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UKRAINE: HELPING THOSE AFFECTED

COMPANY POLICIES

This statement has been published in accordance with the UK Modern Slavery Act 2015. It outlines the measures taken by Yours Clothing Ltd and other relevant group companies during the 2020/21 financial year to assess and prevent the risk of slavery and human trafficking occurring in its business or supply.

Yours Clothing Limited is a privately owned United Kingdom limited liability company. Yours have been a Plus sized clothing retailer since 1993. Yours designs, develops, sources and sells clothing and accessories both in the UK and globally, operating in multi countries. Yours products are sold through our own retail and outlet stores as well as through stores operated by our franchise partners and online via our digital platforms. At 1st August 2017, Yours employed over 1,100 people including part time employees in its 115 stores, 1 distribution depot and head office based in Peterborough UK. Corporate functions providing services in Human Resources, Finance, IT, Marketing and Retail operations are located at the Peterborough Yours head office.

While we undertake most of the design and development of our products ourselves, we outsource the manufacturing of all our products. In most factories, the facilities are shared with production for other Clothing & Accessories brands. We work closely and collaboratively with suppliers and service providers, numbering +100 suppliers in over 10 countries.

As a Brand we have signed up to THE APPAREL AND FOOTWEAR SUPPLY CHAIN TRANSPARENCY PLEDGE which is an important part of our overall approach to Corporate Responsibility.

This Transparency Pledge helps demonstrate apparel and footwear companies’ commitment towards greater transparency in their manufacturing supply chain.

Transparency of a company’s manufacturing supply chain better enables a company to collaborate with civil society in identifying, assessing, and avoiding actual or potential adverse human rights impacts. This is a critical step that strengthens a company’s human rights due diligence.

Each company participating in this Transparency Pledge commits to taking at least the following steps within three months of committing to it:

Publish manufacturing sites the company will publish on its website on a regular basis (such as twice a year) a list naming all sites that manufacture its products. The list should provide the following information in English:

  1. The site addresses
  2. The parent company of the business at the site
  3. Type of products made
  4. Worker numbers at each site

Yours Terms & Conditions and Code of Practice for Suppliers are available via the Bureau Veritas Yours website and published on our web site www.yoursclothing.co.uk

Terms & Conditions

Our T&C’s outlines the values and principles that help shape the way we work. It is primarily aimed at employees and we encourage our business partners, including suppliers, franchise and partners, to adopt and apply the T&C’s wherever they represent or promote the Yours brand. The key principles include:

  • We treat all employees and each other fairly, with dignity and respect

  • We operate with integrity and honesty

  • We base our business relationships on respect; and expect the same from those that we do business with

Code of Practice for Suppliers

Yours Code of Practice summarises the minimum standards for working conditions that we expect our Suppliers to adhere to in the production of all Yours products. The Code of Practice requires compliance with all local legal and regulatory requirements of the country in which the facility is located; to recognise International standards and to uphold the core labour conventions of the International Labour Organization. Where there is any conflict between these we expect the higher standard to be achieved.

It contains specific requirements related to forced labour as follows:

  • All work must be conducted on a voluntary basis, and not under threat of any penalty or sanctions.

  • The Supplier shall not use any form of forced, bonded, indentured, trafficked, slave or prison labour.

  • Workers must not be required to lodge "deposits" or their identity papers with their employer. All workers should be provided free and unrestricted access to potable water and clean toilet facilities.

  • used in the Code of Practice the term “Supplier” includes but is not limited to vendors, agents, factories, sub-contractors and material & component suppliers

HR policies

Yours Clothing Ltd will not use or allow the use of forced, compulsory labour, slavery, servitude or human trafficking in the course of its business. This includes sexual exploitation, securing services by force, threats or deception and securing services from children and vulnerable persons.

Our employment procedures guarantee that Yours Clothing Ltd conducts appropriate checks on all staff to ensure they can legally work in the United Kingdom.

In addition, all internal policies are reviewed regularly to ensure continued compliance with the Modern Slavery Act 2015.

