MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

This statement is issued in compliance with the Modern Slavery Act 2015, Act of the Parliament of the United Kingdom, designed to tackle slavery and human trafficking.

The Pronovias Group (“Pronovias” or the “Group” or “we”) acknowledges that modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. For this reason, the Group adopts this Modern Slavery and Human Trafficking Statement in the name and on behalf of its British subsidiary Pronovias UK Limited for the financial year ending 31 December 2020. Through this statement, Pronovias Group also satisfies the disclosure requirements pursuant to the California Transparency in Supply Chains Act 2010.

Organization

Pronovias Group is a business group founded in Barcelona (Spain), where the headquarters of the Group are based, in 1964, with an international presence, whose core business is the design, manufacture, sale and distribution of wedding, ceremony and party dresses, and all related accessories. As of December 31, 2020, the Pronovias Group was made up of 959 people in 12 countries, from different backgrounds, cultures and nationalities. More than two thirds of Pronovias personnel are based in Europe and the 70% of them in Spain.

Business Model

One of the main objectives of the Pronovias Group is to strive to research and develop new styles, patterns, fabrics and designs in keeping with the latest fashion trends and with a high demand for quality geared towards satisfying the needs of its customers. This is achieved through a strong supply chain, made up of fabric suppliers, final product suppliers monitored by a rigorous quality control and distributed through logistic suppliers.

Our supply chain is complex and has significant scale, it includes 80 suppliers with 82 factories in total, that provide the Group with goods and services to manufacture our products such as raw materials, finished and semi-finished products, warehousing and logistics of our products around the world. In 2020, the Group entered into partnerships with new suppliers in Europe (Lithuania, Latvia, Ukraine, Italy and Portugal) and in 2021 we plan to continue reducing the number of suppliers in risk countries.

Commitment

The Pronovias Group and its employees must comply with the current legislation in each of the countries in which it operates, including respect for human rights, and must adhere to the Code of Conduct, as well as internal rules and regulations and any instructions that may be approved in its development.

It is hereby stated that there is no child labour in any of the companies that make up the Pronovias Group and that all of them comply with the current legislation in the corresponding territory, particularly with regard to workers' rights. As indicated in the Code of Conduct, the Pronovias Group recognizes and protects the rights of workers, both individually and collectively, established by the ILO (International Labour Organization), the applicable legal system and internal policies.

At Pronovias, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in the company’s operations and supply chains. Pronovias commits not to work with any supplier who has demonstrably and repeatedly failed to comply with ILO standards.

During 2020, the Pronovias Group did not receive any complaints regarding cases of human rights violations, consistent with the previous years’ trend. Additionally, we have never been made aware of any allegations of human trafficking or slavery activities against our suppliers.

Policies

The Group’s policies mentioned below reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains:

Code of Conduct: The Pronovias Group has a binding Code of Conduct for all its employees and collaborators, which disseminates ethical values and establishes the line of conduct for members of the organization in carrying out their professional and business activities anywhere in the world. Based on these ethical values, all Pronovias Group professionals show respect in the workplace, act with integrity in the marketplace, guarantee ethics and responsibility in professional and commercial activity.
Supplier Code of Conduct: The Group is committed to conduct its activity in compliance with all the applicable laws, regulations and conventions, as well as with best practices, applying the highest labour standards prohibiting explicitly slavery and human trafficking. We expect our suppliers and subcontractors of the latter to apply the same respect for applicable laws and ethics principles. Consequently, the Group has developed a Code of Conduct applicable to its suppliers in order to align them in compliance with human and fundamental rights. Suppliers have agreed to comply with applicable labour and safety laws and to provide safe and healthy working conditions for employees in accordance with applicable laws and other relevant industry standards.

Particularly, the Supplier Code of Conduct establishes, among other, the following obligations:

prohibition of forced labour: any use of forced, bonded or indentured labour, involuntary or exploitive prison labour, slavery or trafficking of persons is strictly prohibited. This includes transporting, harbouring, recruiting, transferring persons by means of threat, force, coercion, abduction, misleading practices or fraud for labour or services. All work must be voluntary, and workers shall be entitled to accept and leave their employment freely;
prohibition of child labour: referring to any person under the age of 16 or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 shall not perform work that may jeopardize their health or safety;
prohibition of harassment treatment;
prohibition or illegal employment: suppliers are expected to comply with local regulations and procedures during the hiring process. Workers must be provided with a written employment agreement in a language they can understand that contains a description of the terms of employment; and
prohibition of discrimination.

Suppliers must ensure that any subcontractors involved in the supply of raw materials and/or production processes comply with the Group’s Supplier Code of Conduct, which implies a responsibility to communicate its content and ensure that all measures are implemented accordingly.

