Alfred Dunhill Limited Modern Slavery Statement 2023 - 2024

This Statement is made pursuant to section 54 of the Modern Slavery Act 2015 (‘the MSA’). It sets out the steps Alfred Dunhill Limited (‘the Company’), an entity incorporated in the UK, has taken during the 2024 fiscal year ending 31 March 2024 to prevent slavery and human trafficking from taking place in its supply chains or in any part of its business.

The Company has published a Modern Slavery Statement each year since 2016. Previous statements are available on request.

1. INTRODUCTION

The Company is committed to improving its practices to combat slavery and human trafficking and to ensure that its business and supply chains are free from the same.

2. ABOUT THE COMPANY

The Company sells Alfred Dunhill branded clothing, leather goods, jewellery, writing instruments and other luxury goods (‘the Products’) through its retail, e-commerce and wholesale distribution channels. The Company is responsible for the maintenance of the Alfred Dunhill brand including the global marketing and design of the Products. The Company also provides after-sales care for the Products, and offers a repair service for Maison branded products.

2.1.Organisational structure

The Company is an indirect subsidiary of Compagnie Financière Richemont SA (‘CFR’), Chemin de la Chênaie 50, 1293, Bellevue, Switzerland (together with its subsidiaries ‘the Group’). The Company’s immediate parent company is Richemont Holdings (UK) Ltd. The Group owns a number of luxury brands (‘Maisons’ or ‘the Maisons’) including Alfred Dunhill that operate across the following three main areas: Jewellery, Specialist Watchmakers, and Fashion and Accessories/Others sectors. Please see the Group’s Annual Report and Accounts 2024 and the Group’s Non-Financial Report 2024.

Whilst each Maison within the Group operates as an autonomous business, the Group provides certain centralised support services including addressing potential risks of modern slavery. Consequently, the Group works with the Maisons and the Company to set the required governance, standards, and processes to implement requisite policies and procedures which each Maison and each legal entity within the Group (i.e. the Company) is expected to adhere to.

2.2.Locations and employees

The Company’s corporate office, after-sales service centre and a repair and manufacturing facility, are located in London. The Company operates three stores in the UK. At time of reporting, there are 184 employees.

2.3. Management structure

The Company is managed by an Executive Committee (ExCo) comprised of key managers from across each business function. There are three statutory directors including the Company’s Chief Financial Officer (together the ‘Board of Directors’).

3. GOVERNANCE

The Company’s Board of Directors are responsible for compliance with the MSA. The Company is then supported and guided by the Group Compliance and Sustainability teams.

Sustainability is firmly embedded at the highest governance level of the Group through the Governance and Sustainability Committee of the Board, which regularly updates and reports its actions to the Board of Directors. The Chief Sustainability Officer is a permanent attendee of this Committee and a member of the Senior Executive Committee (SEC), the executive management body of the Group is responsible for overseeing the management of ESG performance and reporting, including human rights. The Group's Chief Sustainability Officer, is responsible for overseeing the implementation of the strategy defined by the Board and making recommendations to the SEC for adopting the necessary regulations and policies and for setting up the appropriate bodies. When it comes to human rights, the Group's Chief Sustainability Officer is supported by a Human Rights Taskforce consisting of senior leaders representing Group functions, Maisons and Regions. Please see the Group’s Non-Financial Report 2024.

4. POLICIES AND STANDARDS

The Company is committed to upholding the highest ethical standards in all its operations. It adheres to all Group policies pertaining to human rights, including our Standard of Business Conduct, Supplier Code of Conduct, and responsible raw material sourcing guidelines. These are aligned with the Universal Declaration of Human Rights (UDHR), the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct, the Fundamental Conventions of the International Labour Organizations, the ILO core Labour Standards, and the Principles of the United Nations Global Compact (UNGC), to which the Group is a participant.

The Group’s Standards of Business Conduct (‘the Standards’) apply to everyone who represents the Group. This includes employees, directors, temporary staff, contractors, agents, consultants and business partners. Within its ‘Business & Human Rights’ section, the Standards highlights the Group’s commitment to respecting and promoting human rights.

In fiscal year 2024, the Group launched a Human Rights Statement reflecting the Group’s longstanding fundamental principles of respecting the human rights of all people across the business and value chain, including employees, customers, investors, partners and suppliers. It describes the human rights related focus areas such as ‘Prohibition of forced labour, modern slavery and human trafficking’, which states that the Group does not tolerate forced or compulsory labour of any kind, and that it opposes the use of forced or unlawful compulsory labour in its own business operations, the business operations of its Maisons or by any suppliers, business partners and contractors, or for any other purpose.

With a specific focus on supply chain, the Group’s Supplier Code of Conduct (‘the SCoC’) outlines the requirements that all the Group’s suppliers must comply with, including business ethics, labour and human rights, and environmental protection. More precisely, section 3.4. of the SCoC ‘Freely chosen employment’ mentions that suppliers shall not use forced labour, including bonded, indentured, or involuntary prison labour, or engage in any form of modern slavery or human trafficking. It also adds that workers should not be required to lodge ‘deposits’ or their identity papers with their employer, and are free to leave their employer after reasonable notice. Finally, it mentions that suppliers shall monitor relationships with recruitment agencies for risks of human traffic.

Finally, the Raw Material Sourcing Policy describes the Group’s requirements when sourcing raw materials. The Group commits to respecting human rights, not engaging in or tolerating bribery, corruption, money laundering or the financing of terrorism, supporting transparency of government payments and rights-compatible security forces in the extractives industry, not providing direct or indirect support to illegally armed groups, and, enabling stakeholders to voice concerns about the supply chain, including any concern regarding minerals and metals originating from conflict and high-risk areas, child labour or any type of actual or potential human rights violation and abuse happening within its supply chain. In doing so, the Group works to identify and reduce the risks of modern slavery at the Group level.

5. SUPPLY CHAIN

As in many businesses, supply chains can be susceptible to human rights impacts such as modern slavery. The Company and the Group adopts a proactive and diligent approach in order to address these.