Yours operates the following policies which are relevant to the prevention of slavery and human trafficking in its operations:

  • Outsourcing Policy. This establishes that Yours Clothing Ltd will continue to comply with the Modern Slavery Act 2015 and conduct annual reviews of outsourced suppliers

  • Recruitment Policy. This confirms that Yours Clothing Ltd will conduct checks on all staff to safeguard that they can legally work in the United Kingdom

  • Corporate Responsibility Policy. This policy is designed to ensure that Yours Clothing Ltd is conducting its business responsibly.

  • Whistleblowing Policy. Yours Clothing Ltd encourages all of its employees to report any concerns related to the activities of the firm. The organisation’s whistleblowing procedure is designed to ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the individual who raised the issue. Additionally, the policy guarantees that no one will be victimised for raising a matter under this procedure.

Due Diligence and Audits of suppliers

We believe that our biggest exposure to Modern Slavery is in our product supply chains, which is a biggest focus initially. Within these areas, new suppliers and factories/sites are subject to due diligence checks in the form of a valid 3rd party ethical audit to SMETA (or similar standards). Existing factories are also required to provide Yours with 3rd party audit information.

In common with other retailers, audits are conducted either by our Yours Buying & Garment Technical team or by a third-party service provider on our behalf.

These audits are used to assess compliance with Yours Terms & Conditions and Code of practice for suppliers and identify issues for investigation so action can be taken.

In the first instance, we aim to gather the information through our audit programme to take action to improve conditions were necessary and to inform sourcing decisions.

Yours does not tolerate forced labour, slavery or human trafficking within our direct operations or supply chains. Where any non-compliance to Yours Code of Practice for Suppliers is identified, we expect and support suppliers to take action to correct it. If a supplier does not take effective action in a timely manner withdrawing our business remains the final sanction.

Yours attaches real importance to the welfare of our employees and those employed by our suppliers. We are taking steps to strengthen our understanding and management of the risks of modern slavery and human trafficking in our own business or our supply chains, building on our Terms & Conditions and Code of Practice for Suppliers. These steps include:

  • Mapping our supplier chains to assess particular industry/sector and geographical risk, to have a clear idea of where the business risks lie

  • Assessment scope covers all aspects of our business including Retail operations, Property, Logistics, HR and IT as well as our product supply chains

  • Meeting with a 3rd party to discuss conducting a modern slavery risk assessment on behalf of Yours Clothing

  • Reviewing our governance structures for responsible sourcing of Goods for Resale (GfR) and Goods Not for Resale (GNfR)

  • Published the Yours Modern Slavery statement

During the remainder of the 2020/21 financial year, Yours will continue to build on these activities, considering the following areas in particular:

  • Internally publish the findings of modern slavery risk assessment, collate action plan to further mitigate risks and drive improvement using best practice examples from other retailers

  • Engage our supply base by writing to all areas of our business to raise awareness of the Modern Slavery Act and Human Rights

  • Review of potential KPIs and monitoring

We aim to hold awareness training, on the prevalence of modern slavery and the Modern Slavery Act to highlight the issue and how we expect all employees to play their part.

Supply chains can change for many reasons and the threat of modern slavery can continue to evolve and change. We intend to continue to monitor and review our controls that guard against the risk of modern slavery which will be shared and reported on.

Approved by the Board of Yours Clothing Ltd on 25.01.2021 and signed on its behalf by:

David Preece Company Secretary  25.01.2021

Yours Clothing Limited need to gather and use certain information about individuals. This includes personal information and data from customers, suppliers, business contacts, employees and other people the organisation may have a relationship with and need to contact. This Data Protection Policy describes how this personal data must be collected, handled and stored to comply with the law, and meet data protection standards.

This data protection policy ensures that Yours Clothing Limited:

  • Complies with data protection law and follows good practice

  • Protects the rights of staff, customers, and business partners

  • Is open about how it stores and processes individuals’ data

  • Protects itself from the risks of a data breach

  • The Data Protection Act 1998 describes how organisations — including Yours Clothing Limited — must collect, handle and store personal information.

  • These rules apply regardless of whether data is stored electronically, on paper or on other materials.

