Ethical Trading Code of Conduct
Reviewed: March 2024

CONTENTS
OUR COMMITMENT

03

DEFINITIONS03

SCOPE OF THE ETHICALTRADING CODE OF
CONDUCT04

IMPLEMENTATION

05

REPORTING AND
REMEDY

05

AUDIT ANDCOMPLIANCE

05

ETHICAL TRADING
CODE OF CONDUCT –STANDARD PROVISIONS

06

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OUR COMMITMENT
The Burberry Ethical Trading Code of Conduct sets out standards for Burberry
to uphold in relation to its employees and for its supply chain partners to upholdin relation to their employees. In terms of the supply chain, Burberry requires
agreement to the Ethical Trading Code of Conduct from all those involved in its
extended supply chain, including all Business Associates.

Burberry believes that it is important to be a socially responsible business,promoting fair and sustainable employment practices internally and by
supporting diversity and equal opportunities in the workplace both within its
own operations and across its supply chain. Burberry recognises that within its
supply chain there are many different countries each with their own laws,
cultures, norms and traditions, which Burberry acknowledges and respects.
Some Business Associates will therefore face more complex issues than others
in implementing the Ethical Trading Code of Conduct. Burberry is committed toworking with all relevant bodies to deliver effective action plans for change.
Burberry believes that, by working together with all Business Associates,
Burberry can strengthen our business and improve the quality of life of thepeople who Burberry touch.
DEFINITIONS“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

ETHICAL TRADING CODE OF CONDUCT / 20243••

landlords, andany subcontractor of the above

Business Associates must comply with the Responsible Business Principles andsuch compliance is a condition of working with Burberry (whether directly orindirectly).
‘‘Receiving Country’’ means the country where the Business Associate islocated and where the worker is contracted to work.
‘‘Sending Country’’ means the country where the worker has lived permanentlyor where the worker has resided before entering the contract of employment
with the Business Associate.
‘‘Recruitment Fees’’ refers to any fees paid directly or indirectly in the worker’sSending Country or Receiving Country, for administration and processing andany other amounts required to secure the worker’s employment in theReceiving Country.
Our definition of homework is based upon that of the International Labour
Organisation (ILO): ‘‘Homework’’ means any work carried out by a person in
his or her home or in any other premises of his or her choice, other than theBusiness Associate’s facilities for remuneration which results in a product orservice as specified by the Business Associate. This includes work taken homeby workers who normally work within the Business Associate’s facilities but
who take work home from the Business Associate’s facilities to complete intheir own time.
“Modern Slavery” encompasses any slavery, servitude, forced and compulsory
labour and human trafficking or analogous activity.
SCOPE OF THE ETHICAL TRADING CODE OF CONDUCTThe Ethical Trading Code of Conduct is part of Burberry’s wider responsibility
to safeguard the human rights of the people it touches, including but not limited
to those working within its extended supply chain. It is one of the mechanisms
outlined in Burberry’s Human Rights Policy put in place to address potential
infringements which may arise in connection with Burberry’s operations andactivities.

Through the implementation of the Ethical Trading Code of Conduct in
Burberry’s global supply chain, we are aware that human rights risks may bedisproportionately found within groups of vulnerable workforces. Subsequently,
the Ethical Trading Code of Conduct contains tailored policies which have beendeveloped to address the rights and needs of our supply chain workers including
migrant and home-based workers.
The Ethical Trading Code of Conduct exists to promote fair working conditions
and the responsible management of social issues in the Burberry supply chain.
All Business Associates are expected to establish and maintain a system todeliver compliance with the Ethical Trading Code of Conduct, which is designed
to promote the protection of all workers throughout its extended supply chain

