Marshalls : Modern Slavery Risk Analysis 2022

Elaine Mitchel-Hill

ESG and Human Rights Director June 2023

Without detailed analysis of the countries from which we source it would be impossible for us to take a strategic approach, especially as we approach modern slavery through a human rights lens rather than being driven solely by compliance.

We've been transparently publishing our Risk Analysis for six years now, and I can see looking back that it mirrors our evolution. This year's report is the most detailed that we've been able to provide. The expansion of our business and human rights team, almost twelve months ago, has accelerated our ability to delve deeper into the tiers and allowed us to focus deeply on specific challenging products, commodities, supply chains, geographies and issues. This critical investigation and analysis has enabled us to elevate strategic discussion internally across the Marshalls Group, to share insights with governments and key agencies, and to be a better and stronger partner with which to engage and collaborate. Importantly, it has also helped to galvanise colleagues in the fight to eliminate modern slavery.

Legislation is toughening for many countries, while for others it is not, which adds to the complexities of driving transparency along supply chains. Just transition is upon us. Our work with partners to understand the impact of sustainability drivers on our operating context in 2040 has made plain the challenges ahead.

We will continue to undertake this annual analysis and to share it transparently. By doing so we can stay alert to changes in sourcing, better understand our risks, and continue to build an ever stronger approach to eliminating modern slavery.

Modern slavery risk mapping

Every year, Marshalls carries out a modern slavery risk mapping exercise for countries where it has business operations or from where it sources goods and materials, when the annual spend is greater than £10,000.

This report for 2022 marks the sixth consecutive year that we have published our analysis, reflecting our ongoing commitment to transparency. We do this not only to be open with our stakeholders about the provenance of our products, but also to provide a useful reference guide for anyone operating in or buying from these countries.

The data published in this Risk Analysis Report complements other internal due diligence processes. This helps us to: build a more holistic understanding of modern slavery and human trafficking risk; set clear risk-based priorities on where best to direct our resources; develop engagement programmes with key suppliers in high-risk environments and make plans with our anti-slavery partners regarding remediation and prevention strategies.

Contents

Introduction

1. Modern slavery risk mapping
2. Risk Analysis Process
3. Global Overview

1. Effectiveness and Key Issues
2. Risk profile by country

14 Human Rights Due Diligence System

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

All of this activity is documented in detail in our Modern Slavery Statement for 2022. Download it at:

marshalls.co.uk/sustainability/ modern-slavery

Risk Analysis Process

Emma Crates

Business and Human Rights Manager,

Marshalls Plc.

Our sixth annual Modern Slavery Risk Analysis report features more detail and more countries than ever before, reflecting developments within the wider Marshalls Group.

Last April, Marshalls bought pitched roof systems manufacturer Marley Group plc which owns photovoltaic specialist Viridian Solar. This report brings together analysis based on procurement data from all three companies.

The number of sourcing countries analysed has increased from 21 to 26.

For the first time, we are also publishing analysis of second tier supplier locations. In coming years, we expect to increase reporting on lower tier suppliers as part of our ongoing commitment to mapping product journeys back to raw materials.

In another first, we have also included the percentage of spend on first tier suppliers by country.

The Marshalls Modern Slavery Risk Analysis report should be read alongside our annual Modern Slavery Statement and End Modern Slavery report which are focused on bringing wider systemic change and eradicating modern slavery for good.

The World Bank - Global Findex Database globalfindex.worldbank.org/

The World Bank - Governance Indicators info.worldbank.org/governance/wgi

United Nations Development Programme: Human Development Reports - Inequality- adjusted Human Development Index hdr.undp.org/en/composite/IHDI

United Nations Development Programme: Human Development Reports - Gender Inequality Index hdr.undp.org/en/composite/GII

Children's Rights and Business Atlas http://www.childrensrightsatlas.org/country-data/workplace/

Global Slavery Index -

Government Response Rankings

globalslaveryindex.org/findings/

Ratification of Fundamental ILO Conventions

ilo.org/dyn/normlex/en/f?p=1000:10001:::NO:::

World Justice Project - Rule of Law Index

worldjusticeproject.org/rule-of-law-index/

International Trade Union Confederation - Global Rights Index survey.ituc-csi.org?lang=en

Trafficking In Persons Report

state.gov/trafficking