The Company sources its Products intra-group and via third party suppliers. The Company maintains long-term relationships with its suppliers based on the principles of fair, open, and ethical operations whilst ensuring the continued quality of its Products. In recent years, the Company has undergone a consolidation of its supply chain, with the majority of the network in Italy, to increase visibility and management of operations.

New suppliers must undergo a robust due diligence procedure, conducted by the supply chain and product development teams. As part of this process, suppliers are required to sign specific terms and conditions of purchase and other documents including the SCoC, as well as evidence their own rigorous internal procedures and policies.

The Company benefits from the various Group supply chain procedures and policies relating to suppliers, procurement and sourcing. The Group predominantly produces its creations in Europe and aims to encourage and shape responsible conduct in all relevant aspects within its supply chains. The Group continues to build its management system to enable the identification and mitigation of potential ESG impacts and risks along its supply chains, including modern slavery. This effort is supported by the Group’s responsible sourcing approach founded in the SCoC, the Raw Material Sourcing Policy, and an active promotion of certification standards. In this respect, collaboration across the Group’s supply chains is an enabler to foster continuous improvement. Please see the Group’s Non-Financial Report 2024.

6. RISK ASSESSMENT AND HUMAN RIGHTS DUE DILIGENCE

The Company has a zero-tolerance approach to modern slavery, and it is committed to acting ethically and with integrity in all its business dealings.

The Company benefits from the Group’s risk assessment and due diligence processes. The implementation of a Human Rights Due Diligence Management System starts by assessing the level of potential exposure to human rights risks, including modern slavery. A Human Rights Risk Scan was conducted by the Group with the support of independent experts. Outcomes outline the activities with potential higher exposure to human rights risks, including modern slavery, such as raw material sourcing, making and manufacturing, storage, as well as transport and distribution. Due diligence measures have been adapted accordingly.

When it comes to supply chain management, including activities such as raw material sourcing, making and manufacturing, the Group performs due diligence following a risk-based approach, taking into account the nature of the relationship with its suppliers corresponding to their risk profile. The SCoC outlines the requirements that suppliers must comply with, including business ethics, labour and human rights, and environmental protection.

Depending on the business partner’s activity, the Group requires them to adhere to certification systems such as those of the Responsible Jewellery Council (RJC) a comprehensive standard aimed at ensuring the integrity of the jewellery and watch supply chain, the Kimberley Process Certification Scheme (KPCS), the Leather Working Group (LWG), ISO 14001, ISO 45001, and SA8000. In addition, supplier audits based on the Sedex Members Ethical Trade Audit (SMETA) methodology are conducted on specific suppliers. SMETA is the most widely used format for social audits in the world, enabling businesses to assess their sites and suppliers to understand working conditions in their supply chain. The SMETA audit assesses standards of labour, including forced labour.

In order to assess the effectiveness of the actions it takes to address the risks of modern slavery, the Group undertakes regular due diligence and audits of its suppliers. It recognises that its monitoring, review and assessment of actions taken to both identify and address modern slavery risks in its operations and supply chain are part of an ongoing, evolving process. It will continuously assess the effectiveness of its actions to contribute to the prevention of modern slavery and promotion of human rights. Its efforts to respect human rights are summarised in the Group’s Non-Financial Report 2024.

7. GRIEVANCE MECHANISMS

The Richemont Speak Up Platform launched in June 2022, allows employees and any affected third party to report any concerns by telephone or an online form, with an option for anonymity. These reports are then escalated to the Richemont Speak Up Taskforce, a team of coordinators from relevant functions within the Group responsible for assessing concerns and forwarding them to an appropriate impartial issue owner for further investigation. To ensure that impartiality, the Speak Up reporting system is overseen by the Head of Internal Audit, who is independent from management and reports to the Chair of the CFR Audit Committee, who is updated immediately on all matters of significance that are raised.

The Platform is available to all global operating entities, including all Maisons, and to external stakeholders and third parties. Concerns are addressed confidentially and individuals who report issues are supported. The Group has a zero-tolerance policy for any retaliation towards anyone who makes a report in good faith or who participates in an investigation.

In this regards, a Group Speak-Up Policy has been put in place to encourage the notification of failure, or suspicion of failure, to meet the expected standards of business. It also provides reassurance that any concerns about misconduct or wrongdoing can be reported in a protected environment of mutual trust and confidence. The Group takes all reported concerns seriously and shall ensure that they will be addressed in a fair, honest and timely manner without any fear of retaliation.

8. TRAINING

In alignment with its human rights commitment, a global training program has been launched in fiscal year 2024 at Group level for all employees on ‘Business and Human Rights at Richemont’.

The training aims to increase employee awareness on human rights and guide them in managing potential impacts, ensure that participants understand human rights concepts, learn about the Group’s approach to human rights, and recognise the importance of human rights in their roles. Additionally, eLearning modules on ‘Modern Slavery & Human Trafficking’ were introduced in August 2022. The training is available to all employees worldwide and it is mandatory for employees located in the UK amongst other countries.

The Group launched a general employee awareness campaign and provided Group-wide training in order to promote the Speak Up Platform, the Group’s grievance mechanism.

Finally, the Group requires its employees to follow online training modules on the key topics addressed in the Group’s Standards of Business Conduct.

9. LOOKING AHEAD

The Company and the Group use their best efforts to advance its human rights practices. In light of a continuous improvement approach, the Company and the Group will keep on refining and strengthening its human rights management system with a specific focus on modern slavery.

This Statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the Company’s Slavery and Human Trafficking Statement for the fiscal year ending 31 March 2024. It was approved by the Board on 26 September 2024 and the information contained in this Statement is accurate as of that date.

Signed by Andrew Holmes, Chief Financial Officer and Chief Executive Officer, for and on behalf of Alfred Dunhill Limited.

Alfred Dunhill Limited
MODERN SLAVERY STATEMENT
Financial Year 2022/2023

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (MSA). It sets out the steps that Alfred Dunhill Limited (the Company) has taken during the fiscal year ending 31 March 2023 to prevent modern slavery and human trafficking in its supply chains or within any part of the business.