ETHICAL TRADING CODE OF CONDUCT / 2024

4and operations, including any workers employed by third party contractors andrecruitment agencies.
IMPLEMENTATION• Business Associates shall enter into undertakings with Burberry in theform provided by Burberry from time to time, which contain, amongst
other things, terms of engagement on both ethical trading, human rights
and environmental issues.
• Burberry will provide reasonable assistance to the Business Associate in
the implementation of the Ethical Trading Code of Conduct and may
monitor such implementation using a variety of methods including audits
and site visits to assess performance against the Ethical Trading Code ofConduct. The cost of any implementation of the Ethical Trading Code ofConduct, audit or site visit will be met by the Business Associate, except
for Ethical Trade initial audits conducted at finished good vendors, forwhich the cost is covered by Burberry.
• For the purpose of assessing compliance with the Ethical Trading Codeof Conduct, Burberry and/or its authorised representatives, agents orprofessional advisors must be given immediate unaccompanied accessto the Business Associate’s relevant site, without notice to the Business
Associate. Burberry, its authorised representatives, agents orprofessional advisors must also be given immediate unaccompanied
access to the Business Associate’s relevant site where any workers may
reside, without notice to the Business Associate. Should any breach ofthe Ethical Trading Code of Conduct be observed at Business Associate’srelevant site(s), Burberry’s Partner Non-Compliance Policy applies.
• Burberry is committed to working collaboratively with industry partners,
government organisations, non-governmental organisations (NGOs) andtrade unions to implement the Ethical Trading Code of Conduct
effectively and use the most relevant techniques to assess policy
adherence.
REPORTING AND REMEDY• Burberry will report progress on its and its Business Associates'
compliance with the Ethical Trading Code of Conduct in Burberry’s
Annual Report.
• Burberry and its Business Associates will use reasonable endeavours tooffer workers and other stakeholders a confidential means to report anyactual or potential breach of the Ethical Trading Code of Conduct.
AUDIT AND COMPLIANCE• Measurable steps, such as the onsite inspection of Business Associate’s
facilities, will be carried out to assess whether the standards set forth in
the Ethical Trading Code of Conduct are being properly implemented andcomplied with.
• Business Associates are expected to identify and correct any activities
that conflict with the standard of the Ethical Trading Code of Conduct
via verifiable continual improvement programmes agreed by Burberry.

ETHICAL TRADING CODE OF CONDUCT / 20245••Business Associates shall immediately report any serious breaches of theEthical Trading Code of Conduct together with a schedule for corrective
action to be reviewed and agreed by Burberry.
Where serious breaches of the Ethical Trading Code of Conduct persist,
Burberry will consider termination of the business relationship with theBusiness Associate concerned. Please see the Partner Non-Compliance
Policy for further details on this.

ETHICAL TRADING CODE OF CONDUCT – STANDARD PROVISIONSThe standards outlined below apply to all Business Associates and compliancewith these standards is expected of every Business Associate.
1. Employment shall be freely chosen
1.1 Under no circumstances shall Burberry nor any Business Associate use or inany way benefit from any form of Modern Slavery including but not limited to,forced, bonded or involuntary prison labour.

1.2 Workers are not required to lodge "deposits" or their identity papers with
their employer and are free to leave their employer after reasonable notice.
2. Freedom of association and the right to collective bargaining shall berespected
2.1 Workers, without distinction, have the right to join or form trade unions of
their own choice and to bargain collectively.

2.2 The employer adopts an open attitude towards the activities of trade unions
and their organisational activities.
2.3 Worker representatives are not discriminated against and have access tocarry out their representative functions in the workplace.
2.4 Where the right to freedom of association and collective bargaining isrestricted under law, the employer facilitates, and does not hinder, thedevelopment of parallel means for independent and free association andbargaining.
3. Working conditions shall be safe and hygienic
3.1 A safe and hygienic working environment shall be provided, bearing in mind
the prevailing knowledge of the industry and of any specific hazards. Adequate
steps shall be taken to prevent accidents and injury to health arising out of,associated with, or occurring in the course of work, by minimising, so far as isreasonably practical, the causes of hazards inherent in the working
environment.

3.2 As a minimum, building (including structural, fire and electrical safetystandards) must be compliant with local laws and regulations.
3.3 Workers shall receive regular and recorded health and safety training
provided by the Business Associate, and such training shall be repeated for newor reassigned workers.

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3.4 Access to clean toilet facilities and to potable (safe drinking) water and, if
appropriate, clean sanitary facilities for food storage shall be provided.
3.5 Accommodation, where provided, shall be clean, safe and meet the basic
needs of the workers.
3.6 Each Business Associate shall assign responsibility for health and safety toa senior management representative.
4. Child Labour shall not be used
4.1 There shall be no child labour.

4.2 Young persons between 16 and 18 (or between 15 and 18 in countries where
15 years is the minimum age a person can be legally employed full-time) shallnot be employed at night or in hazardous conditions and the Business Associates
must observe any requirements of the law concerning workers under 18.
4.3 Burberry and its Business Associates will always conform to the relevant
ILO standards.
5. Living Wages shall be paid
5.1 Wages and benefits paid for a standard working week must meet, at aminimum, national legal standards or industry benchmark standards, whicheveris higher. In any event wages should always be enough to meet basic needs andto provide some discretionary income.