  • To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

Policy Scope

This policy applies to the Head Office, all store sites, all staff and volunteers, and all contractors, suppliers and other people working on behalf of Yours Clothing Limited.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998, including but not limited to individuals’:

  • Name
  • Postal Address
  • Email Address
  • Telephone Number
  • Payment Information
  • Photographs
  • Locations
  • IP Address
  • Online Behaviours
  • Any special category data such as; Religion, Health Information

Data protection risks

This policy helps to protect from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.

  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.

  • Reputation damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with the Company has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and the data protection principles.

However, these people have key areas of responsibility:

  • The Board of Directors is ultimately responsible for ensuring legal obligations are met.

  • The Compliance Officer is responsible for:

    • Keeping the board updated about data protection responsibilities, risks and issues.
    • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
    • Handling data protection questions from staff and anyone else covered by this policy.
  • The Company Secretary is responsible for:

    • Dealing with requests from individuals to see the data held about them (also called ‘subject access requests’).
    • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
  • The IT Manager is responsible for:

    • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
    • Performing regular checks and scans to ensure security hardware and software is functioning properly.
    • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
  • The Managing Director is responsible for:

    • Approving any data protection statements attached to communications such as emails and letters.
    • Addressing any data protection queries from journalists or media outlets like newspapers.
    • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
  • All employees will be provided with training to help them understand their responsibilities when handling data.
  • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords must be used and they should never be shared.
  • Personal data should not be disclosed to unauthorised people, either within the company or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
  • Employees should request help from their line manager or the compliance officer if they are unsure about any aspect of data protection.

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

Where data is stored on paper, it will be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Data printouts should be shredded and disposed of securely when no longer required.

Where data is stored electronically, it will be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees.
  • If data is stored on removable media, these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

Personal data is of no value to Yours Clothing unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
  • Employees should not save copies of personal data to their own computers. Always access and update the most recent version of the document from the main file, and update the version.

The law requires Yours Clothing to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort should be put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • Make it easy for data subjects to update the information held about them. For instance, via their account online.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

All individuals who are the subject of personal data held are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a Subject Access Request. Subject Access Requests from individuals should be made by email.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Yours Clothing will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Yours Clothing aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How the data is being used
  • How to exercise their rights

To these ends, the company has a Privacy Policy, setting out how data relating to individuals is used by the company. The latest version of this policy is available on the company website www.yoursclothing.co.uk

This Information Security Policy is a key component of Yours Clothing Limited’s overall information security management framework.

Data and information systems are vital to the business. Incidents involving loss of confidentiality, integrity or availability of information can be costly. Serious incidents, which may include failure to comply with information legislation, can also be damaging to the business reputation.

1.1. Objectives

The objectives of the Yours Clothing Limited Information Security Policy are:

  • Confidentiality - Access to Data shall be confined to those with appropriate authority, and protected from unauthorised access.

  • Integrity – Information shall be complete and accurate. All systems, assets and networks shall operate correctly, according to specification.

  • Risk Management - Appropriate measures are taken to manage risks to the availability and disclosure of information.

  • Compliance – Ensured compliance with laws, regulations, and the terms of contracts.

*Failure to comply with the Yours Clothing Limited Information Security Policy may lead to disciplinary action.

1.2. Policy Aim

The aim of this policy is to establish and maintain the security of individuals’ information, information systems, applications and networks owned or held by Yours Clothing Limited by:

  • Ensuring all members of staff are aware of, and fully comply with the relevant legislation as described in this and other policies.

  • Explaining the principals of security and how they shall be implemented in the organisation.

  • Ensuring all members of staff fully understand their own responsibilities towards a consistent approach to security.

  • Creating and maintaining a level of awareness of the need for Information Security as an integral part of the day to day business.

  • Protecting information assets.

1.3. Scope

  • This policy applies to all information, information systems, networks, applications, locations and users of Yours Clothing Limited, or supplied under contract to them.

