Modern Slavery Statement 2023

Introduction from the Board of Directors of MandM Direct Limited

We, MandM Direct Limited, are committed to improving our practices to combat slavery and human trafficking in our business and supply chain. In 2023, we commenced a review of our policies and procedures to identify where improvements could be made to support our commitment to ensuring no slavery or human trafficking in our business or supply chain. Whilst we continue to work on improving our processes, we believe that tackling modern slavery is a key component of responsible business. We have appointed a member of the management team as the strategic lead for ESG. Our ESG strategy will be recommended for approval in 2024. We have also joined Business in the Community to support us on our journey to becoming a more responsible business.

Organisation's structure

We are an online off-price retailer of clothing and footwear, selling global brands at discounted prices. We are a part of the Danish fashion group Bestseller United A/S (Group), and our ultimate parent company is Heartland A/S. Heartland A/S has its head office in Denmark. We have over 750 employees and operate in the UK, Ireland, France, Germany, The Netherlands, Denmark and Poland.

We have a global annual turnover of £320,000,000.

Our business

Our business is organised into the following business functions: Buying, Merchandising, Operations, E-commerce and Marketing supported by corporate functions of Finance, IT, HR, Legal and Compliance.

Our supply chains

Our product supply chains consist of a range of international manufacturers and suppliers of fashion and sportswear. A small proportion of our product is own-brand purchased directly from UK importers. Our non-product supply chains consist of a range of suppliers including carrier companies and suppliers of IT services and products.

Our policies on slavery and human trafficking

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We have the following policies in place relevant to modern slavery, which we continuously review and update:

• Supplier Code of Conduct
• Supplier Questionnaire
• Human Rights Policy
• Whistleblowing Policy

Due diligence processes for slavery and human trafficking

We understand that the following areas give rise to the highest modern slavery risks: purchasing of product, particularly own-brand products.

As part of our initiative to identify and mitigate risk we require our UK-based importers to undertake regular audits and provide us with necessary assurance that there is no modern slavery or human trafficking.

Supplier adherence to our values and ethics

We have zero tolerance to slavery and human trafficking. To ensure those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme. This consists of: supplier questionnaires, a Supplier Code of Conduct and regular assurances throughout the relationship.

We have a dedicated compliance team, which consists of involvement from the following departments:

• Legal.
• Compliance
• Buying

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, in 2024 we will be providing training to our staff. We also seek assurances from our product suppliers that they also provide equivalent training to their staff, suppliers and providers.

Our effectiveness in combating slavery and human trafficking

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:
- Implement identified improvements to our due diligence process
- Establish KPIs to help us monitor progress against our commitment to ensure no modern slavery or human trafficking and ensure that these are regularly reported to the management team.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 July 2023. It was approved by the board on 30 January 2024.

Signed:

Mike Tomkins
MandM Direct Limited
30^th January 2024