5.2 All workers shall be provided with clear, written information about theiremployment conditions in respect to wages before they commence theiremployment and about the particulars of their wages for the pay period
concerned each time they are paid.
5.3 Deductions from wages as a disciplinary measure shall not be permitted norshall any deductions from wages not provided for by national law be permitted
without the express permission of the worker concerned. All disciplinary
measures should be recorded.
6. Working hours are not excessive
6.1 Working hours must comply with national laws, collective agreements, andthe provisions of paragraphs 6.2 to 6.6 below, whichever affords the greater
protection for workers. Paragraphs 6.2 to 6.6 are based on international labour
standards.

6.2 Working hours, excluding overtime, shall be defined by contract and shallnot exceed 48 hours per week.1
6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking
into account all of the following: the extent, frequency and hours worked byindividual workers and the workforce as a whole. It shall not be used to replace
regular employment. Overtime shall always be compensated at a premium rate,
which is recommended to be not less than 125% of the regular rate of pay.

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6.4 The total hours worked in any 7 day period shall not exceed 60 hours(including overtime), except where covered by paragraph 6.5 below.
6.5 Working hours may exceed 60 hours in any 7 day period only in exceptional
circumstances where all of the following are met:
• this is allowed by national law;
• this is allowed by a collective agreement freely negotiated with aworkers’ organisation representing a significant portion of theworkforce;• appropriate safeguards are taken to protect the workers’ health andsafety; and• the employer can demonstrate that exceptional circumstances apply
such as unexpected production peaks, accidents or emergencies.
6.6 Workers shall be provided with at least one day off in every 7 day periodor, where allowed/ required by national law, 2 days off in every 14 day period.
7. Discrimination shall not be practiced
7.1 There shall be no discrimination in hiring, compensation, access to training,promotion, termination or retirement based on race, caste, national origin,religion, age, disability, gender, marital status, sexual orientation, union
membership or political affiliation.
8. Regular employment shall be provided
8.1 To every extent possible, work performed must be on the basis of arecognised employment relationship established through national law andpractice.

8.2 Obligations to workers under labour or social security laws and regulations
arising from the regular employment relationship shall not be avoided. The useof labour-only contracting, subcontracting, or home-working arrangements, orthrough apprenticeship schemes where there is no real intent to impart skills orprovide regular employment are not permitted, nor is the excessive use of
fixed-term or flexible hour contracts of employment.
9. Harsh or inhumane treatment shall not be allowed
9.1 Physical abuse, the threat of physical abuse, sexual or other harassment andverbal abuse or other forms of intimidation shall be prohibited.

9.2 Business Associates will have a formal disciplinary and grievance appeal
procedure with documented records of individual disciplinary hearings. Such a
procedure will support fair treatment of workers.
10. The environment shall be protected10.1 Business Associates shall carry out their activities in accordance withnational laws, regulations, administrative practices and policies relating to thepreservation of the environment of the countries in which they operate as wellas in accordance with relevant international agreements, principles, objectives,responsibilities and standards with regard to the environment including, but notlimited to, Burberry's Global Environmental Policy.

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11. Workers shall have legal entitlement to work
11.1 Business Associates should only employ or use workers with a legal right towork in the country.

11.2 The Business Associate must validate, by reviewing original documents andthen returning them to the workers, all workers’ and employment agency
workers’ legal right to work.
11.3 Employment agencies can only supply workers registered with them.
11.4 The Business Associate is expected to establish a process that effectively
monitors the provisions of this paragraph.
12. Sub-contracting and home working
12.1 Business Associates are not authorised to sub-contract any part of theirbusiness related to the production of goods or services they provide either
directly or indirectly to Burberry, without the prior written consent and approvalof Burberry.

12.2 Similarly, sub-contractors are not authorised to sub-contract any part oftheir business related to the production of goods or services they provide either
directly or indirectly to Burberry, without the prior written consent and approvalof Burberry.
12.3 Homeworking is not authorised without the prior written consent andapproval of Burberry (see ‘Homeworker Policy’ on burberryplc.com).
8. Stakeholder Engagement and Communication
8.1 Detail the process for stakeholder consultation, and briefly summarise
those involved in the development and consultation of the guideline.

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