Codes and Policies

As a global luxury retailer and manufacturer operating in over 400 retail locations worldwide, we take our corporate, social and environmental responsibilities very seriously. Our tax strategy is intended to enable the Group to fulfil those responsibilities in respect of tax. Our tax strategy applies to Burberry Group plc and its subsidiaries. We regard publication of this document in the current financial year as complying with the requirements of paragraph 16(2) of Schedule 19 of the Finance Act 2016.

To meet the new requirements, our tax strategy covers our approach to: governance, risk management and compliance; tax planning; dealings with Tax Authorities; and the level of tax risk we are prepared to accept.

Burberry has been a signatory of the UN Global Compact since 2008 and we continue to use the UN Global Compact’s Ten Principles to guide our business activities. We fully support the core values of the initiative across the areas of human rights, labour standards, the environment and anti-corruption.

As part of our commitment, we submit an annual ‘Communication on Progress’, including a statement by our Chief Executive and a description of practical actions we have taken to implement the Ten Principles.

We require all our supply chain partners, whether they are providing products or services, to agree with our Responsible Business Principles. These include the Burberry Ethical Trading Code of Conduct, Migrant Worker and Homeworker Policy. The Ethical Trading Code of Conduct is underpinned by the United Nations Universal Declaration of Human Rights, the Fundamental Conventions of the International Labour Organization and the Ethical Trading Initiative Base Code.

Our Ethical Trading Code of Conduct sets out the standards we uphold in relation to our own employees and for our supply chain partners to uphold in relation to their employees. Targets to promote fair and responsible employment practices have been set and integrated into the performance objectives of our sourcing teams as well as at an individual level. Existing as well as potential new suppliers are audited against international labour standards, which is particularly important in places where local labour laws are weak, absent or poorly enforced.

To ensure compliance with our Responsible Business Principles, our ethical trading programme comprises announced and unannounced audits, monitoring and improvement programmes, and covers all finished goods vendors, sub-contractors and key raw material suppliers. Audits consist of a site tour focusing on health and safety, documentation review and worker interviews. A representative sample of workers are selected for interview, including, where relevant, union representatives, first aiders and migrant workers. Audits are repeated periodically to monitor ongoing compliance and continuous improvement. The frequency of audits depends on a factory’s performance, with high-performing factories audited less frequently.

Living Wages referred to in the Ethical Trading Code of Conduct are defined by the following principles:

• A Living Wage should be calculated by reference to the income an individual needs to earn to live a decent life (where basic standards of living are met) and to participate fully in society
• The Living Wage for any country should be set by reference to local living standards and needs
• The Living Wage should be set in a transparent way, independent of control or manipulation by government, employers or other parties
• A Living Wage should be sufficient to pay for a locally agreed basket of goods, which is likely to include food, housing, utilities, transport, a degree of leisure and potentially education, health insurance, childcare, servicing debt and savings. A Living Wage is likely to include support for family members as defined in the local context
• A Living Wage should be paid to all employees (male and female) over a locally agreed minimum working age
• A Living Wage should be paid voluntarily by employers

These principles were established through multi-stakeholder consultation by the Living Wage Foundation and ACCA.

We have introduced a holistic global diversity, equity and inclusion policy, which includes clear guidelines and stronger accountability measures to ensure we attract and retain a diverse workforce.

Burberry’s priority is ensuring appropriate measures are in place to provide a safe and healthy environment for employees and visitors attending Burberry’s premises’.

We manage our business in a way that is designed to ensure that we maintain the highest standards of health and safety that are reasonably achievable throughout our global operations. We monitor health and safety performance through an independent audit programme and undertake unannounced audits at key locations on an annual basis and all other sites at least every three years. We follow all applicable guidelines and procedures relevant to our industry as well as following local laws.

A safe, healthy and well-planned business environment is important to the long-term sustainable growth of our business and we acknowledge the collective and individual roles played by each employee in providing health and safety leadership in their areas of responsibility.

Burberry's global parental leave policy offers all employees 18 weeks of parental leave at full pay and the opportunity to work a 30-hour week at full pay for a further four weeks on their return. The policy builds on Burberry’s existing maternity, paternity, adoption and partner leave commitments and creates a consistent approach for all employees globally who have worked at the Company for at least 12 months.

While we respect and uphold human rights wherever we operate, we are aware that risks can arise in relation to our own workforce, our supply chain, our communities and customers.

Burberry’s Human Rights Policy sets out our procedures to uphold human rights across these stakeholder groups, and the mechanisms we use to identify and address any instances of potential infringement. The policy was developed with reference to the International Bill of Human Rights and follows the UN Guiding Principles on Business and Human Rights for the implementation of the UN’s “Protect, Respect and Remedy” framework. Responsibility for the policy lies with Burberry’s CEO. To ensure compliance with the policy, we assess human rights impacts and monitor labour conditions across our own operations and extended supply chain on a regular basis through our ethical trading programme, which is delivered by an established global team of ethical trading experts.

Supporting our human rights commitment is our Modern Slavery Statement. This is published in line with the UK Modern Slavery Act and can be found here.