The Company has a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all business dealings. The Company recognises that no supply chain is without risk of modern slavery, and openly works with supply chain partners to better understand these risks and work together to mitigate them.

The Company has voluntarily published a modern slavery statement each year since 2016, which illustrates their ongoing commitment to acting transparently and tackling systemic modern slavery.

ORGANISATIONAL STRUCTURE

The Company is part of the Richemont group (the Group) and our ultimate parent company is Compagnie Financière Richemont SA, Chemin de la Chênaie 50, 1293, Bellevue, Switzerland. The Group owns a number of luxury brands (Maisons) in the Jewellery, Specialist Watchmakers, Online Distributors and Other (primarily fashion and accessories) sectors.

Whilst each Maison within the Group operates as an autonomous business, the Group provides certain centralised support services including supply chain compliance, sourcing, and procurement. Subsequently, the Group works with the Maisons to set the required standards and to implement necessary policies and procedures which each Maison and each legal entity within the Group is expected to adhere to.

The Business

The Company engages with carefully selected suppliers to provide its products and /or services. The products are sold through either the Company’s own-managed points of sales or through authorised wholesale accounts. As part of the Group, the Company adheres to Group policies, procedures and standards relating to the management of its supply chain and its corporate governance can be found here: https://www.richemont.com/en/home/about-us/corporate-governance/

The Company is managed by an Executive Committee (ExCo) comprised of key managers from across each business function. The Company’s corporate office, after-sales service centre and a repair and manufacturing facility, are located in London. The Company operates four stores in the UK. At time of reporting, there are 159 UK-based employees.

SUPPLY CHAINS AND PROCUREMENT

Supply Chain Relationships

The Company maintains strong, long-term relationships with suppliers based on the principles of fair, open, and ethical operations whilst ensuring the continued quality of its branded products. In the past years, the Company has undergone a consolidation of its supply chain, with the majority of the network in Italy, to increase visibility and management of operations.

Supply Chain Policies and Supplier Code of Conduct

New suppliers must undergo a robust due diligence procedure, conducted by the supply chain and product development teams. As part of this process, suppliers are required to sign specific terms and conditions of purchase and other documents including the Group’s Supplier Code of Conduct(Supplier Code of Conduct), as well as evidence their own rigorous internal procedures and policies.

The Supplier Code of Conduct is based on the main ILO Conventions, the Universal Declaration of Human Rights, the OECD Guidelines and the United Nations Global Compact 10 Principles, amongst others. It reflects emerging best practice in the areas of business and human rights, whistleblowing and grievance mechanisms amongst others. During the year, the Supplier Code was updated to reflect the developed changes on the Speak-Up tool. The Supplier Code is available in 13 languages on the Group's website: richemont-supplier-code-of-conduct-01- 2022-eng.pdf

Suppliers with whom we contract directly will also be required to adhere to the Supplier Code. In exceptional circumstances, suppliers may be permitted to adhere to their own internal equivalent to the Supplier Code of Conduct, but only where the supplier’s own internal processes exceed the Company’s Supplier Code of Conduct.

Standards of Business Conduct Policy

The Standards of Business Conduct sets out the Group’s commitment to diversity stipulating that all aspects of the employment relationship should be free from any form of discrimination. The Standard of Business Conduct also delineates specific standards of ethical behaviour expected from employees. The business and human rights section of the Standards of Business Conduct further highlights the Group’s commitment to respecting and promoting human rights as described in the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct.

This document also sets out the Group’s whistleblowing and grievance reporting line, the Speak Up platform. Launched internally in 2022, this platform should be used to raise any concerns about unethical or illegal behaviour. The Speak Up platform is a comprehensive reporting tool that ensures the Group’s values are maintained and all reported concerns are taken seriously without any fear of retaliation. A concern can be reported to the Speak Up platform through the online process or via telephone and the status of an existing question or concern can be checked on the platform.

The Speak Up platform is accessible on the intranet for employees and will be made available on the Group’s external facing website and can used by external stakeholders such as suppliers, clients, business partners and the wider public. The aim is to empower our people to report suspicious activities and foster an open culture where concerns can be raised. To ensure impartiality the reporting system is overseen by the Head of Internal Audit, who is independent from management and reports to the Chair of the Audit Committee. The extension of the Speak Up Platform to external shareholders took place in May 2023 and we are aware that this action is beyond the reporting timeframe, but we consider relevant to mention it here.

Risk Management, Monitoring and Due Diligence Processes

In terms of human rights due diligence, the Group looks into its whole value chain in order to identify any potential human rights risk, from the sourcing of raw material, to the relationships with our clients.

In 2022 the Group conducted a human rights risk scan to complete our understanding of actual and potential human rights impact along our value chain. Outcomes presented that activities with higher exposure to human rights risks include: raw material sourcing, making and manufacturing, storage, as well as transport and distribution. As a result, we are adapting our due diligence measures in these areas. For instance, the Group have launched a specific assessment for our logistic activities to develop risk mitigation plans.

The Group also conducts regular audits of leather and textile suppliers, as well as indirect suppliers. In this context they leverage their Sedex membership and their SMETA audit referential.

Raw Materials

Sourcing of raw materials and indirect procurement within many businesses’ supply chains could be susceptible of human rights impacts such as modern slavery. Strict rules are applied to the engagement of suppliers, procurement, and the sourcing of raw materials by the Company, as outlined in the Group’s Supplier Code of Conduct and Environment Code of Conduct https://www.richemont.com/media/lbod5lyh/richemont_environment_code_of_conduct_16052019.pdf

PEOPLE POLICIES

Training and Capacity Building

We are advancing the implementation of our human rights work by building capacity through training. In FY23, Richemont launched a training on Modern Slavery and Human Trafficking. The training is available to all employees worldwide and it is mandatory for employees located in Australia, France, New Zealand, Norway, Switzerland and United Kingdom, aligned with local jurisdiction. By the end of FY23, 80% of dunhill employees completed the training.

