As part of our commitment to the UK Modern Slavery Act (2015) we are sharing our Modern Slavery Statement for the financial year 2025 - 2026. The contents of this statement are aligned with the Home Office’s Statutory Guidance.

1 | Organisation Structure + Approach

3 | Due Diligence + Risk Management

We maintain a comprehensive Corporate Social Responsibility (CSR) policy, which all suppliers must adhere to as a condition of business. This policy is foundational to our Ethical Trading strategy and outlines our strict requirements regarding human rights, including prohibitions against modern slavery, human trafficking, and child labour. While we have robust policies currently in place, we are actively strengthening our standards and expectations, in Q4 2026, we are introducing a redeveloped supplier manual featuring a dedicated, enhanced CSR section. This manual will further integrate our requirements into contractual agreements, ensuring that all suppliers not only understand but proactively meet our elevated expectations for ethical conduct and labour rights.

Supplier Auditing

We are an engaged member of the Sedex community and use their globally recognised auditing methodology Sedex Members Ethical Trade Audit (SMETA) as the benchmark for monitoring and assessing our suppliers’ approach and performance to prevent human rights violations in their supply chains.

SMETA audits are governed by the standards contained in the Ethical Trading Initiative base code and the International Labour Organisation conventions human rights treaties. The audit reports for our suppliers are held on the Sedex database which is also used as an interactive tool for suppliers to upload appropriate information that gives us greater visibility of their ethical practices.

In the event that a supplier has an audit where non-compliances are found, they are given a summary of the action required to resolve the non-compliance and a time frame in which to satisfy the auditors recommendations. All active ME+EM suppliers must provide an audit annually, previously only held for sites in China and Turkey where we have strengthened our requirements. We have been working with our suppliers to conduct SMETA audits as our preferred auditing methodology. We are pleased that 98% have achieved this, including our top 10 manufacturing sites up 10% in the last 12 months.

Reporting

We have developed an internal reporting system to capture and monitor supplier audit outcomes, with a focus on identifying and addressing any non-compliances related to labour standards. Each issue is assessed for severity, and we apply our own scoring to ensure prompt and proportionate remediation with the supplier. While SMETA audits recommend timelines for resolution, we require faster action where a potential risk is identified. Audit outcomes are presented in a dashboard separated by supplier origin, enabling us to identify regional trends and systemic risks. Key findings and priority actions are shared at executive level on a monthly basis to ensure accountability and continuous improvement.

Cotton Sourcing + Banned Regions

We recognise the significant risk of modern slavery in global cotton supply chains, particularly within lower tiers. To address this, we have implemented a strict cotton sourcing policy that prohibits any sourcing from Uzbekistan, Turkmenistan, and China due to credible evidence of forced labour and human rights violations in these regions. Our broader Forced Labour and Human Trafficking Policy further extends these protections by banning all business operations and sourcing from Uzbekistan, Turkmenistan, Myanmar, and the Xinjiang Uyghur Autonomous Region (XUAR) in China.

To effectively mitigate these inherent risks, we are committed to increasing our use of certified, organic cotton. These certification standards provide vital traceability back to the source and ensure that strict social and ethical standards are rigorously upheld throughout the supply chain.

Whistle Blowing and Grievance Mechanisms

We provide a whistle blowing procedure in the employee handbook which explains how an employee can communicate their concern through internal escalation or contact details for an independent organisation where advice and support can be obtained. In addition to this we provide contact details for a dedicated modern slavery helpline. As part of our forward objectives we will be assessing grievance and whistleblowing mechanism options for our stock suppliers.

Freedom of Association + Collective Bargaining

ME+EM recognises freedom of association and the right to collective bargaining as fundamental human rights, grounded in our commitment to the ETI Base Code. We are dedicated to ensuring these rights are respected across our supply chain; however, we acknowledge the challenges in high risk regions, particularly in China and Turkey, where legislative restrictions can limit formal union activity.

We are dedicated to supporting worker representation and promoting direct, open channels for dialogue, particularly where traditional union activity faces barriers. We view this as an evolving area of our due diligence and are actively taking steps to strengthen our oversight, including:

• Identifying existing representation: Mapping suppliers with established worker committees or representative bodies.

• Engaging external partners: Proactively building links with NGOs and labour rights experts to facilitate worker dialogue where traditional channels are restricted.

• Enhancing monitoring: Integrating worker engagement metrics into our regular supply chain risk assessments to ensure we remain vigilant and responsive to worker needs.

Supply Chain Risk Assessment

Our CSR team takes a risk-based approach to human rights due diligence, prioritising suppliers and sourcing regions where workers may be at greater risk of adverse human rights impacts. Through the creation of our internal dashboard we can understand risk by county and region which dictates our focus. We use multiple sources to identify risks in our supply chain, including the Sedex suite of risk tools that combines information from several sources including:

• ILO (International Labour Organisation)

• Walk FreeUNDP (United Nations Development Programme)

• WEF (World Economic Forum)

• ITUC (International Trade Union Confederation)

• UNICEF

We monitor and assess our supply chain through factory visits, social audits, risk assessment tools, and our own supplier reviews. As members of the Ethical Trading Initiative (ETI), we engage with global issues affecting workers, such as displaced people from Ukraine and the 2023 earthquakes in Turkey.

