Marshalls : Modern Slavery Statement 2021

End

Modern

Slavery

Marshalls plc

Modern Slavery Statement

2021

Introduction

We do the right things, for the right reasons, in the right way

This is The Marshalls Way of doing business

Martyn Coffey

Marshalls' Chief Executive

June 2021

This, Marshalls' sixth Modern Slavery Statement, has full Board approval and its unreserved commitment to continue to do all that we can as a national business with an international supply chain to demonstrate what can be done by the private sector, and to leverage the entirety of our value chain to eliminate modern slavery.

We aim to encourage other organisations in our sector to fully engage, to share what we know and have found to be effective, to offer our collateral at no cost to others, to share our challenges, to be open to learning, to lead and support innovative approaches and to identify risks. We also want to lead the way and speak out when instances of modern slavery are found.

We recognise as a Board that for some of the most vulnerable in our society and in our supply chains, the events of the last 18 months have put them in a position of increased vulnerability and further exposed them and their families to exploitation. The pandemic has meant that human rights and modern slavery are firmly at the top of our own agenda like never before, and rightly so.

We have a robust and far-reaching Business & Human Rights Roadmap to 2030. We are clear what this means for us in terms of concrete actions in the coming 12 months. We have total alignment across our business to ensure that we do all that we can to eliminate modern slavery in all of its forms. Internal drive, challenge and desire are strong and our message is clear; we are focused upon building knowledge, confidence and respect for human rights. Our people are fully engaged, and the Board is clear that we always say 'no to modern slavery'.

Highlights from the past 12 months at a glance

• Reviewed, revised and strengthened our sustainable procurement human rights due diligence system and our processes.
• Continued to ensure that all of our employees are exposed to modern slavery awareness training - specifically how to spot the signs and how to report, and our stance and policies.
• Continued to deepen our engagement with suppliers with higher risk supply chains, and in higher risk geographies - working in five geographies to roll out a grievance mechanism and develop an IT platform for live monitoring providing real-time information.
• Continued to actively engage with the UN, ILO Child Labour
  Platform, UK Government, overseas governments, international business associations and bodies on the issues of modern slavery.
• Worked in partnership with Crimestoppers on the delivery of the #slaveryonyourdoorstep campaign, making the entirety of our transport and logistics 'spot and report' collateral free to use for other businesses, as well as the production of an associated podcast featuring experts in the field, blogs and articles - all to raise the awareness and reporting of modern slavery.
• Continued to provide intelligence to law enforcement in the UK, including the Gangmasters & Labour Abuse Authority ("GLAA"), local law enforcement, the Modern Slavery Helpline and
  via Crimestoppers.
• Maintained our Power of Logistics transport and logistics initiative by undertaking a second wave of training, and also engaging two of our biggest suppliers to join forces - Tarmac and Hanson - as well as other independent organisations such as Freight Line International.
• Published our Modern Slavery Country Risk Mapping for 100% of our business operations and supply chains and making this publicly available.
• Undertaken advanced supply chain mapping for 100% of our natural stone highest risk supply chains, working in partnership with Traffik Analysis Hub.
• Implemented an independent Modern Slavery Threat Assessment programme throughout our UK operations, which includes 52 sites/locations.
• Undertaken an independent internal investigation for one of our highest risk suppliers in the UK in the waste and recycling sector.
• Continued to actively engage with UK Government and associated bodies to address root causes of modern slavery.
• Continued to work with Bright Future, and to be a founding member of its co-operative status, offering work opportunities to victims of modern slavery in the UK.

Contents

1. Areas of activity
2. How Marshalls does business

UK Modern Slavery Act 2015

6 I. The organisation's structure, its business and its supply chains

1. II. Policies in relation to slavery and human trafficking
2. III. Due diligence processes in relation to slavery and human trafficking in its business and supply chains

1. IV. The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk
2. V. Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measures against such performance indicators as it considers appropriate
3. VI. The training available to staff
4. More information

Find out more about Marshalls at: marshalls.co.uk/about-us

All of this activity is documented in detail in our 2021 End Modern Slavery Report. Download it at:

marshalls.co.uk/sustainability/ modern-slavery

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Modern Slavery Statement 2021

Areas of activity

As shared in our previous Modern Slavery Statement, as a result of the global pandemic, we have reviewed all aspects of our business and human rights programme to address the increased vulnerabilities of many within our business operations and supply chains. As a result we have revised, enhanced and expanded our focus areas and activities for the next 12 months - these constitute our key performance indicators.

