WH Smith PLC Modern Slavery Statement 2024/2025 Introduction
This is WH Smith PLC's (WHSmith)'s tenth annual statement published in accordance with the Modern Slavery Act 2015. This statement is also published in accordance with the Australian Modern Slavery
Act 2018, Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act 2023 and the California Transparency in Supply Chains Act 2010.This statement outlines the steps we have taken to prevent modern slavery in our operations and supply chain for the financial year
1stSeptember - 31 August 2025.
Modern slavery, including all forms of slavery, servitude, forced and compulsory labour and human trafficking are abhorrent practices that continue throughout the world today. WHSmith is committed to ensuring that the human rights of anyone working for us in any capacity are fully respected. We recognise we have a responsibility to prevent modern slavery, and to mitigate and remediate cases where necessary, and we have zero tolerance for any cases of human rights abuses in our business operations or supply chains.
This year we made progress in strengthening our approach, which includes:
The supplier onboarding process for the Travel UK and International (Rest of the World) divisions has been updated to request information on supplier policies and processes at the earliest stage. This means that all trade suppliers for these divisions are being assessed for potential risks prior to placing orders.
Continuing our work to extend our Worker Representation project with 20 per cent of own brand suppliers now included in the initiative.
Developing our due diligence processes for non-trade goods and services by incorporating ethical trade and broader sustainability questions into the tender process. Next year, this will be extended to include questions relating to Diversity, Equity and Inclusion.
This statement sets out the steps taken to prevent slavery and human trafficking in the operations and supply chains of all subsidiary companies included within our financial statement for the year
2024/25 including WH Smith Travel Limited, WH Smith Hospitals Limited, WH Smith North America Inc and WH Smith Australia Pty Ltd. Measures taken in respect of WH Smith Retail Holdings Limited and WH Smith High Street Limited have been included in this statement prior to the sale of the High Street business on 29thJune 2025 and for Funky Pigeon Limited prior to its sale on 14thAugust 2025. The statement was approved by the Board of WH Smith PLC on 2ndFebruary 2026.
Andrew Harrison
Interim Group Chief Executive, WH Smith PLC Date: 2ndFebruary 2026
Our Business Operations WHSmith is a leading global travel retailer for travel essentials with a presence across more than 30 countries. Following the divestment of our High Street and Funky Pigeon businesses, we have established a platform for long-term growth as a pure-play global travel retailer. We operate across three divisions, directly employing over 9,000 colleagues:Travel UK is the largest division in the Group and operates stores in a range of locations, including airports, hospitals, railways stations and motorway services areas. Our strategy is to become a one-stop-shop for travel essentials across UK transport hubs, supporting customers on their journeys. We sell a range of travel essentials including food and drinks, health and beauty, books, magazines, digital accessories and souvenirs. This year, we have enhanced and expanded our Smith's Family Kitchen offer with an expanded meal deal proposition and an enhanced hot food and coffee range. As of 31st August 2025, Travel UK operated from 593 stores.
As the world's largest travel retail market, North America is our most exciting opportunity for growth. We serve customers a wide range of products through a diverse portfolio of stores in major airport hubs across North America, including food and drinks, news, gifts, local souvenirs and travel accessories. We operate under our own brands such as District Market, Flight Stop, Lick, Marshall Rousso and Root & Branch and an extensive array of franchised stores including Tom Ford, Lego and Harley Davidson. Our InMotion brand provides digital products including a wide range of headphones, mobile power devices, Bluetooth speakers and travel accessories. As of 31stAugust 2025, we operated from 362 stores in the United States and Canada.
Our Rest of the World division is focused on growing and building scale in strategically important markets, particularly in Australia, Ireland and Spain, whilst actively managing our store portfolio in our other markets thorough Europe, the Middle East and Asia. As of 31stAugust 2025, we had 325 stores with approximately 60 per cent directly operated by WHSmith, 10 per cent operating as joint ventures and 30 per cent operating under a franchise model. Further details of international locations, including the numbers of stores in each country, can be found on our website.
Our Supply Chain WHSmith rely on over 3,000 suppliers to provide trade products, goods not for resale and services. Suppliers range from large multi-national companies to small and medium sized enterprises.Purchasing and supply chain management are led by a team of buyers based predominantly in the UK, USA and Australia supported by a procurement and ethical trade team based in Hong Kong and Shanghai.
Own brand products
We work with over 140 suppliers who provide our own-brand products, including food ranges, technology products, stationery and other travel accessories. The vast majority of suppliers for our own-brand goods are based in China, and we also source a small number of products from factories in Bangladesh, Egypt, India, Indonesia, Philippines, South Korea, Taiwan, Turkey and Vietnam. Our current factory list is available on our website and on Open Supply Hub. Chilled food is sourced locally within our countries of operation. We have the strongest relationships, and most influence, with our top 20 suppliers by value, where we buy a larger proportion of their supply and tend to have longer-term commercial relationships. Outside of this supply base, we tend to be a comparatively small
customer, buying relatively limited quantities. Our ability to influence activity with these suppliers is more limited.
We continue to grow our own Smith's Family Kitchen brand of food-to-go products, using a small number of familiar suppliers. Due diligence includes reviewing policies on modern slavery and labour
rights and checking suppliers' processes for audit and engagement of their supply chain. As we expand our product offering further, due diligence is included at the first stages of onboarding for new suppliers to ensure our Responsible Sourcing Standards are accepted and adopted.
