Modern Slavery Statement 2025

Docusign Envelope ID: 7673327F-00E7-4A0A-81E7-BDDBE80055B1

MODERN SLAVERY STATEMENT

MODERN SLAVERY STATEMENT / SEPTEMBER 2025

OCTOBER 2 0 2 5

Docusign Envelope ID: 7673327F-00E7-4A0A-81E7-BDDBE80055B1

CONTENTS

STATEMENT FROM DAN FINLEY

At Debenhams Group1, we are committed to upholding high standards oṪ ethical trade, responsible sourcing, and the protection oṪ human rights across our operations and global supply chain. Reducing the risk oṪ modern slavery and human traṪficking remains a core component oṪ our corporate responsibility agenda.

We acknowledge the complex and oṪten hidden nature oṪ modern slavery, which can include Ṫorced labour, child labour, debt bondage, and the exploitation oṪ migrant and vulnerable workers. We maintain a zero-tolerance approach to any Ṫorm oṪ modern slavery-whether within our own business or among those who supply or work on our behalṪ.

Debenhams Group source Ṫrom all over the globe and with this international Ṫootprint comes the responsibility to ensure robust oversight and continuous improvement across all tiers oṪ our supply chain. During the 2024/25 financial year, we strengthened our ethical governance through several key initiatives:

Continued support for the International Accord framework, reinforcing our commitment to collaborative action on worker safety, labour rights, and supply chain accountability in

high-risk sourcing regions.

Implementation of the Segura digital platform, to enable greater supply chain transparency through enhanced traceability, compliance mapping, and data-driven risk analysis.

The expansion of our Ethical Compliance team internationally into key sourcing regions, to support proactive monitoring, supplier capability building, and local remediation where needed.

MODERN SLAVERY STATEMENT / SEPTEMBER 2025

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These actions Ṫorm part oṪ our broader due diligence and ethical sourcing strategy, which includes regular risk assessments, third-party audits, capacity-building initiatives, and engagement with sector peers and multi-stakeholder platṪorms.

This Modern Slavery Statement is made in accordance with the UK Modern Slavery Act 2015, covering the activities undertaken during the 2024/25 financial year. It outlines the steps Debenhams Group, and its subsidiaries have taken to assess and address modern slavery risks as well as our ongoing commitment to responsible and ethical business practices across all sourcing regions.

This statement has been approved by the Board oṪ Directors oṪ Debenhams Group and is made on behalṪ oṪ Debenhams Group and its relevant entities.

Signed,

Dan Finley

ChieṪ Executive OṪficer

Debenhams Group

1(trading name oṪ boohoo group plc)

MODERN SLAVERY STATEMENT

Statement from CEO 2

Overview 3

Business overview 3

Supply Chains and Transparency 4

Supply Chain and Tier Mapping 4 - 5

Global Risks and Due Diligence 5 - 6

Auditing & Monitoring 7

Policies 7

Training 7

Goods Not for Resale 7

Governance 8

Whistleblowing 9

Industry Associations 9

Forward Look 9-10

Founded in Manchester in 2006, Debenhams Group is an inclusive and innovative brand, delivering fashion, beauty, and lifestyle for everyone. We continue to push boundaries to offer trend-led, inspirational products - anytime, anywhere."

Visit us online at: Home | Debenhams Group

@boohoo

boohoo

@boohoo.com

Docusign Envelope ID: 7673327F-00E7-4A0A-81E7-BDDBE80055B1

OVERVIEW

This Modern Slavery Statement (this "Statement") covers the financial year Ṫrom 1 March 2024 to 28 February 2025. It applies to the operations and product supply chains oṪ all Debenhams Group (hereinaṪter reṪerred to as "the group") brands and subsidiaries.

The group remains committed to upholding the fundamental human rights of workers who

manufacture our products across the globe and acknowledges the inherent risks associated with operating complex international supply chains, including poor labour practices, unsafe working conditions, the threat of modern slavery and human trafficking.

Our ethical sourcing strategy is designed to proactively address these risks while supporting the group's agile business model. The group work to ensure that workers are treated fairly and ethically, and that responsible practices are embedded throughout the group's sourcing process.

In 2024/25, the group continued to implement and strengthen a range of due diligence mechanisms, policies, and partnerships aimed at:

• protecting worker welfare and rights;

• identifying and mitigating modern slavery risks;

• enhancing transparency and traceability; and

• upholding a commitment to ethical trade across all of the group's sourcing regions.

  This statement outlines the actions the group has taken over the past year to address the risk of modern slavery within our business and supply chains. It further demonstrates our ongoing commitment to responsible sourcing, enhanced

  transparency and the continuous improvement of ethical practices.

  CONCEPT

• Designers

• Buyers

• Suppliers

SAMPLE INTO PRODUCTION

Turning an idea into a sample and then an order

PRODUCTION

Fabric is cut and sewn

REPEAT

Most popular items repeated

DELIVERED TO CUSTOMER

New items delivered to customers

BUSINESS OVERVIEW

The group comprises five core brands: boohoo, boohooMAN, PrettyLittleThing, Karen Millen and Debenhams. The group continues to invest strategically to support and grow these brands in markets and channels where it sees strong potential Ṫor value creation.

Originally founded as a single brand with significant growth across the UK and international markets, the group has evolved into a multi-brand platform, serving customers globally and generating sales in excess of £1.2 billion in FY 2024/25. During the same period, the group served over 11.4 million active customers.

