STONEMANOR LIMITED MODERN SLAVERY STATEMENT 2020/21

INTRODUCTION

Modern slavery and human trafficking are gross violations of fundamental human rights. Stonemanor Limited is committed to protecting human rights and the dignity of all persons within our global supply chain and implement and enforce systems and controls to ensure no forms of modern slavery occur

(A) ABOUT US

Stonemanor Limited trades as Apricot and is a multi-channel womenswear fashion brand which was founded in 2007 and is based in the UK. We currently have 15 standalone stores and over 300 concessions across the UK in host stores which include, New Look and Boundary Mills, along with several independent retailers.

We also trade globally with over 600 concessions and stockist across Ireland, Germany, Austria, The Netherlands, Italy, Luxembourg, the USA, and Canada.

Stonemanor Ltd annual turnover in FY 20/21 was £26m.

We therefore believe that our recruitment processes are not gender biased in any way and it is the nature of our business that has the biggest influence on our gender pay gap.

Our head office in North London is home to the design and development, buying and merchandising, digital and marketing, IT and technical, ethical, sourcing, logistics, and finance teams. Our distribution centre (DC) in Biggleswade receives holds, and distributes our products to stores, wholesale partners and online customers.

Total Number of UK Employees in FY20/21 was 255 made up of 35 Head Office, 43 DC and 177 Retail.

(B) SUPPLY CHAIN

We work closely with our suppliers and aim to build long-term sustainable business relationships. In FY 20/21 our product was 100% "own label" and includes clothing and accessories sourced from approximately 30 suppliers across approximately 70 factories. The top five countries were China, Vietnam, Romania, Morocco, and Italy who collectively represented 95% of our range.

We also sourced a wide range of goods and services such as shop-fitting, packaging, cleaning, catering, logistics, security, IT, marketing, ecommerce, advisory and so forth (collectively referred to as goods not for resale or GNFR) from 150 third party suppliers, the vast majority of which were based in the UK.

(C) POLICIES

Stonemanor have a framework of policies that sets out our ethical standards and methodology. These include the following:

1. Code of conduct Which is derived from ILO (International Labour Organization) conventions.
2. Supplier manual
3. Ethical Sourcing Declaration
4. Employee contracts All Stonemanor employment contracts directly incorporate a suite of policies designed to protect worker rights and promote a safe and fair supply chain.
5. GNFR contracts All GNFR goods and services are required to be fully compliant with the Modern Slavery Act. These policies define and guide workplace and employment standards and business conduct and apply to either our own operations and/or that of our business partners. The framework and each individual policy is under constant review to ensure they are effective and capable of addressing new and emerging risks.

(D) DUE DILIGENCE

Due diligence is critical to the overall effectiveness of addressing risk and evolving our approach. Over the last year we continue to follow through on the following key steps:

1. Mapping all first-tier suppliers and business partners: Ensuring the terms of our supplier manual is being honored and all suppliers are registered with Sedex Global or BSCI.
2. Third-party audits: Our suppliers and factories are regularly audited. These audits include, but are not limited to, working conditions, health and safety, hours worked, wages and ability to leave work after working shifts.
3. We have introduced procedures to ensure our buying and quality control team review audit results regularly, follow up with suppliers and ensure there is full compliance with our supplier Manual.

(E) NEXT YEAR

Over the coming year we continue to work on our working practices and our monitoring processes, here are some of the key steps we continue to work on:

1. Training
   Induction process for new starters include information and initial training on modern slavery. Furthermore, key personnel within the business will be trained on the risks of modern slavery annually, including the various forms modern slavery takes (e.g., forced, bonded and child labour) and country specific risks. Training and communication are another area we continue to work on to strengthen our efforts both internally and with business partners.
2. Mapping GNFR
   Continued mapping of our GNFR supply chain and risk assessment exercises.
3. Monitoring
   We continue to explore initiatives within each department to further reduce the risk of modern slavery. Developing new systems, and looking at integrated processes to ensure further compliance, where identified, as necessary. We will also continue to look at the ways we measure the performance of actions we take to combat modern slavery and human trafficking, to help us monitor how effective our practices have been.

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This statement was approved by the Board of Directors of Stonemanor Limited.