All new Company employees are asked to read and acknowledge the Group’s Standards of Business Conduct mentioned in this statement.

Employees

The Group have a whistleblowing policy and a hotline (Speak-Up Platform) for employees to voice any concerns they may have related to the operations of the business. The Company is committed to maintaining and improving systems and processes to eliminate all forms of forced and compulsory labour within its supply chain and its business. The Company will continue to review its policies andprocesses to ensure the highest standards in its supply chain, as expected by customers, the companies with which it works and in accordance with the requirements of the Group.

LOOKING AHEAD

The Group will continue its work collaboratively with industry organisations and business partners to promote best practices across its full supply chain and continue to ensure an ethical supply chain.

In its annual Sustainability Report, the Group states its intention to continue to prioritise transparency in its supply chains as well as due diligence and risk mitigation measures. The Group highlighted by the appointment of the Group’s first Chief Sustainability Officer in 2022 who joined the Senior Executive Committee in 2023. In FY24, the Company will hire a Director of Quality and Sustainability, to further drive the sustainability strategy internally, increasing governance, ownership and progression.

The Group is conducting regular materiality assessments to proactively engage with internal and external stakeholders and continue to monitor sustainability reporting framework. Taking this into consideration, looking ahead the Group will strengthen its management systems and human rights due diligence processes in order to prioritize our focus areas in the field and accordingly develop strategies that will allow us to prevent, mitigate and in case it is necessary remediate any potential human rights risk.

The deployment of the Speak-Up platform and of other product social impact assessments will be valuable tools that will assist the Group in this journey, as it will be the collaboration and engagement with the Group’s main stakeholders.

Consequently, the Group is working on developing different ways of training both its employees and other relevant stakeholders in order to raise awareness on human rights. Being a member of SEDEX (Supplier Ethical Data Exchange) since 2021, the ongoing implementation of this platform across the supply chain, has meant having additional risk mitigation tools to assist in this journey. The Company has set ambitious social auditing targets for year-on-year continuous improvement, committing to work with the supply chain to proactively tackle worker rights and Health and Safety factors within their ecosystem. The SEDEX membership will aid in reinforcing ethical supply chain practices through the application of the SMETA audit standard.

More information about future plans at a Group level can be found in the ESG Report, and in the Group Slavery and Human Trafficking Statement.

The ESG Report can be viewed: https://www.richemont.com/media/zimbq1ew/richemont-esg-report-2023-en.pdf, and in the Group Slavery and Human Trafficking Statement which can be viewed: https://www.richemont.com/media/o5cdiwzp/slavery_human_trafficking_statement.pdf.

Approval by Alfred Dunhill Limited’s Board of Directors

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 2023. It was approved by the board on 6 December 2023 and the information contained in this Statement is accurate as of that date.

Signed by Gary Stevenson, Finance Officer, on behalf of Alfred Dunhill Limited.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It sets out the steps that Alfred Dunhill Limited has taken during the financial year ending 31 March 2021 to prevent modern slavery and human trafficking in its supply chains or within any part of the business.

Alfred Dunhill Limited has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings. We recognise that no supply chain is without risk of modern slavery, and it is our responsibility to ensure we understand these risks and work together with our suppliers to mitigate them.

Our Business

Alfred Dunhill Limited engages with carefully selected suppliers to manufacture its products and/or provide relevant services to the company. We sell our branded products either through Alfred Dunhill Limited’s own-managed points of sales or through authorised wholesale accounts. As part of the Richemont Group (“Group”), Alfred Dunhill Limited adheres to Group policies, procedures and standards relating to the management of its supply chain and its general business conduct.

Our Supply Chain Relationships

Alfred Dunhill Limited maintains strong, long-term relationships with suppliers based on the principles of fair, open, and ethical operations whilst ensuring the continued quality of its branded products. We continue to focus resources on building trusting and transparent relationships with key suppliers. Recently, Alfred Dunhill Ltd has undergone a consolidation of its supply chain, centralising our supply chain network in Italy, which increases our ability to manage processes and increases visibility of our supply chain operations.

Alfred Dunhill Limited’s CSR & Supply Chain Compliance Manager, reporting directly into the Quality & Technical Director, is responsible for ensuring the continuous development of policies and strategies to tackle modern slavery and labour issues, increasing the scope of work to hidden areas deeper within the supply chain, and creating a more robust governance and accountability framework.

Our Policies and Processes

When taking on new product suppliers, Alfred Dunhill Limited undertakes due diligence that is carried out by the supply chain and procurement teams within the business. As part of this process, suppliers are required to sign our terms and conditions of purchase and other documents including the Richemont Group Supplier Code of Conduct (“Code of Conduct”).

A full copy of our Code of Conduct for the financial year ending 31 March 2021, is available here: Richemont Supplier Code of Conduct 2022

The Group is currently in the process of revising our Code of Conduct to address further human rights topics, in accordance with the Modern Slavery Act 2015 and the Organisation for Economic Cooperation and Development’s due diligence guidelines. The revised version of our Code of Conduct should be finalised and ready to issue to new and current suppliers imminently.

The Group and its Maisons’ relationships with all business partners – suppliers, subcontractors, and business partners – are based on fair, honest and mutually rewarding relationships contributing to high quality standards of product and services. The Group therefore requires that all its business partners adhere to robust ethical values and ensure the compliance of their own operations against the Richemont’s 39 Principles outlined in the Supplier Code of Conduct.

Alfred Dunhill Limited continues to work in partnership with an accredited compliancy verification company to facilitate a robust social audit programme aimed at monitoring the labour conditions in our product supply chains and ensuring compliance against the Group’s Code of Conduct (as above) over a three-year rolling format. Monitoring and verification activities are carried out throughout our finished goods suppliers and where feasible, at their subcontractor sites.