2.1. Ultimate responsibility for information security rests with the Yours Clothing Board of Directors, and they shall be responsible for managing and overseeing implementing the policy and related procedures

2.2. Line Managers are responsible for ensuring that their permanent and temporary staff, and contractors are aware of:

  • The areas of the Information Security Policy that is applicable in their department

  • Personal responsibilities for information security

  • Where to find, and how to access advice on information security matters

2.3. All staff shall have to comply with information security procedures including the maintenance of data confidentiality and integrity.

2.4. The Information Security Policy shall be maintained, reviewed, and updated accordingly on an annual basis.

2.5. Line managers shall be responsible for the security of their department physical environments where information is accessed, processed or stored.

2.6. Each member of staff shall be responsible for the operational security of the information systems they use.

2.7. Each system user shall comply with the security requirements that are currently in force, and shall also ensure that the confidentiality, integrity and availability of the information they use is maintained to the highest standard.

2.8. Contracts with external contractors that allow access to the organisation’s information systems shall be in operation before access is allowed. These contracts shall ensure that the staff or sub-contractors of the external organisation shall comply with all appropriate security policies.

3.1. Yours Clothing Limited is obliged to abide by all relevant UK and European Union legislation. The requirement to comply with this legislation shall be devolved to employees and agents, who may be held personally accountable for any breaches of information security for which they may be held responsible.

4.1. Management of Security

  • Responsibility for Information Security shall reside with the Board of Directors.

  • Department Managers are responsible for implementing, monitoring, documenting and communicating security requirements within their teams for the organisation.

4.2. Information Security Awareness Training

  • Information security awareness training shall be included in the staff induction process.

  • Staff awareness will be reviewed, refreshed, and updated as necessary.

4.3. Contracts of Employment

  • All contracts of employment shall contain a confidentiality clause.

  • Information security expectations of staff shall be included within the employee handbook, and on induction.

4.4. Security Control of Assets

  • Each IT asset, (i.e. hardware, software, application) shall have a named person who shall be responsible for the information security of that asset.

4.5. Access Controls

  • Only authorised personnel who have a justified business need shall be given authorisation to access restricted areas containing information systems or stored data.

4.6. Computer Access Control

  • Access to computer facilities shall be restricted to authorised users who have business need to use the facilities.

4.7. Application Access Control

  • Access to data, system utilities and program source libraries shall be controlled and restricted to those authorised users who have a legitimate business need e.g. systems or database administrators.

4.8. Equipment Security

  • In order to minimise loss of, or damage to, all assets, equipment shall be physically protected from threats and environmental hazards.

4.9. Computer and Network Procedures

  • Management of computers and networks shall be controlled through standard documented procedures that have been authorised by the board.

4.10. Information Risk Assessment

  • Risk assessment and management requires the identification and quantification of information security risks in terms of their perceived value of asset, severity of impact and the likelihood of occurrence. 

  • Once identified, information security risks will be recorded on a central business risk register and action plans devised to effectively manage those risks. The risk register and all associated actions shall be reviewed regularly. Any implemented information security arrangements shall also be a regularly reviewed. These reviews shall help identify areas of continuing best practice and possible weakness, as well as potential risks that may have arisen since the last review was completed.

4.11. Information Security Events and Weakness

  • All information security events and suspected weaknesses will be reported. These shall be investigated to establish their cause and impacts with a view to avoiding similar or future events.

4.12. Protection from Malicious Software

  • Yours Clothing shall use management procedures and countermeasures relating to any software used to protect itself against the threat of malicious software. Users shall not install software on the organisation’s property without permission from the IT Manager, or a Director.

4.13. User Media

  • Removable media of all types that contain software or data from external sources, or that have been used on external equipment, require the approval of the IT Manager or a Director before they may be used on Yours Clothing systems. Such media must also be fully virus checked before being used on the organisation’s equipment.

4.14. Monitoring System Access and Use

  • An audit trail of system access and data use by all staff shall be maintained.

  • Yours Clothing regularly audits compliance with this and other policies. In addition it reserves the right monitor activity where it suspects that there has been a breach of policy. The Regulation of Investigatory Powers Act (2000) permits monitoring and recording of employees’ electronic communications (including telephone communications) for the following reasons:

  • To establish the existence of facts

  • Detection and investigation of any unauthorised use of the system

  • Prevention and detection of crime

  • To ascertain or demonstrate standards which are achieved or ought to be achieved by persons using the system (quality control and training)

  • National Security Interests

  • Compliance with regulatory practices or procedures

  • Ensuring the effective systems operation.