	Focus	Activity for the coming 12 months
Strategic	›	Develop/support/engage in strategic	›	Active and deepened engagement with the ILO Child Labour Platform.
collaboration		collaborations/partnerships/initiatives	›	Delivery of our UN International Year for the Elimination of Child Labour
to accelerate		to identify, prevent and mitigate		Action Pledge ("IYECL") .
	human rights abuses in Marshalls'
the eradication		own business operations and global	›	Co-Chairing of UK Government Modern Slavery Training Delivery ("MSTD")
of modern		supply chains; build knowledge,		sub-group focusing upon construction, transport and logistics.
slavery		capacity and facilitate engagement	›	Active engagement with the UNGC PACE investor initiative focusing on the
		from/with the wider construction		worst forms of child labour.
		sector and across sectors,	›	Continue to work with Traffik Analysis Hub to further develop its supply chain
		as appropriate.
			mapping programme, and to engage the private sector.
			› Continue to engage with the Dutch and Flemish Government's responsible
				production and purchase of natural stone initiative, TruStone.
			› Support the work of Crimestoppers regarding transport and logistics and
				spot and report.
			› Support and engage in the work of CCLA Find it, Fix it, Prevent it investor initiative.
			› Establish an internal Business and Human Rights Accelerator Group to aid
				the embedding, implementation and delivery of the BHR Roadmap to 2030.
			› Engage with universities to support and facilitate research regarding modern
				slavery and human trafficking.
Remediation	›	Implement appropriate remediation	›	Review and strengthen our process of remediation and support for 80% of the
and support		action to ensure that victims of		supply chain identified as high risk, by volume of product for natural stone.
for victims/		modern slavery, identified within our	›	Continue to actively engage with Bright Future - work placement/job
	own business operations and supply
		programme for survivors of modern slavery in the UK.
survivors		chains, can access the appropriate
	›	Increase in-country presence and live monitoring.
		support, and that we offer support
		more widely as appropriate.
Human rights	› Continuously improve our human	›	Roll out of enhanced human rights due diligence ("HRDD") supplier systems
due diligence		rights due diligence systems and		and processes.
systems		processes, and encourage the	›	Further refinement of our supplier risk analysis and resulting action following
	identification of instances of modern
		Slavery and Trafficking Risk Template ("STRT") implementation.
		slavery - taking appropriate action to
		›	Advanced supply chain network mapping - against global human trafficking
		report and also to ensure that the
			data - for all high risk suppliers.
		most vulnerable are not further
		adversely affected.	›	Continue with specific work regarding Chinese suppliers in relation
				to forced labour.
			› Further progress with our enhanced Modern Slavery Risk Assessment
				programme across UK business operations.
Effectiveness	› Report on our efforts and	›	Roll out the Safecall whistleblowing hotline in high risk geographies for
in identifying		effectiveness in helping to ensure that		natural stone.
and preventing		modern slavery and human trafficking	›	Roll out live monitoring in high risk geographies for natural stone, by volume.
	is not taking place in our business
slavery		operations and global supply chains.	›	Expand the advanced supply chain network mapping to assist with
				prevention and identification.
Reporting on	› Report on our efforts to address the	›	Continue to share with appropriate stakeholders, agencies, authorities,
efforts to		root causes of salient human rights		platforms and associations, our research, findings and insights as a result of
address root		issues; child labour, bonded labour,		our activity with UN partners, NGOs and others.
	prison labour and forced labour.	›	Continue to engage with governments to provide evidence and intelligence,
causes
			and to push for mandatory HRDD and the engagement in private sector efforts.
			› Work to deliver the 'Guiding Framework' within our IYECL Action Pledge.
Delivery of	› Enhance, develop, shape and deliver	›	Bespoke training for HR, procurement, operations and environmental teams.
modern slavery		modern slavery training which	›	Knowledge partner accelerator programme with internal colleagues.
training, and its		empowers and assists internal	›	Roll out of modern slavery and ETI training in four languages.
	decision making in support of human
impact		rights, and increases the reporting of	›	Continue to actively engage with the MSTD Group.

instances of modern slavery.

› Active engagement in the development, shaping and delivery of modern slavery training in the UK - across sectors - using IT.

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Modern Slavery Statement 2021

How Marshalls does business

The Marshalls group of companies (including Marshalls plc and its direct and indirect subsidiaries, referred to in this Statement as "Marshalls"), wherever it operates around the world, is committed to conducting business with honesty and integrity; in treating all people with dignity and respect and in complying with applicable laws, regulations and treaties.

Marshalls is also committed to protecting and promoting human rights globally. Marshalls does not tolerate child labour, forced labour, including prison labour, or any use of force or other forms of coercion, fraud, deception, abuse of power or other means to achieve control over another person for the purpose of exploitation.

Marshalls respects international principles of human rights including, but not limited to, those expressed in the UN Declaration of Human Rights, the UN Guiding Principles on Business & Human Rights, United Nations Global Compact Principles, Children's Rights and Business Principles, Women's Empowerment Principles and those principles contained within the UK's Modern Slavery Act 2015. These principles and commitments are now embodied in Marshalls' Supplier Code of Conduct, which can be accessed via our document library.

marshalls.co.uk/sustainability/ document-library

Marshalls complies with the employment laws of every country in which it operates and expects those with whom it does business to do the same. Marshalls also complies with national and international laws governing issues of supply chain management and expects those with whom it does business to do the same. Our Code of Conduct specifies supplier obligations regarding modern slavery and human trafficking.

The UK Modern Slavery Act 2015 requires Marshalls to disclose annually online, as a minimum, the following:

I	The organisation's structure, its	see	6
business and its supply chains	page
II	Its policies in relation to slavery and	see	9
human trafficking	page
III	Its due diligence processes in relation	see	10
to slavery and human trafficking in its	page
	business and supply chains
IV	The parts of its business and supply	see	12
chains where there is a risk of slavery	page
	and human trafficking taking place,
	and the steps it has taken to assess
	and manage that risk
V	Its effectiveness in ensuring that	see	13
slavery and human trafficking is not	page
	taking place in its business or supply
	chains, measured against such
	performance indicators as it
	considers appropriate
VI	The training available to its staff	see	14
involved in supply chain management	page

and employees throughout the rest of the organisation

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