Alfred Dunhill Limited’s due diligence processes, including social audits, highlight a risk of slavery and/or human trafficking, or any other non-compliance with the Code of Conduct, we will assess such non-compliance on a case-by-case basis and take appropriate remedial action.

During the financial year ending 31 March 2021, Alfred Dunhill continues to source directly from nonproduct suppliers. We request these suppliers to adhere to our Group’s Code of Conduct and we continue to assess those suppliers who have not returned a signed confirmation of compliance, to ensure they have sufficient processes and policies in place to satisfy us that they are operating to the highest standards.

Our Training

Alfred Dunhill Limited continue to take steps to increase employee awareness and engagement regarding slavery and human trafficking issues. Richemont’s Corporate Responsibility Policy (“Policy”), defines the standards the Group expects its managers, employees and suppliers to uphold and specifically articulate the Group’s zero-tolerance policy regarding forced labour.

A copy of the Policy can be found at: https://www.richemont.com/media/u3shrthu/richemont_cr_policy_16052019.pdf

Our Employees

Alfred Dunhill Limited and the Group have a whistleblowing policy and a hotline for employees to voice any concerns they may have including concerns about any part of the Alfred Dunhill Limited business. Alfred Dunhill Limited is committed to maintaining and improving systems and processes to eliminate all forms of forced and compulsory labour within its supply chain and its business. Alfred Dunhill Limited will continue to review its policies and processes to ensure the highest standards in its supply chain, as expected by customers, the companies with which it works and in accordance with the requirements of its Group.

Impact of the Coronavirus Pandemic (“Covid-19”)

Alfred Dunhill Limited has taken appropriate precautions to ensure the safety and protection of all its employees and external third parties encountering its employees, in accordance with Government guidelines. Some of these precautions include encouraging employees to work from home (unless the nature of their work meant that they were unable to do so), controlling movement of employees to and from the office, temperature checking employees upon arrival at the office and wearing PPE and social distancing when working in the office. Alfred Dunhill Limited’s cleaning service providers were also required to implement a more rigorous cleaning routine within the office to ensure cleanliness and hygiene remains at a high standard.

Covid-19 has caused some disruption to Alfred Dunhill Limited’s Social Audit Programme annual plan. However, Alfred Dunhill Limited looks to resume normal levels in 2022 and is confident that an appropriate level of due diligence will be achieved.

Alfred Dunhill Limited continues to review the changing Covid-19 landscape to ensure that the measures taken remain appropriate for the health and safety of its employees and third-party organisations within our supply chain, to avoid the risk of exposing them to conditions that make them vulnerable to modern slavery.

Approval by Alfred Dunhill Limited’s Board of Directors

I certify that the information contained in the above statement has been approved by Alfred Dunhill Limited’s Board of Directors.

Signed by Gary Stevenson, Finance Officer, on behalf of Alfred Dunhill Limited.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It sets out the steps that Alfred Dunhill Limited has taken during the financial year ending 31 March 2020 to prevent modern slavery and human trafficking in its supply chains or within any part of the business.

Alfred Dunhill Limited has a zero tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings. We recognise that no supply chain is without risk of modern slavery and it is our responsibility to ensure we understand these risks and work together with our suppliers to mitigate them.

Our Business

Our Supply Chain Relationships

Alfred Dunhill Limited continues to maintain good relationships with suppliers based on the principles of fair, open, honest and ethical operations at all times whilst ensuring the continued quality of its branded products. Since January 2019, we have continued to focus resources on building trusting and transparent relationships with key suppliers – some of those having worked with Alfred Dunhill Limited for many years. We continue to indirectly source finished products, through a Richemont Group Company based in Switzerland, with the majority of our supply chain network centralised in Italy.

Alfred Dunhill Limited hired a dedicated resource; a CSR & Supply Chain Compliance Manager who reports directly into the Quality & Technical Director, to support in the development of specific policies and strategies to tackle modern slavery and labour issues, increase the scope of work to hidden areas deeper within the supply chain, and create a more robust governance and accountability framework.

Our Policies and Processes

A full copy of our Code of Conduct, is available here: https://www.richemont.com/images/csr/2017/supplier_code_of_conduct_2017.pdf.

The Group is currently in the process of revising our Code of Conduct to address further human rights topics, in accordance with the Modern Slavery Act 2015 and the Organisation for Economic Co-operation and Development’s due diligence guidelines. The revised version of our Code of Conduct should be finalised and ready to issue to new and current suppliers in 2021.

The Group and its Maisons’ relationships with all business partners – suppliers, subcontractors and business partners – are based on fair, honest and mutually rewarding relationships contributing to high quality standards of product and services. The Group therefore requires that all its business partners adhere to robust ethical values and ensure the compliance of their own operations against the Richemont’s 39 Principles outlined in the Supplier Code of Conduct.

Alfred Dunhill Limited continues to work in partnership with an accredited compliancy verification company to facilitate a robust social audit programme aimed at monitoring the labour conditions in our product supply chains and ensuring compliance against the Group’s Code of Conduct (as above). Monitoring and verification activities are carried out throughout our finished goods suppliers and where feasible, at their subcontractor sites.

Alfred Dunhill Limited’s due diligence processes, including audits, highlight a risk of slavery and/or human trafficking, or any other non-compliance with the Code of Conduct, we will assess such non-compliance on a case by case basis and take appropriate remedial action.

During the financial year ending 31 March 2020, Alfred Dunhill continues to source directly from non-product suppliers. We request these suppliers to adhere to our Group’s Code of Conduct and we continue to assess those suppliers who have not returned a signed confirmation of compliance, in order to ensure they have sufficient processes and policies in place to satisfy us that they are operating to the highest standards.

Our Training

A copy of the Policy can be found at: https://www.richemont.com/images/about_richemont/corporate_governance/richemont_cr_policy_16052019.pdf

Our Employees

Alfred Dunhill Limited and the Group have a whistleblowing policy and a hotline for employees to voice any concerns they may have including concerns about any part of the Alfred Dunhill Limited business. Alfred Dunhill Limited is committed to maintaining and improving systems and processes in order to eliminate all forms of forced and compulsory labour within its supply chain and its business. Alfred Dunhill Limited will continue to review its policies and processes to ensure the highest standards in its supply chain, as expected by customers, the companies with which it works and in accordance with the requirements of its Group.