Anti-Bribery and Corruption Policy: We encourage employees to act righteously by clearly stating the actions and behaviour expected of them when representing the business. The aim is to reduce exposure to regulatory risks of a criminal nature, and in particular to crimes related to corruption, fraud and bribery, pledging to conduct its business in an ethical and honest manner and to act with fairness and integrity in all business dealings.
Whistleblowing Channel: We encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation and through confidential channels to protect identity. The responsible for investigating complaints processes to this channel is the Ethics Committee configured as an autonomous body when exercising its functions, organically and functionally dependent of the Board of Directors of the Spanish head company of the Group. The main mission of the Ethics Committee is to ensure compliance with the Code of Conduct and all other policies of the Group, as well as any internal rules or protocols adopted in order to strengthen the commitment to compliance with the law and the prevention, control and prosecution of regulatory violations especially of a criminal nature.

Procedures

We commit to regularly monitor the risk of modern slavery in our business and supply chain by considering the geography, the type of work being carried out and the type of labour being used. Based on this, we believe that the risk of modern slavery in our directly employed workforce is low, because our employees are well skilled and are undertaking work in controlled environments where there are established policies and processes.

Suppliers selection and onboarding procedure includes due diligence of the supplier’s reputation and its compliance with international and local laws and standards. We require all suppliers to attest that they do not use any form of forced, compulsory or slave labour; their employees work voluntarily and are entitled to leave anytime; they provide each employee with an employment contract; they do not withhold employees’ salaries for any reasons and they do not require employees to surrender passports or work permits as a condition of employment. However, Pronovias reserves the right to review the business relationships and possibly terminate them if suppliers fail to demonstrate compliance with the laws and code of conduct or to implement appropriate corrective actions to improve performance.

The selection of suppliers is governed by criteria of objectivity and transparency reconciling the Group’s interest in obtaining the best conditions with the convenience of maintaining stable relationships with ethical and responsible suppliers. The Group’s Spending Approval Committee, which reviews the spending proposals and budgets provided by the various suppliers, is required to apply the principles outlined above.

Additionally, the Group has contracted an external provider of risk and compliance services, to improve the 'know your customer' process. This service includes a database consultation tool that identifies and evaluates criminal risks when establishing new business relationships with relevant customers and contracting services and products with key suppliers.

As indicated above, in order to ensure compliance with the Supplier Code of Conduct throughout the duration of the agreement, Supplier shall provide on demand all elements requested to establish such compliance, and shall inform Pronovias without any delay, when it knows or has any reason to know of any failure to comply with the Code of Conduct, either by itself or by any subcontractor, as well as the corrective measures adopted to improve or correct any deficiencies identified. The Group and/or its authorized representatives are entitled to perform compliance audit activities to evaluate suppliers’ actual conformity to the Code of Conduct.

Steps taken in 2020 and future progress

Since 2019, the Pronovias Group has introduced a Strategic Supplier Management function which main objective is to impart to the entire Group strict guidelines for supplier selection and onboarding, to conduct periodic supplier evaluation reviews based on performance and risk analysis, and to provide strategic guidelines aimed at optimizing the supplier base.

In 2019, the Pronovias Group presented to its board of directors a five-year strategy for specific supplier compliance (factory improvement program or "FIP Program") and the same was integrated into the Group's corporate social responsibility strategy.

Following the FIP Program execution, the Group developed the first Group Compliance Standards ("GCS"), which include:

a classification of types of non-compliance by product suppliers (categorized between non-compliances that cannot be tolerated and those from highest to lowest level of relevance);
a formal supplier authorization process; and
all procedures for enforcing the code of conduct at different stages of a supplier collaboration.

At the end of 2019 the Pronovias Group signed a 3-year collaboration with the company ECOVADIS to carry out a corporate social responsibility supplier rating service through a global software platform in order to execute the FIP Program. Suppliers are ranked based on 3 criteria (country risk index, business involvement and previous proven compliance experience) and are contracted in order of priority.

In 2020 the Group had to suspend the launch of the evaluation of the factories to be carried out by ECOVADIS due to travel restrictions caused by the COVID-19 crisis. In 2021, the Group plans to resume the program, starting with a first remote phase.

Pronovias Group will apply an approach aimed at obtaining inputs through the collaboration of suppliers, limiting on-site audits (SMETA 4 pillars) to cases of serious non-compliance detected during the assessment processes, in order to achieve the highest number of participants in the FIP Program.

Participation in the FIP program will be a mandatory prerequisite for starting or continuing the business relationship with the Pronovias Group. The SSM will monitor the outcome of the FIP Program and the evaluation of suppliers. The objective is to steadily increase the degree of supplier participation year after year to achieve a minimum participation of 80% of the supplier base (first and second tier) by 2025 and to have in the same period a minimum of 80% of suppliers scoring above the satisfactory level.

Lastly, Pronovias Group employees receive Code of Conduct training trough Pronovias Group training internal platform. In 2021 the Group plans to review its Code of Conduct and launch a training to all its employees, with the aim set to disseminate the ethical values of the Group and establish the lines of conduct of the members of the organization in the performance of their professional and business activity anywhere in the world.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Pronovias UK Limited’s slavery and human trafficking statement. Additionally, through this statement, Pronovias Group also satisfies the disclosure requirements pursuant to the California Transparency in Supply Chains Act 2010. Our Senior Management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources and investment to ensure that slavery and human trafficking is not taking place within the organisation and within the supply chains.

Amandine Ohayon

C.E.O. Pronovias Group

28 June 2021