  • Any monitoring will be undertaken in accordance with the above act and the Human Rights Act

4.15. Accreditation of Information Systems

  • Yours Clothing will ensure that all new information systems, applications and networks include a security plan and are approved by the Board before they commence operation.

4.16. System Change Control

  • Changes to information systems, applications or networks shall be reviewed and approved by the IT Manager and the Board.

4.17. Intellectual Property Rights

  • Yours Clothing will ensure that all information products are properly licensed and approved. Users shall not install software on the organisation’s property without permission from the IT Manager or a Director.

4.18. Business Continuity and Disaster Recovery Plans

  • The organisation shall ensure that business impact assessment, business continuity and disaster recovery plans are produced for all mission critical information, applications, systems and networks.

4.19. Reporting

  • The IT Manager shall keep the Board informed of the information security status of the organisation by means of regular reports.

The directors recognise their duties under section 172(1) (a) to (f) of the Companies Act 2006 and at all times act in the way they consider, in good faith, would be most likely to promote the success of the company for the benefit of its members as a whole. We have built and maintain strong relationships with our customers, suppliers and producers. They are key to the success of our business. In doing so we like to maintain our business standards to the highest ethical standards. In support of the community the company has partnered with a local hospital charity for focused fundraising drives. This is in addition to supporting national fund raising drives for charities selected by its employees as well as being a bronze award holder for the level of charitable contributions donated to the charities trust through the company assisted payroll giving scheme. Understanding and clear communication remains key to our relationship with our Bankers and professional advisors, together they offer valued experienced guidance. We are an equal opportunity employer and continue to invest in our people and their working conditions and remain committed to good human relations and working practices in all areas of our business. We endeavour to minimise our impact upon the environment and to contribute positively wherever possible. We recycle all plastics and cardboard throughout our stores, warehouse and offices. We utilise Hybrid cars to reduce emission as well as having installed solar panels which supply non-polluting electricity back to the National Grid. The Company actively follows up on our Energy Savings Opportunity Scheme (ESOS) Reports.

Yours Clothing was established in 1994 to provide women, often forgotten by UK retailers, with affordable, fashionable clothing regardless of size. We have dedicated our work on continuously improving our offering to women and are also able to extend our service to men through our “BadRhino” brand and to tall customers through the recent acquisition of the “Long Tall Sally” brand too. Our growth in the UK has been as a result of our talented, hard working employees whom we value greatly. We are proud of our growth as a business and the opportunities that it has given to our employees who have equal opportunities to shine, develop and earn. Due to us being largely recognised as a women’s fashion retailer, we attract mainly female applicants to work in our stores and, with the majority of our employees based in our retail stores, the net result is that Yours Clothing employee population is currently 95% female. The male staff we do have in our stores are paid equally to our female staff, and we are confident that our gender pay gap is as a result of the variety of roles in which men and women work within the organisation and the salaries that these roles attract. As part of the Government’s commitment to tackling gender inequality, UK companies with over 250 employees are required by law to publish calculations every year showing the pay gap between male and female employees. At Yours Clothing, we value inclusion and strive for equality and fairness for each and every team member. This year’s report shows some significant positive differences in all areas. This is a result of a combination of factors including an increase in the proportion of Males employed in the business but most significant was a change in the people included within the full pay relevant employees. The snapshot date was at a time that our retail stores were closed due to the Coronavirus pandemic with the majority of employees unable to be included as they were on furlough leave. The gender pay figures are therefore only inclusive of a skeleton staff working in our stores and the rest made up from Head Office and warehouse employees at the time so the roles being compared have less variation than in previous years reports. The following information is accurate as of the snapshot date of 5 April 2021, and shows our overall mean and median gender pay gap and bonus pay gap based on hourly rates of pay.

