chain.

This year, 15 of our
key supply chain
partners have been
actively involvedin our wellbeing
programme,
positively impacting
over 5,000
workers. As well as
ensuring continuous
improvement acrossworkers’ wellbeing,
we also focusedon responding to
specific gaps andneeds to maintaincritical skills, attract
and retain uniquetalents, encouragea responsible
employee-conscious
culture and ensurea sustainable supply
chain throughspecific actionplans.

Over the next
year we plan tokeep engaging
the participants
involved during thelast year in order
to work with themto strengthen the
improvements
achieved, measure
the results
obtained as wellas to cascade theproject within theirown supply chain
where applicable.
Moreover we areplanning to include
more key vendors
and manufacturing
facilities aiming
at bringing wider
positive impacts
along our supply
chain.

Introduction

Burberry Group PLC

Ourcommitment/KPI

Progressduring
FY22/23

Plannedactions for
FY23/24

Human Rights Impacts
We regularly conduct
Human Rights Impact
Assessments (HRIA)
of our operations andactivities and those of
our extended supply
chain, to understandour potential andactual impacts.

Our latest impact
assessment took
place in Q4 of FY
2022/23, wherein addition to ourstandard assessment,
we conducted a
supplementary
analysis with a areas
where human rights
violations are more
likely to be identified
across our finishedgoods and raw
materials suppliers.
This identified thefollowing key areas
where human rights
violations are more
likely to be identified
across our finishedgoods and raw
materials suppliers.
These are:•Working andliving conditions,
including accessto health services•

Worker voice– specific toproviding remedy•

Diversity, equity
and inclusion•

Modern slavery

Utilising the resultsfrom our Human
Rights Impact
Assessment, in FY
2023/24 we willcontinue to focus
on implementing
measures to mitigate
these risk areas.
In addition, toensure our HRIA
methodology remains
comprehensive andprovides us with amaterial assessmentof Burberry’s
operational Human
Rights footprint, we
are working closelywith an external
consultant, to revise
and enhance ourmethodology.

2022/23

Modern Slavery Statement

Burberry Group PLC

Looking Ahead
Introduction

Looking Ahead

Burberry Group
BurberryGroupPLC
PLC

2022/23

Modern Slavery Statement

Burberry Group PLC

Looking Ahead

We continue to strengthen the breadth and depth of our humanrights due diligence and Ethical Trading Programme, as well as
implement the action plans resulting from our FY 2022/23 Human
Rights Impact Assessment.
A key focus in the coming year will be to continue to enhance
our due diligence model to ensure it meets the heightened
expectations of our external stakeholders such as consumers,
investors and governments and ensure alignment to upcoming
human rights legislation. We will also work to strengthen ourhuman rights strategy, which will be supported by the revisions
made to our human rights impact assessment methodology andunderpinned by our modern slavery mitigation programme. As partof this, we will continue to review our own business operations
and procurement procedures to ensure that risks of modern
slavery are considered right from the initial stage of sourcing.
Over the next year we will increase our efforts to strengthen
our supply chain traceability, in line with our FY 2029/30
commitments. We believe that our focus on transparency andtraceability throughout the supply chain will further strengthen
our ability to identify modern slavery risks and address any newchallenge that might emerge.
Should any instances of modern slavery be identified, we believethat we are well positioned to address these, and to support
workers through the mitigation and prevention processes we have
put in place.
Approved by the Board on 11th May 2023 and signed on its behalfby:Jonathan Akeroyd
Chief Executive Officer
Burberry Group plc

Introduction

Burberry Group PLC

2022/23

Modern Slavery Statement

Burberry Group PLC