Boux Avenue Modern Slavery and Human Trafficking Statement 2025

This statement is published in accordance with section 54 of the Modern Slavery Act 2015 and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. It sets out the steps taken during 2024/25 by Boux Avenue Limited (“Boux Avenue”), having its registered office at Kindred House, 17 Hartfield Road, London, United Kingdom, SW19 3SE, and company number 07191520.

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Modern slavery includes slavery, servitude, human trafficking, and forced labour. It is recognised that this is a global and growing issue that can exist in all economies and business sectors. The Modern Slavery Act is an important piece of legislation which seeks to provide protection to vulnerable workers, respect their human rights, drive transparency throughout the supply chain, and ensure the supply chain is both slavery and trafficking-free. As responsible retailers, Boux Avenue is fully committed to acting ethically and with integrity. We are also committed to putting effective systems and controls in place within our organisation, and continually improving our processes, to ensure we prevent any form of modern slavery and human trafficking from taking place within our business and supply chains. This statement sets out the actions we have taken, and continue to take, during the financial year ending 29 March 2025.

We are a trusted multi-channel brand focused on delivering outstanding customer service and first-class product knowledge. We strive to trade with the best quality suppliers who uphold the highest social and ethical standards and who make available the highest quality products and services for our business and valued customers. Our products and services are sourced globally via the 24 suppliers we engage with, across 50 factories spanning seven countries, including Morocco, Turkey, the Indian subcontinent, and Asia.

As a responsible retailer, we are committed to the continual improvement of our systems and processes and strive to ensure modern slavery does not exist within our business or supply chains. Our Code of Conduct aims to uphold internationally agreed standards of labour, in particular those set by the Ethical Trading Initiative (ETI). It sets out our commitment to:

• Freedom to choose employment

• Freedom of association and collective bargaining

• Safe and hygienic working conditions

• No child labour

• Payment of a living wage

• No excessive hours

• No discrimination

• Regular employment

• No harsh or inhumane treatment

We expect those in our supply chain to respect the rights and wellbeing of their workforce and to promote high standards of welfare. The implementation of our Code is monitored through regular checks of supplier services and factories by our agents and third parties.

We pride ourselves on having long-standing relationships with a large number of carefully selected suppliers who produce some of the most prominent brands within the sector and who provide services (including contract and temporary labour) to our business. We are committed to making sure all colleagues involved in the sourcing and production of our products and services are safe and treated fairly at all times. It is also our aim to source from factories and suppliers who share this commitment.

Our suppliers are expected to adhere to our Supplier Code of Conduct, which reflects our commitment to striving to ensure that slavery and human trafficking are not taking place within our supply chains. We request copies of our preferred and new suppliers’ anti-slavery policies to ensure they align with our principles and Code of Conduct. We continue to monitor suppliers, including carrying out factory audits through our agents and approved third parties. We work with suppliers to identify issues and develop improvement plans where required.

As part of our efforts to monitor and reduce the risk of slavery and human trafficking within our supply chains, we have adopted various due diligence procedures, as outlined in the following section. Our procedures are designed to:

• Establish and assess areas of potential risk in our business and supply chains;

• Monitor potential risk areas in our business and supply chains

• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

We are proud to put our name and branding on our range of uniquely designed, high-quality products. Our due diligence processes are designed to demonstrate our commitment to ensuring there is no slavery or human trafficking in our supply chain. We track all factories producing and packing our branded products in terms of audit status and factory grading. We expect, and obtain confirmation, that suppliers of each of our products, and suppliers of services to our business, adhere to our Supplier Code of Conduct.

We adhere to a strict supplier on-boarding process. As soon as a potential new supplier has been identified by one of our buyers, our technical team is informed. They then request an independent audit from the factory the supplier intends to use, to ensure the rights of workers are upheld.

We adhere to a strict supplier onboarding process. Once a potential new supplier is identified by one of our buyers, our technical team is informed. They then request an independent audit from the factory the supplier intends to use, to ensure the rights of workers are upheld.

Factory audits are extensive and are reviewed by our technical team upon receipt to ensure adequate practices are in place. Our technical team has the authority to confirm whether an audit meets expected standards. We recognise audits that meet standards relating to, but not limited to:

• SMETA (Sedex Members Ethical Trade Audit, based on the ETI Base Code)

• AMFORI (formerly BSCI – Business Social Compliance Initiative, based on SA8000)

• WPAP (Worldwide Responsible Accredited Production Certification)

• BUREAU VERITAS (PAS)

SMETA and AMFORI audits with minor or no non-conformances are valid for two years. When audits are due for renewal, we ask our suppliers to submit a renewed audit for review

Before our technical team can approve a new supplier, the factory audit provided must have no “critical issues” outstanding, and the supplier must also provide notice of any past compliance issues. Furthermore, no purchase orders can be raised by our buyers until an approved, up-to-date, and satisfactory audit has been provided to our technical team. Once an audit is deemed satisfactory and approved, our technical team will proceed with completing the remaining technical processes, which include quality and fit assessments, before the onboarding process is complete.

Our suppliers are expected to keep a portfolio evidencing their manufacturers’ compliance, which must be available for scrutiny within 24 hours’ notice.

We have developed an in-house eLearning course to ensure all colleagues are aware of, and have a better understanding of the risks of modern slavery and human trafficking. All of our store colleagues are required to complete our basic awareness eLearning course every two years, whilst our retail support centre colleagues must complete this annually. Our trading and buying colleagues are required to complete our specialist version of the course on an annual basis. Modern Slavery awareness is also included as part of colleague inductions and the relevant eLearning course is assigned to all new starters. Additionally, our BUREAU VERITAS supplier website hosts regular webinars that can be accessed by our colleagues and suppliers.

Modern slavery awareness is also included as part of colleague inductions, and the relevant eLearning course is assigned to all new starters. Additionally, our Bureau Veritas supplier website hosts regular webinars that can be accessed by our colleagues and suppliers.

Completion rates are monitored and overdue training is followed up.

We understand that tackling modern slavery requires ongoing assessment of our business and supply chain to continue minimising the risk of its occurrence. We will continue to work towards reducing risks within our business in the coming year. To do this, we plan to review the following key areas:

• Governance: Continued development of our Corporate and Social Responsibility governance framework, including a review of modern slavery governance to build focus and clear action planning for the future

• Learning and Development: Maintain awareness across all areas of the business through training for colleagues at all levels.

• Policy review: Review, improve, and develop systems and processes to ensure that our supply chain adheres to our principles and values, including an ongoing review of our Code of Conduct to ensure it is fit for purpose and effective.

• Risk Mitigation and Audit compliance: Review and improve our due diligence and selection process for new suppliers to ensure they, and their supply chains, adhere to our Code of Conduct.

Approval

This statement was approved by the board of Boux Avenue Limited.

Kirsten Lawton

Director and Group Company Secretary

30th September 2025