Impact of the Coronavirus Pandemic (“Covid-19”)

Alfred Dunhill Limited has taken appropriate precautions to ensure the safety and protection of all its employees and external third parties encountering its employees, in accordance with Government guidelines. Some of these precautions include: encouraging employees to work from home (unless the nature of their work meant that they were unable to do so), controlling movement of employees to and from the office, temperature checking employees upon arrival at the office and wearing PPE and social distancing when working in the office. Alfred Dunhill Limited’s cleaning service providers were also required to implement a more rigorous cleaning routine within the office to ensure cleanliness and hygiene remains at a high standard.

Covid-19 has caused some disruption to Alfred Dunhill Limited’s three-year rolling Social Audit Programme annual plan. However, Alfred Dunhill Limited looks to resume normal levels by 31 March 2022 and is confident that an appropriate level of due diligence will be achieved over the three-year period.

Alfred Dunhill Limited continues to review the changing Covid-19 landscape to ensure that the measures taken remain appropriate for the health and safety of its employees and third-party organizations within our supply chain, to avoid the risk of exposing them to conditions that make them vulnerable to modern slavery.

Approval by Alfred Dunhill Limited’s Board of Directors

I certify that the information contained in the above statement has been approved by Alfred Dunhill Limited’s Board of Directors.

Approved by the Board on 2 December 2020 and signed on its behalf by Gary Stevenson, Finance Director.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It sets out the steps that Alfred Dunhill Limited has taken during the financial year ending 31 March 2019 to prevent modern slavery and human trafficking in its supply chains or within any part of the business.

Our Business

Our Supply Chain Relationships

Alfred Dunhill Limited continues to maintain good relationships with suppliers based on the principles of fair, open, honest and ethical operations at all times whilst ensuring the continued quality of its branded products. Commencing January 2019, we have focused resources on building trusting and transparent relationships with key suppliers — some of those having worked with Alfred Dunhill Limited for many years. We continue to indirectly source finished products, through a Richemont Group Company based in Switzerland, with the majority of our supply chain network centralised in Italy.

In the following financial year (FY20) Alfred Dunhill Limited will further invest in this area by hiring a dedicated resource. A CSR & Supply Chain Compliance Manager will be hired, reporting directly into the Quality & Technical Director, to develop specific policies and strategies to tackle modern slavery and labour issues, increase the scope of work to hidden areas deeper within the supply chain, and create a more robust governance and accountability framework.

Our Policies and Processes

A full copy of our Code of Conduct, is available here: https://www.richemont.com/images/csr/2017/supplier_code_of_conduct_2017.pdf.

The Group and its Maisons’ relationships with all business partners — suppliers, subcontractors and business partners — are based on fair, honest and mutually rewarding relationships contributing to high quality standards of product and services. The Group therefore requires that all its business partners adhere to robust ethical values and ensure the compliance of their own operations against the Richemont’s 39 Principles outlined in the Supplier Code of Conduct.

Alfred Dunhill Limited continues to work in partnership with an accredited compliancy verification company to facilitate a robust social audit programme aimed at monitoring the labour conditions in our product supply chains and ensuring compliance against the Group’s Code of Conduct (as above). Monitoring and verification activities are carried out throughout our finished goods and key raw material supply chains, and where feasible, at subcontractor sites.

During the financial year ending 31 March 2019, Alfred Dunhill continues to source directly from non-product suppliers. We request these suppliers to adhere to our Group’s Code of Conduct and we continue to assess those suppliers who have not returned a signed confirmation of compliance, in order to ensure they have sufficient processes and policies in place to satisfy us that they are operating to the highest standards.

Our Training

Alfred Dunhill Limited continue to taI‹e steps to increase employee awareness and engagement regarding slavery and human trafficking issues. Richemont’s Corporate Social Responsibility Guidelines (“Guidelines”), defines the standards the Group expects its managers, employees and suppliers to uphold and specifically articulate the Group’s zero-tolerance policy regarding forced labour.

A copy of the Guidelines can be found at: https://www.richemont.com/images/csr/2012/extract_corporate_social_responsbilitiy_guidelines_based_on_jul08_version.pdf

Our Employees

Alfred Dunhill Limited and the Group have a whistleblowing policy and a hotline for employees to voice any concerns they may have including concerns about any part of the Alfred Dunhill Limited business. Alfred Dunhill Limited is committed to maintaining and improving systems and processes in order to eliminate all forms of forced and compulsory labour within its supply chain and its business. Alfred Dunhill Limited will continue to review its policies and processes to ensure the highest standards in its supply chain, as expected by customers, the companies with which it worl‹s and in accordance with the requirements of its Group.

Approval by Alfred Dunhill Limited’s Board of Directors

I certify that the information contained in the above statement has been approved by Alfred Dunhill Limited's Board of Directors.

Approved by the Board on 13 December 2019 and signed on its behalf by Gary Stevenson, Finance Director

This statement has been published in accordance with the Modern Slavery Act 2015 (the "Act"). It sets out the steps that Alfred Dunhill Limited has taken during the financial year ending 31 March 2018 to prevent modern slavery and human trafficking in its supply chains or within any part of the business.

Our Business

As part of the Richemont Group ("Group"), Alfred Dunhill Limited adheres to Group policies, procedures and standards relating to the management of its supply chain and its general business conduct. Details of the Group's business governance and corporate social responsibility policies can be found at: https://www.richemont.com/corporate-social-responsibility/governanceethics/policies.html

Our Supply Chain Relationships

Alfred Dunhill Limited strives to maintain good relationships with suppliers based on the principles of fair, open, honest and ethical dealings at all times whilst ensuring the continued quality of its branded products.