We conduct periodic risk assessments across our supply chain to identify, monitor, and mitigate inherent and supplier specific sourcing risks. Our assessments utilise the comprehensive Sedex risk reporting framework, covering country, region, and sector risks, as well as forced labour insights and audit indicator details.

The CSR team analyses risk ratings for our main sourcing countries, based on a review of key labour issues including discrimination, forced labour, freedom of association, child labour, gender, employment, wages, and working hours.

Salient Human Rights and Modern Slavery Risks

Our 2025-26 risk assessment identified India, Nepal, Sri Lanka, Turkey, and China as the sourcing countries with the highest inherent exposure to labour rights and modern slavery risks, based on Sedex country risk indicators. India recorded the highest overall risk score, with elevated indicators across all assessed labour rights categories, including forced labour and excessive working hours.

Across our sourcing regions, we have identified the following priority areas of salient human rights risk:

• Forced labour: Particularly affecting migrant, temporary, agency and subcontracted workers, who may be more vulnerable to exploitative recruitment practices, restricted freedom of association and debt bondage.

• Restricted freedom of association: Risks associated with limitations on worker representation, collective bargaining and access to effective grievance mechanisms.

• Excessive working hours: Risks associated with production pressures, capacity constraints and inadequate working time management, particularly within manufacturing operations.

These risks are assessed through a combination of independent social audits, supplier engagement, Sedex risk intelligence and targeted in-country assessments.

Importantly, country and sector risk indicators represent potential exposure and do not indicate that violations have occurred within ME+EM’s supply chain.

We recognise that social audits alone cannot provide complete assurance, particularly where risks may be concealed or occur beyond direct manufacturing partners. We therefore continue to strengthen our approach through greater supply chain visibility, local expertise and ongoing engagements with suppliers.

Risk Mitigation and Priorities

Our approach focuses on identifying potential adverse human rights impacts, prioritising action according to risk and supporting meaningful improvements in working conditions.

Building on our existing ethical trade programme, our priorities include:

• Strengthening supply chain transparency: Implementing Textile Genesis to improve visibility beyond direct suppliers and support more targeted human rights due diligence across our extended supply chain.

• Enhancing supplier engagement: Engaging independent in-country expertise to provide targeted support to suppliers where additional guidance or intervention can strengthen working conditions and worker wellbeing.

• Improving corrective action and remediation: Working collaboratively with suppliers to address identified non-compliances, monitor progress and support sustainable improvements.

• Embedding responsible purchasing practices: Continuing to strengthen internal awareness and training to help ensure commercial decisions support responsible working conditions.

• Strengthening worker voice: Exploring opportunities to improve access to effective worker feedback.

These measures will support the continued development of our human rights due diligence programme, enabling us to direct resources towards areas of greatest risk and prioritise positive outcomes for workers.

Compliance + Policies

We believe everyone in our global supply chain deserves the rights and protections as set out in the ETI Code of Conduct. This Code underpins our Ethical Trading strategy, which includes supplier monitoring and auditing. All ME+EM suppliers must adhere to our CSR policy in full, which includes the following declarations:

• CSR Declaration and latest Audit

• Animal Testing and Animal Welfare Policy and Declaration

• Code of Conduct Policy and Declaration

• Forced Labour and Human Trafficking Policy and Declaration

• Cotton Sourcing Policy and Declaration

• Anti-Bribery policy and Declaration

• Restricted Substances Policy and Declaration

• Data Protection Policy and Declaration

We prohibit sourcing from the Xinjiang Uyghur Autonomous Region and are part of the Coalition to End Forced Labour in collaboration with Anti-Slavery International. We demonstrate our commitment to best practice and responsible sourcing through our collaboration with recognised industry bodies and adoption of their standards. To strengthen traceability and risk management, we are members of the Leather Working Group (since 2022) and Textile Exchange (since 2023), achieving the Responsible Animal Fiber certification. We also expanded our use of certified materials by becoming members of the Good Cashmere Standard (since 2025)

We review auditing dashboards monthly at leadership level. Any evidence of human rights violations would be escalated to the board with recommended actions. Our priority is protecting workers, whether by working with suppliers on remediation or, where necessary, responsibly ending relationships.

We actively mitigate risk through a structured, proactive strategy. Following audits, we enforce a strict follow up process, requiring prompt acknowledgment and remediation of any non-compliance. We maintain strict control of our supply base, particularly in China and Turkey. Oversight is reinforced by our Product and CSR teams, who integrate risk assessments into every site visit, while monthly risk updates ensure direct senior management accountability. We prioritise transparency and supplier engagement through regular communication and feedback.