Third party branded products
Over 1,500 suppliers provide third-party branded products, ranging from large multi-national brands to small enterprises, with complex global supply chains involving thousands of businesses. The suppliers we work with source from across the world, but principally from the United Kingdom, China, the US, Australia, Germany and Vietnam. Products include food and drinks, books, newspapers and magazines, cards, stationery, health and beauty and technology products.
Procurement (non-trade)
We have over 1,500 suppliers of non-trade services and goods not for resale, which include IT equipment, store fixtures and fittings, professional services, transport and logistics, staff uniforms and cleaning services.
Governance and policy frameworks We have a well-developed set of policies and processes to protect the human rights of those who work for us, either directly in our operations, or indirectly through our business partners and in our supply chains. These policies and processes include measures to prevent modern slavery. We will not tolerate any abuse of human rights, including any form of slavery, anywhere in our business, supply chains or partnerships.WHSmith is committed to respecting human rights in our business operations and supply chain as set out in the United Nation's Universal Declaration of Human Rights; the United Nation's Guiding Principles on Business and Human Rights; and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work.
Our governance framework
The WHSmith Board oversees the governance of sustainability issues, including those relating to modern slavery and wider human rights. The Group Board has ultimate responsibility for modern slavery and receives updates on the effectiveness of risk management and controls at least once per year. The Environmental, Social and Corporate Governance (ESG) Board Committee leads and oversees delivery of our sustainability strategy, setting out our ambition and monitoring progress. The Committee is responsible for understanding the potential impact and related risks of ESG
considerations on the business. It approves the Company's sustainability strategy - including those components relating to human rights and responsible sourcing policies; objectives and the roadmap for delivery; and monitors progress against agreed targets. The ESG Committee meets at least three times per year.
The Group Audit Committee is responsible for governance in respect of company systems for internal controls, business risks and related compliance activities. This includes any principal risks relating to human rights. The Group Executive Committee has overall accountability to the Board for sustainability issues, including those relating to modern slavery.
An ESG Steering Group chaired by the Group Chief Executive and including the Managing Directors of each business, the Group Chief Financial Officer, the Group Communications Director and the Sustainability Director meets monthly to review progress and next steps for all ESG work, including our human rights strategy and modern slavery work.
As part of WHSmith's risk management processes, detailed risk registers are maintained by each business and used to identify, manage and monitor risks. Business Risk Committees meet quarterly and monitor action plans for measures to prevent modern slavery or associated risk issues in business operations and supply chain.
Modern slavery risks and the measures taken to mitigate those risks are co-ordinated by the Sustainability Director, who also leads the development of policies, processes and wider activities to prevent modern slavery across our businesses and supply chains.
Policies and standards
Our policy framework includes a number of group-wide standards relevant to protecting human rights and preventing modern slavery, all of which are reviewed annually by our Board-level ESG Committee.
One of WHSmith's core values is 'Value our People' and we try to ensure that all colleagues are valued and respected in an open and honest environment. Our Code of Business Conduct sets out how our business operates, and what is expected of every person who works for and on behalf of WHSmith.
This includes WHSmith employees, directors, contractors, subsidiaries, joint ventures, suppliers, franchisees, agents, consultants and professional advisors.
Our Code of Conduct makes it clear that we will not tolerate any form of discrimination, harassment or bullying. In support of this Code of Conduct, we have additional policies covering equality and diversity, dignity at work, grievance mechanisms and whistleblowing.
Our Human Rights Policy emphasises our commitment to respecting the human rights of our employees, those working for our suppliers and business partners, and our customers and the communities in which we are based. It sets out our values, principles and monitor procedures for each of our stakeholder groups and includes those linked to grievance mechanisms and access to remedy.
Expectations for suppliers and business partners are set out in our Responsible Sourcing Standards which are aligned to the Ethical Trading Initiative's (ETI's) Base Code. These Standards provide further clarification on our expectations regarding modern slavery controls, including restrictions on the withholding of identity documents and payments of deposits, additional information on verification checks for child labour and steps to prevent excessive working hours. We also stipulate that no worker should have to pay a fee or other deposit for a job and include specific policy requirements aimed at protecting migrant workers, agency staff and female workers.
We continue to support industry-wide initiatives and are a signatory to the British Retail Consortium's Better Retail, Better World actions, which commits the retail industry to build a fairer, more sustainable economy in line with the UN Sustainable Development Goals, including promoting decent work for all.
Embedding our policies
All employees are expected to re-appraise themselves of the requirements of Our Code of Business Conduct and associated policies covering modern slavery risks on an annual basis and certify that they have done so. The Code of Business Conduct is also included in induction material for all new starters. We expect our staff to have completed a number of essential training courses relating to responsible commercial practices, including risks from modern slavery.
We regularly refer to the requirements of our Code of Business Conduct and Responsible Sourcing Standards through our dialogue and engagement with suppliers, business partners and franchisees. WHSmith's joint venture and franchise partners are required to provide written confirmation of compliance with our policies every year. Our Responsible Sourcing Standards are included in all standard supplier contracts and agreements. Potential new suppliers are informed of our Responsible Sourcing Standards during the tender process so that they can take our requirements into account when quoting for the provision of goods or services. Any potential new supplier of our own-brand products is audited by our in-house, specialist ethical trade team before any order is placed.
Own-brand products: suppliers are required to notify WHSmith of any non-compliances with our Responsible Sourcing Standards. We audit suppliers of our own-brand products at least every two years and have processes in place to support remedy with any non-conformances and drive continual improvement. Audits are primarily conducted by our in-house, specialist teams based in Hong Kong and Shanghai, who make specific checks on modern slavery as part of their processes. The team