U.K. MODERN SLAVERY ACT 2015
1. BUSINESS OVERVIEW

VAYYU™  is an internationally recognized multi-brand apparel and accessories retailer that differentiates itself through high standards of quality, style, design and fabrics. We are a vertically-integrated omnichannel speciality retailer that operates stores and websites both domestically and internationally. We source our merchandise through the use of buying agents and by purchasing merchandise directly from trading companies and manufacturers

2. ANTI-SLAVERY AND ANTI HUMAN TRAFFICKING POLICIES

At VAYYU™ we believe that we have a responsibility to source our products in a legal, ethical and responsible manner consistent with the highest standards. This includes our commitment ensuring that no forced labour, whether in the form of human trafficking or indentured labour is taking place in any parts of our business or in our supply chain. 

To this end all of our associates are expected to act professionally and ethically and comply with all applicable laws where we do business and must certify the Code of Ethics and Business Practices. If associate believes that they are witnessing or suspecting unethical conduct, they can anonymously report these actions to our confidential email submission form. 

In our supply chain, all of our suppliers, factories and contractors are required to adhere to our Code of Vendor Conduct Policies found by clicking here (here) which prohibits the use of forced labour of any kind, including slavery and human trafficking. Our vendors are contractually required to comply with our Responsible Sourcing Supplier Guidelines, for example, the "Fair Wear Foundation" which outlines our requirement that our vendors need to verify that their own suppliers operate according to our Vendor Code of Conduct principles. 

3. RISK ASSESSMENT, DUE DILIGENCE & ENFORCEMENT

We have a comprehensive Responsible Sourcing program in place to evaluate and address risks in our supply chain, including the risk of human trafficking and slavery. Our inspectors are trained in identifying any potential risks of forced labour or human trafficking. We determine our inspection strategy based on country and industry risk as well as previous inspection reports. 

We conduct both announced and unannounced inspections of manufacturing facilities. A typical inspection covers code elements ranging from health and safety, wages, working hours to forced labour and consists of document reviews, private worker interviews and a walk-through of the facility. When appropriate, we will also conduct surveillance and off-site interviews. In cases where there is a higher risk of potential forced labour, we will conduct targeted inspections. 

Should issues of noncompliance be identified during our inspections, it is our practice to work with suppliers to address these issues. We aim to provide suppliers with the tools they need to improve working conditions, including training and in-factory consultations, and we will conduct re-inspections when necessary to verify improvement.

However, we will terminate a business relationship, if identified issues are not resolved to our satisfaction, if a critical issue of noncompliance is repeatedly identified or if a supplier does not share our commitment to the principles laid forth in the Vendor Code of Conduct. 

4. TRAINING & CAPACITY BUILDING

All VAYYU™ our associates are trained in the Code of Ethics and Business Practices. Among other expectations, associates are expected to act professionally and ethically and comply with all applicable laws where we do business. Any failure to comply with the Code of Ethics and Business Practices could lead to corrective action, up to and including termination. Associates and management, who have a responsibility in managing and monitoring our suppliers, have been trained on the risks of human trafficking and slavery. 

In addition to internal training, we regularly conduct Responsible Sourcing training seminars for suppliers. 

5. EFFECTIVENESS
The principles laid out in our Code of Ethics as wells as in our Vendor Code of Conduct aim to clearly communicate our zero-tolerance stance towards unethical conduct and any form of forced labour in our business or supply chain. 

Our internal grievance mechanisms, as well as our continuous monitoring efforts at our factories, help us to identify risks, and to assess whether our guidelines are being followed by our associates and supply chain partners. 

Modern Slavery and Human Trafficking are serious issues. Based on data from the International Labor Organization there are currently as many as 21 million affected victims. We acknowledge the risks of forced labour in our global supply chain and understand the importance of the requirements of Section 54 of the UK Modern Slavery Act. 

Here at VAYYU™, we are committed to strengthening our internal processes, working with our suppliers as well as industry groups, governments and other stakeholders to develop strategies to address modern slavery and human trafficking in our supply chain.