Vulnerable Worker Groups

We recognise that specific groups, including migrant, refugee, female, and temporary/subcontracted workers, face heightened risks of modern slavery, often exacerbated by seasonal production pressures.

For migrant workers in our top 5 manufacturing countries (Portugal, China, Italy, Turkey, India), we actively collect and analyse audit data to monitor worker representation and robust HR practices.To mitigate risks for temporary and subcontracted workers, we are proactively mapping subcontractors beyond Tier 1 and investing in traceability platforms. We enforce strict controls by requiring prior approval for all third-party sites and are partnering with independent in-country CSR consultants to enhance oversight, ensuring suppliers responsibly manage their production capacity.

4 | 2025-2026 Achievements + Activities

Our Achievements

Activity Highlights

Leather Supply Chain Mapping

ME+EM partnered with Eurofins to undertake a targeted mapping exercise across our leather supply chain, covering clothing, footwear and accessories. The project has strengthened supplier engagement, improved traceability back to source and increased visibility of potential risks within lower tiers of our supply chain. This work has also laid important foundations for the adoption of Textile Genesis and the next phase of our supply chain traceability programme.

Turkey: Enhanced in-Country Due Diligence

Recognising Turkey as a priority sourcing region, we engaged independent in-Country CSR expertise to undertake targeted supplier assessments beyond traditional social auditing. This approach has enabled us to gain deeper insight into working practices, identify root causes of non-compliance and provide suppliers with practical guidance and tools to support meaningful, longer term improvements for workers.

Escalation ProcedureWe have implemented a comprehensive escalation procedure for identifying and addressing human rights risks, ensuring all issues are managed according to their severity and urgency.

Buying Team EngagementIn 2025-2026 we implemented 1:1 meetings between Senior Buyers and the Ethical Trade Manager to ensure full visibility of our supplier base. These sessions proactively identify risks, review sourcing changes, and align our buying teams on human rights due diligence.

Our Programme in ActionTo date, we have received no reports of modern slavery through our internal grievance or whistleblowing procedures from ME+EM employees. In 2025/2026, we achieved 100% audit visibility across our active supplier base. While this process has not uncovered evidence of modern slavery, we remain vigilant. In the coming financial year, we are developing enhanced KPIs to monitor the effectiveness of our human rights initiatives, with a specific focus on training and supplier engagement. Our approach is fundamentally rooted in partnership. We actively support our suppliers by subsidising audit costs and providing guidance throughout the remediation process, demonstrating our dedication to continuous improvement. Compliance is an ongoing evolution, and we are continuously refining our due diligence frameworks to detect indicators that might otherwise be hidden, reinforcing our absolute zero-tolerance stance.

This 'beyond audit' approach has been essential in identifying risks. We are committed to continuing these independent expert assessments throughout 2026–2027 as a core part of our due diligence and support processes for suppliers who need extra help to improve.

Reflections + Learnings

Whilst we have made significant progress in enhancing supply chain visibility and risk mitigation, we recognise that our journey toward full transparency is complex and that systemic challenges remain. We treat these vulnerabilities with the utmost seriousness, maintaining a continuous commitment to the rights and wellbeing of all individuals in our global supply chain. Informed by the insights gained this year, we have embedded a robust, long term strategic roadmap designed to proactively identify, manage, and address these risks, ensuring our continuous evolution towards increasingly responsible and sustainable business practices.

ME+EM has made a significant strategic investment in Textile Genesis, a digital supply chain mapping and traceability platform, to support the next phase of our traceability and transparency and transparency programme, strengthening visibility across our supply chain and enhancing our ability to identify, assess and manage potential human rights risks.

5 | Training & Communication

Responsible Purchase Practice Training

In April 2026, we partnered with the Ethical Trading Initiative (ETI) to train our buying team on responsible purchasing practices. This session examined supplier relationships, extreme heat impacts, and just transitions, providing our team with frameworks and action plans to mitigate exploitation risks. We are currently evaluating 2026–2027 training options to further empower our teams to embed ethical considerations into every decision.

Just Transitions

Recognising extreme heat’s growing impact on our supply chain and workers, we hold meetings with key factories to understand their challenges and foster information sharing. To build our expertise and optimise our support, we regularly attend related webinars and in-person sessions, including the ETI’s Accelerating just transition in fashion workshop during London Climate Action Week.

Communication

Communication is central to our zero tolerance approach. In Q4 2026, we will implement our redeveloped supplier manual, featuring a dedicated CSR section to strengthen our standards and expectations. Internally, our CSR team ensures human rights remain a priority through regular sharing of audit results, risk alerts, and our new internal CSR newsletter. Externally, we foster strong, long-term supplier relationships, some spanning over 15 years, through open dialogue, performance reviews, and site visits that serve as both assessment and training opportunities.

6 | 2026-2027 Objectives + Targets