We directly employ approximately 3,082 people across the group, with offices located in Manchester, London, and Shanghai. Our operations are supported by two UK-based distribution centres: Burnley and Sheffield.

The Group is currently undergoing a significant transformation, transitioning all brands to operate on the Debenhams marketplace platform. This strategic shift is part of our broader mission to connect people with the brands they love, leveraging the proven Debenhams model to shape the future of our business.

The decision to transition to Debenhams group refiects a clear strategic ambition: to build on the marketplace model's established success and extend its benefits across the entire group. This transformation is redefining how we engage with both customers and partners, in alignment with our vision: Fashion. Beauty. Lifestyle. For Everyone.

GOODS FOR RESALE

DEBENHAMS GROUP (MADE-TO-ORDER OWN-BRANDS AND LABELS)

This category covers Debenhams group products that are designed and commissioned by the group under its own brands and labels, and manuṪactured by selected suppliers on a made-to-order basis.

Goods for resale - Debenhams group products are produced by third-party suppliers and are sold through our direct platforms and wholesale partnerships. The group uses a test and repeat model which means that we purchase small runs of new stock and if our customers like them we order more. The supply chain for these brands spans 12 countries, encompassing 525 Tier 1 manufacturers and 407 suppliers. All partners within our supply chain are required to adhere to the group's code of conduct.

The group is determined to play its part in reducing the social impact of clothing and operations through increased focus on responsible sourcing, ethical practices, and upholding high standards of governance.

Debenhams group own-brands and labels are sourced Ṫrom:

GROUP BRANDS

5 Core Brands

ACTIVE CUSTOMERS

11.4 Million

SALES

£1.22 Billion

12

Sourcing countries

EMPLOYEES

4

MODERN SLAVERY STATEMENT / SEPTEMBER 2025

3082

OFFICES

3 Countries

UK DISTRIBUTION

2 centres

525

Tier 1 Manufacturers

407

Suppliers

Docusign Envelope ID: 7673327F-00E7-4A0A-81E7-BDDBE80055B1

OVERVIEW -

SUPPLY CHAINS AND TRANSPARENCY

We source products Ṫrom Ṫactories in the UK, Europe, Asia and AṪrica.

Amongst the 525 factories that we work with globally, we have a mix of small family run facilities, to much larger high-volume units within excess of 5000+ workers. We share a number

of these factories with multiple global retailers. A key benefit of this crossover is collaboration across retailers in improving factory standards globally. As a group we commit to publishing our global supply chain every 4 months, we have

published our supply chain on our group PLC site since September 2021, see link below.

Debenhamsgroup_globalmanuṪacturinglist

We source from 12 countries. Our top 7 sourcing countries by volume are China, Pakistan, UK, Morocco, India, Turkey and Bangladesh.

MAP OF THE WORLD WITH 12 REGIONS HIGHLIGHTED**

**Out of reporting period

**Correct at 27th August 2025

SUPPLY CHAIN AND TIER MAPPING

The table below outlines how the group define each tier within the supply chain. Although industry definitions may vary, we are committed to clearly communicating our approach to improve understanding and accountability.

As part of our ongoing commitment to transparency, the group have partnered with a third-party supply chain management platform to help us map our global supply chain down to Tier 4. This deeper level of visibility enables us to better identify risks and drive responsible sourcing practices across all levels of our supply chain.

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MODERN SLAVERY STATEMENT / SEPTEMBER 2025

APPAREL SUPPLY CHAIN TIER DEFINITIONS

Docusign Envelope ID: 7673327F-00E7-4A0A-81E7-BDDBE80055B1

FOOTWEAR TIER MAPPING DEFINITIONS

The group has now introduced an updated tier-mapping framework specific to our footwear supply chain. This enhanced structure recognises the complexity of footwear production and enables us to assess and manage risks more effectively across each level of the supply chain

The updated definitions are outlined below:

THIS TIERED FRAMEWORK SUPPORTS INCREASED VISIBILITY AND TARGETED DUE DILIGENCE BY ALLOWING US TO:

• Map multi-tier supplier relationships using supply chain management tools such as Segura.

• Prioritise audits and assessments where the risk of labour exploitation is highest.

• Engage more effectively with suppliers on traceability and responsible sourcing requirements; and lay the groundwork for improved data collection and reporting in future statements.

We will continue to build upon this tiered model across additional product categories, applying lessons learned from footwear to support a consistent and robust approach to ethical sourcing and modern slavery risk mitigation.

Global Risks and Due Diligence

We recognise there are salient human rights risks in the countries we source from that vary by location. It is imperative that we reduce the risk of modern slavery and child labour and protect vulnerable groups such as female and migrant workers. With our top sourcing countries taking priority, we will focus on the most severe and likely issues when working with factories supplying the group.

Due Diligence

As part of our global risk and due diligence assessment we have an on-boarding process for all new suppliers that join the group. Each audit report for Tier 1 factories is reviewed by the Ethical compliance team along with corrective action plans and evidence of any non-compliance remediation.

MODERN SLAVERY STATEMENT / SEPTEMBER 2025

MODERN SLAVERY STATEMENT / SEPTEMBER 2025

Our global on the ground Ethical compliance team visit our factories and suppliers in region, conducting unannounced spot checks, purchase order verification visits along with health and safety, wages and working hours and documentation checks.