Alfred Dunhill Limited has an extensive range of global supplier relationships. However, from 1 September 2017, all inventory purchasing and distribution flows were transferred from Alfred Dunhill Limited to a Richemont Group Company based in Switzerland to improve operational efficiencies within the brand. We now indirectly source finished products, through this Richemont Group Company.

Our Policies and Processes

The Code of Conduct covers the following areas:

No forced employment — not using forced labour and not using employment where terms are not voluntary;
Healthy and safe working conditions — providing a healthy and safe working environment in accordance with applicable laws and regulations;
Wages and working hours — complying with local legislation on minimum wages, working hours and employee benefits;
Freedom of association — allowing workers to associate with lawful and peaceful workers' associations;
No discrimination — net subjecting people to discrimination based on factors including ethnicity, age, religion and sexual orientation, amongst others;
No child labour — net employing people under the age of 15 or younger than the age for completing compulsory education;
No use of corporal punishment — and not subjecting people to harassment, violence or intimidation;
Responsible environmental management — fully complying with local legislation, industry regulations and the Richemont Environmental Code of Conduct;
Grievance Procedure and Whistleblowing — allowing workers to report actual or suspected misconduct without fear of reprisal.

A full copy of the Code of Conduct, which was updated in 2017, is available at: https://www.richemont.com/images/csr/2017/supplier_code_of_conduct_2017.pdf.

Alfred Dunhill Limited also works in partnership with an accredited compliancy verification company in order to carry out audits of our suppliers. Our suppliers are audited at least every 3 years. The audits cover manufacturing sites including sub-contractors. We audit suppliers according to the SEDEX Member Ethical Trade audit formats which assess the suppliers on Health & Safety, Labour Standards, Environment and Business Ethics in line with our Supplier Code of Conduct.

In the event that Alfred Dunhill Limited's due diligence processes, including audits, highlight a risk of slavery and/or human trafficking, or any other non-compliance with the Code of Conduct, we will assess such non-compliance on a case by case basis and take appropriate remedial action.

We endeavour to trade only with those suppliers who comply with the Code of Conduct or those who are taking verifiable steps towards compliance. Arrangements with suppliers in material or persistent breach will be terminated.

We also recognise the risk that modern slavery can exist within our non-product supply chain.

During the financial year ending 31 March 2018, Alfred Dunhill continues to source directly from non-product suppliers. We request these suppliers to adhere to our Group's Code of Conduct and we continue to assess those suppliers who have not returned a signed confirmation of compliance, in order to ensure they have sufficient processes and policies in place to satisfy us that they are operating to the highest standards.

Our Training

The Group and Alfred Dunhill Limited continue to take steps to increase employee awareness and engagement regarding slavery and human trafficking issues. Richemont's Corporate Social Responsibility Guidelines ("Guidelines"), which defines the standards the Group expects its managers, employees and suppliers to uphold, specifically articulate the Group's zero-tolerance policy regarding forced labour.

A copy of the Guidelines can be found at: https://www.richemont.com/images/csr/2012/extract_corporate_social_responsbilitiy_guidelines_based_on_jul08_version.pdf

As part of our ongoing commitment, this year we launched a new compliance module titled 'Avoiding Trafficked Labour'. All relevant employees (current and new) working for Richemont Group's UK subsidiaries are required to complete this module and it is accessible via our learning management system. The module helps to recognize and raise the awareness on human trafficking while also explaining how to avoid the risks in our supply chains through different case scenarios.

Our Employees

Alfred Dunhill Limited and the Group have a whistleblowing policy and a hotline for employees to voice any concerns they may have including concens about any part of the Alfred Dunhill Limited business.

Alfred Dunhill Limited is committed to maintaining and improving systems and processes in order to eliminate all forms of forced and compulsory labour within its supply chain and its business. Alfred Dunhill Limited will continue to review its policies and processes to ensure the highest standards in its supply chain, as expected by customers, the companies with which it works and in accordance with the requirements of its Group.

Approval by Alfred Dunhill Limited’s Board of Directors

I certify that the information contained in the above statement has been approved by Alfred Dunhill Limited's Board of Directors.

Approved by the Board on 12 December 2018 and signed on its behalf by Gary Stevenson, Finance Director

This statement has been published in accordance with the Modern Slavery Act 2015 (the "Act"). lt sets out the steps that Alfred Dunhill Limited has taken during the financial year ending 31 March 2017 to prevent modern slavery and human trafficking in its supply chains or within any part of the business.

This statement has been approved by the Board and signed by Gary Stevenson, Finance Director of Alfred Dunhill Limited.

Our Business

Our Supply Chain Relationships

Alfred Dunhill Limited strives to maintain good and lengthy relationships with suppliers based on the principle of fair, open, honest and ethical dealings at all times whilst ensuring continued quality of its branded products.

Alfred Dunhill Limited has an extensive range of global supplier relationships. We source finished products from approximately 70 suppliers, of which over 60% have been supplying Alfred Dunhill Limited for more than 3 years; more than 20% of these companies have been supplying Alfred Dunhill Limited for more than 10 years. 85% of our suppliers are based in Western Europe

Our Policies and Processes

The Code of Conduct covers the following areas:

No forced employment — not using forced labour and not using employment where terms are not voluntary;
Healthy and safe working conditions — providing a healthy and safe working environment in accordance with applicable laws and regulations;
Wages and working hours — complying with local legislation on minimum wages, working hours and employee benefits;
Freedom of association — allowing workers to associate with lawful and peaceful workers' associations;
No discrimination — net subjecting people to discrimination based on factors including ethnicity, age, religion and sexual orientation, amongst others;
No child labour — net employing people under the age of 15 or younger than the age for completing compulsory education;
No use of corporal punishment — and not subjecting people to harassment, violence or intimidation;
Responsible environmental management — fully complying with locai legislation, industry regulations and the Richemont Environmental Code of Conduct;
Grievance Procedure and Whistleblowing — allowing workers to report actual or suspected misconduct without fear of reprisal.

A copy of the Code of Conduct is available at: https://www.richemont.com/images/csr/2015/supplier_code_of_conduct_2015.pdf.