Gender & Bonus Pay Gap

The table below shows the percentage difference in overall mean and median pay and bonus between men and women across the whole company:

Mean Median
Hourly Pay Gap 28% 37%
Bonus Pay Gap 34% 51%

Proportion of males and females receiving a bonus payment

Out of a total of 729 employees, 172 employees received a bonus payment and 85% of these employees are female. In total 24% of all staff employed on the snap shot date received a bonus in the financial year 2020/2021.

Percentage of Females who received Bonus 21%
Percentage of Males who received Bonus 71%

We are pleased that we have been able to reward our employees this year with a bonus and we continue to look at our reward packages across the business.

Pay Quartiles

We have divided our employees into four equal-sized pay quartiles and shown below the percentage of males and females in each quartile.

Upper Quartile
Upper Middle Quartile
Lower Middle Quartile
Lower Quartile

There are 204 people employed in our Head Office and Warehouse, 32 of which are male and 172 female. Our Senior Leadership team is 60% female. Any gender pay gap that exists is a result of differentiating roles and not due to any variance in pay for like for like roles.

Going Forward

We are committed to reducing our gender pay gap and will continue to focus on women having the same opportunities for senior roles as men as well as continuing to support men and women to develop to the best of their potential.

I can confirm that the information contained within this report is accurate.

Anna Heather

Finance Director

1.1 About this policy

(a) Yours Clothing Limited (the Company) is committed to conducting business with high standards of professionalism and integrity. It is important to the Company that any wrongdoing at work is reported and properly dealt with. Often the first people to know of any possible wrongdoing will be those who work in or for the Company. They may however feel that they cannot raise their concerns because this would be disloyal to their colleagues or the Company, or out of fear of reprisals. This policy reflects the Company's commitment that any genuine concerns our staff have in relation to wrongdoing at work and raise in accordance with this policy will be taken seriously and dealt with appropriately.

(b) The aims of this policy are to:

(i) encourage staff to report any genuine concerns about wrongdoing at work (as defined in paragraph 1.3 of this policy) as soon as possible;

(ii) provide guidance on how to report any wrongdoing and how such concerns will be dealt with;

(iii) demonstrate that the Company is serious about addressing any genuine concerns about wrongdoing and that it will support any individuals who raise such concerns within the terms of this policy; and

(iv) make it clear that the Company will not tolerate the victimisation of anyone who raises genuine concerns about wrongdoing in accordance with this policy, even if it turns out that those concerns are misplaced.

(c) This policy only applies to concerns that have a public interest aspect to them. It does not cover individual grievances or complaints about an individual’s own employment position, e.g. where someone believes they are being bullied or discriminated against or the terms of their contract have been breached. Such concerns should be raised under the Company's Grievance Procedure or Harassment Procedure. If you are unsure about which procedure to use, you should speak to one of the Designated Officers whose details are set out at the end of this policy.

(d) This policy is non-contractual which means that it does not give any legal rights to individuals. The Company may change all or any part of this policy in any way at any time and while it sets out the Company's likely response to disclosures, it does not commit the Company to them.

1.2 Who does the policy apply to?

This policy applies to anyone who works in or for the Company, including: employees; workers (including agency workers, homeworkers, freelancers); non-executive directors; and consultants.

1.3 What types of concern should be raised under this policy?

(a) If you have genuine concerns that any of the following activities are taking place at work (or have taken or are likely to take place) and have a public interest element in them, you should raise them under this policy:

(i) criminal activity;

(ii) breach of any legal obligation;

(iii) danger to health and safety;

(iv) damage to the environment;

(v) miscarriages of justice; or

(vi) the deliberate concealment of any of the above.

(b) If you are unsure about whether any suspected wrongdoing is covered by this policy you should speak to one of the Designated Officers, whose contact details are set out at the end of this policy.

1.4 How to raise a concern

(a) You should normally raise any concerns about wrongdoing at work with your immediate manager in the first instance. If you do not feel confident about doing so (for example, because you believe the manager may be involved) or where concerns have been raised already with the line manager, but you do not believe they have been addressed, you should contact one of the Designated Officers whose contact details are set out at the end of this policy. A confidential telephone hotline is also available for staff to use. Contact details are set out at the end of this policy.