Burberry’s Migrant Worker Policy is intended to protect workers who may be vulnerable to exploitation during domestic and / or international migration. Our policy sets standards we uphold in relation to our own employees and for our supply chain partners to uphold in relation to all their workers, not just those who have migrated for work. The policy promotes workers’ rights in relation to recruitment, remuneration, identification documents, repatriation and living terms.

Burberry is committed to protecting the wellbeing and health of models engaged by Burberry across its global operations.

Burberry has liaised with external authorities and industry specialists in the development of this policy and will continue to do so to ensure the policy is kept up to date with all appropriate UK and International regulations.

This policy is informed by the following organisations and guidance: British Fashion Council, Association of Modelling Agencies Code of Practice, Equity Models’ Union Code and the UN Declaration of Human Rights.

We strive to work with our Business Associates to ensure compliance with Burberry’s Responsible Business Principles and, where applicable, any Letter of Undertaking. Burberry may take action in respect of Business Associates that do not demonstrate sufficient commitment to, or are in breach of (or reasonably suspected of being), the standards set out in the Responsible Business Principles or, where applicable, the terms of any Letter of Undertaking. This action may include terminating our direct business relationship with the Business Associate or requiring that the relevant Business Associate is no longer used by other Business Associates in any part of the supply of products or services to Burberry.

The Partner Non-Compliance Policy is designed to give a Business Associate a reasonable amount of time to rectify the critical issues to minimise any potential and/or detrimental impact on workers’ livelihoods.

The statement sets out the steps we have taken during the financial year 2022/23 to prevent slavery and human trafficking from taking place in our supply chain or in any part of our business. This statement is made pursuant to Section 54 of the The Modern Slavery Act 2015 and California Transparency in Supply Chains Act of 2010 (SB657).

Burberry is highly committed to respecting the communities and environments in which we operate and working in partnership with key stakeholders. Our communities are made up of Burberry employees, neighbouring individuals and businesses, our customers, local authorities and local media, wherever we operate.

Our Local Stakeholder Engagement Policy applies when a local stakeholder reports an issue or risk that has arisen due to Burberry operations or activities. For example, issues may relate to littering, noise, lighting in offices or stores, obstructions, behaviour of employees/customers in the local area, construction work etc. Local stakeholders can contact Burberry in store or online by contacting [email protected].

The Burberry Foundation is an independent charity (UK registered charity number 1154468), with an ambition to harness the power of creativity to drive positive change.

Introduced in 2022, its new global strategic mission focuses on empowering disadvantaged youth and expanding The Burberry Foundation’s activities to include Burberry’s key operational geographies.

The Burberry Foundation focuses its grant-making on supporting youth organisations around the world working to break down barriers faced by marginalised young people. These safe spaces provide essential services to help young people gain confidence and develop valuable skills to improve their lives and progress their career pathways.

We are committed to respecting the environment, minimising the environmental impacts of our own operations and activities in our supply chain.

Our Global Environmental Policy forms part of our Responsible Business Principles is mandatory and applies to all our own and our supply chain partners’ activities. The Policy includes compliance with environmental standards and is one the policies Burberry suppliers must follow as it forms part of the agreement between Burberry and the supplier (the Letter of Undertaking). Consideration of suppliers’ environmental performance is applied systematically via vendor and supplier scorecards. Burberry employees learn about our policies, as well as environmental topics relevant to our business during the onboarding process. We have not paid any fines related to environmental or ecological issues in the past four financial years.

Managerial responsibility for the company’s environmental performance, including its GHG emissions, as well as the environmental performance of suppliers sits with the Ethics Committee and the Sustainability Committee. The Sustainability Committee is chaired by the CEO.

We are committed to responsible and sustainable business principles and practices, including responsible sourcing.

Our Responsible Sourcing Policy prescribes the sourcing of all raw materials from suppliers that are governed by the highest animal welfare standards. Burberry actively seeks collaboration and learning opportunities in order to deepen our understanding of species specific best practice. We will never knowingly source raw materials if there have been any concerns over animal welfare and we actively engage welfare experts to ensure good husbandry of animals in our supply chain. Examples include our sourcing of wool, exotic skins and down.

Fur - Our responsible sourcing values drive the decisions that we make around raw material use. With effect from September 2018, Burberry does not manufacture or procure any real fur from rabbit, fox, mink or Asiatic racoon and Angora rabbit will not be used.

Wool - We aim to source 100% certified wool by FY 29/30, ensuring that wool comes from responsibly treated sheep and from farms with a progressive approach to land management. We support certifications that uphold the highest animal welfare standards and prohibit the practice of mulesing.

Exotic Skins – As a modern luxury company, we have banned the use of exotics in future collections, building on our commitment to go fur free in September 2018.

Down – Down and feathers are used in some of our jackets. Burberry does not permit the use of hair that is plucked from live animals or from farms where there is any concern that there has been unacceptable treatment of animals. Industry concerns around force feeding and live plucking led to the development of a Responsible Down Standard by Textile Exchange in 2014, which sets strict criteria to ensure bird welfare from hatching to slaughter. We work with supply chain partners to complete an annual self-declaration of humane practices and to increase the percentage of certified down in our products.

Our Product goals outline our work in sourcing certified key raw materials.