Alfred Dunhill Limited also works in partnership with a compliancy verification company who is an AAG member of SEDEX. This company utilises auditors with SociaI Accountability Certification SA8000 accreditation in order to carry out audits of our suppliers.

We have a rolling auditing plan where our suppliers are audited at least every 3 years. The audits cover manufacturing sites including sub-contractors. We audit suppliers according to the SMETA 4 Pillar audit which assesses the suppliers on Health & Safety, Labour Standards, Environment and Business Ethics in line with our Supplier Code of Conduct.

We also recognise the risk that modem slavery can exist within our non-product supply chain.

During the financial year ending 31 March 2017, we asked all our non-product suppliers to confirm in writing their compliance with the Act, as well as that of their sub-contractors. Out of approximately 100 suppliers contacted, over half have so far returned a signed confirmation of compliance. We will continue to assess whether those suppliers who have not returned a signed confirmation of compliance have sufficient processes and policies in place to satisfy us that they are operating to the highest standards required by us and the Group and in any event in accordance with the requirements of the Act.

During the next financial year we will assess the risk of our non-product supply chain to further understand the risk of modem slavery and to take steps to mitigate this risk where possible.

Our Training

A copy of the Guidelines can be found at: https://www.richemont.com/images/csr/2012/extract_corporate_social_responsbilitiy_guidelines_based_on_jul08_version.pdf

As part of our commitment, this year we delivered presentations on supply chain compliance to Supply Chain and Product Development departments. These presentations reinforced the importance of awareness for potential Labour Standards and Health & Safety non-compliance issues when visiting suppliers.

Our Employees

Approval by Alfred Dunhill Limited’s Board of Directors

I certify that the information contained in the above statement has been approved by Alfred Dunhill Limited's Board of Directors.

Approved by the Board on 12 December 2017 and signed on its behalf by Gary Stevenson, Finance Director

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (\"Act\") and sets out the steps Alfred Dunhill Limited has taken to ensure that slavery and human trafficking is not taking place within its supply chains nor within any part of our business. This statement is for the financial year ended 31 March 2016. Alfred Dunhill Limited has a zero tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings.

Our Business

Alfred Dunhill Limited engages with carefully selected suppliers to manufacture its products and/or provide relevant services to the company. We sell our products either through Alfred Dunhill Limited’s own managed points of sales, through authorised wholesale accounts or through the subsidiaries of the Richemont Group (“Group”). As part of the Group, Alfred Dunhill Limited adheres to Group policies, procedures and standards relating to the management of its supply chain and the conduct of its business generally. Details of the Group’s business governance and corporate social responsibility policies can be found at: https://www.richemont.com/corporate-social-responsibility/governance-ethics/policies.html

Our Supply Chain Relationships

Alfred Dunhill Limited has an extensive range of global supplier relationships. Alfred Dunhill Limited strives to maintain good and lengthy relationships with suppliers based on the principle of fair, open, honest and ethical dealings at all times.

Our Policies and Processes

During our procurement process, Alfred Dunhill Limited issues purchase orders which incorporate our terms and conditions of purchase (“Terms”). The Terms are further supplemented by the Richemont Supplier Code of Conduct (\"Code of Conduct\") and other policies issued by our Group.

The Code of Conduct includes an endorsement of International Labour Organisation Conventions, the Universal Declaration of Human Rights and other internationally recognised labour practice standards. A copy of the Code of Conduct is available at: https://www.richemont.com/images/csr/2015/supplier_code_of_conduct_2015.pdf.

We are seeking to ensure that all high risk Alfred Dunhill Limited suppliers sign the Code of Conduct and adhere to the requirements set out therein. For those suppliers whom are of lower risk, Alfred Dunhill Limited will be formally reminding them of their obligations under the Act and requesting written undertakings from them of their commitment to eradicate slavery and human trafficking in their own business and supply chain.

Alfred Dunhill Limited undertakes due diligence when considering taking on new suppliers. Such due diligence is carried out by the supply chain and procurement teams within the business.

In addition, Alfred Dunhill Limited works in partnership with a company who is an AAG member of SEDEX and utilises auditors with Social Accountability Certification SA8000 accreditation in order to carry out audits of Alfred Dunhill Limited's suppliers. In the event that Alfred Dunhill Limited’s due diligence or audits highlight a risk of slavery and human trafficking or any other non-compliance with the Code of Conduct, we will assess such non-compliance on a case by case basis and take appropriate remedial action.

We endeavour to trade with those suppliers who comply with the Code of Conduct or those who are taking verifiable steps towards compliance. Arrangements with suppliers in material or persistent breach will be terminated.

Our Training

The Group and Alfred Dunhill Limited are undertaking steps to increase employee awareness and compliance regarding slavery and human trafficking issues. Richemont’s Corporate Social Responsibility Guidelines (“Guidelines”), which articulate the standards the Group expects its managers, employees and suppliers to uphold, specifically articulate the Group’s zero-tolerance policy regarding forced labour. A copy of the Guidelines can be found at: https://www.richemont.com/images/csr/2012/extract_corporate_social_responsbilitiy_guidelines_based_on_jul08_version.pdf

Our Employees

Alfred Dunhill Limited and the Group have a whistleblowing policy and a hotline for employees to voice any concerns they may have including concerns about slavery and human trafficking within Alfred Dunhill Limited’s supply chain or any part of the Alfred Dunhill Limited business. Alfred Dunhill Limited is committed to maintaining and improving systems and processes in order to eliminate all forms of forced and compulsory labour within its supply chain and its business.

Alfred Dunhill Limited will continue to review its policies and processes to ensure the highest standards in its supply chain, as expected by customers, the companies with which it works and in accordance with the requirements of its Group.

Approval by Alfred Dunhill Limited’s Board of Directors

I certify that the information contained in the above statement has been approved by Alfred Dunhill Limited’s Board of Directors.

Approved by the Board on 14 September 2016 and signed on its behalf by Gary Stevenson, Finance Director

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