(b) Where concerns are raised with a Designated Officer, they will arrange for an initial confidential interview with you to discuss the areas of concern. You will be expected to provide as much information and supporting details as you can in relation to the disclosure being made. Failure to do this may hamper any subsequent investigation and raise doubts about the genuineness of your belief in that disclosure. At this stage you will be asked whether you are prepared for your identity to be disclosed, as this may affect the extent of the investigation that may be carried out and so possibly also the remedial steps which can be taken. The Designated Officer will prepare a brief summary of the interview and provide you with a copy of this.

(c) You may bring a work colleague or union representative to any meetings under this policy, provided such representative agrees to respect the confidentiality of the matter.

(d) Depending on the nature of the concerns raised, the Company may appoint an investigator or team of investigators to investigate your concerns. The Company will aim to keep you reasonably informed of the progress of any investigation and the final outcome. While the Company will give as much feedback as it properly can, due to the legal obligations of confidentiality it owes to other employees, it will not usually be possible for the Company to provide detailed feedback on the outcome of any disciplinary action taken against another employee or where the Company's response may be commercially sensitive. You should treat any information about the investigation as confidential.

(e) Raising a genuine concern will protect you against victimisation or other less favourable treatment imposed as a result of that disclosure. However, it does not provide you with any right to any (or any minimum level of) involvement in the resulting investigation nor to dictate any particular remedy or response, whether or not your concern is found to be genuine.

(f) If you raise or repeat a concern which you know is false you may be subject to disciplinary action, up to and including dismissal.

1.5 Anonymous complaints

(a) Staff are not encouraged to raise any concerns about wrongdoing at work anonymously, as this makes it difficult for the Company to investigate them. If anybody has any concerns about identifying themselves, they should speak to one of the Designated Officers whose contact details are set out at the end of this policy. The Company will seek to accommodate any requests for anonymity as far as practicable.

(b) Staff can obtain free confidential advice on whether and how to raise a concern via the helpline run by the independent whistleblowing charity, Protect. Contact details are set out at the end of this policy.

1.6 Raising concerns externally

(a) The Company expects that employees will first raise any concerns about wrongdoing at work internally in accordance with this policy, but it recognises that it may occasionally be appropriate for employees to contact an appropriate external body such as a regulator where the complaint has been raised internally but ignored or there has been a recurrence of the same wrongdoing.

(b) The Company would strongly recommend that employees seek advice before raising any concerns externally. As set out above, employees can obtain free confidential advice on whether and how to raise a concern via the helpline run by the independent whistleblowing charity, Protect. Contact details are set out at the end of this policy.

1.7 Protection from victimisation

(a) We will not tolerate any victimisation of individuals because they have raised a genuine concern under this policy. The Company will treat any such victimisation as a disciplinary matter, which might lead to dismissal. However, nothing in this policy means that someone who has raised a concern under it cannot be managed (monitored, directed, disciplined, dismissed, etc.) in the ordinary course of the employment relationship for reasons unrelated.

(b) If you believe you are being victimised or have suffered detrimental treatment for having raised genuine concerns about wrongdoing at work in accordance with this policy, you should raise a grievance in accordance with the Company's Grievance Procedure. This should identify the concern raised and how it was raised, and also the specifics of the treatment which you believe has resulted from your doing so.

(c) The Company will take all complaints seriously and seek to deal with them promptly. If your complaint is upheld then you will be notified of this. The details of any action taken against the perpetrator as a result are usually confidential as between him/her and the Company. Alternatively, the Company may request that you participate in addressing the matter via a mediation or similar process.

(d) Staff should be aware that if they victimise someone for having raised concerns about perceived wrongdoing, they could be held personally liable to pay compensation in the Employment Tribunal.

1.8 Responsibility for the policy

The Board has overall responsibility for this policy and the Designated Officers have day-to-day responsibility for it. This policy will be reviewed periodically.

1.9 Contacts

Protect – the independent whistleblowing charity 020 3117 2520 www.pcaw.org.uk
Yours Clothing Confidential Whistleblowing hotline 01733 830465 (Answerphone)