Modern Slavery Act

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

’47 Brand Europe Limited – Financial Year 2025

Introduction
Modern Slavery is a crime in a number of countries, including in the United Kingdom, and a violation of fundamental human rights. It can take various forms, including slavery, servitude, forced and compulsory labour, child slavery and human trafficking. ’47 Brand Europe Limited (“47 Brand”) is committed to acting ethically and with integrity in all business dealings, running the business responsibly and respecting human rights in that regard. 47 Brand is committed to preventing modern slavery and human trafficking within the business and expects the same from its direct supply chain.

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 (Transparency in Supply Chains) and sets out the steps 47 Brand has taken during the financial year ending 31 December 2025 to prevent modern slavery and human trafficking in 47 Brand’s business and supply chains.

About 47 Brand
47 Brand is a premium sports lifestyle brand rooting in a tradition of quality craftsmanship dating back to 1947.  We design, source, and sell apparel, headwear, and accessories globally, with products available in more than 80 countries.  47 Brand has a long-standing commitment to social responsibility in the manufacture of our products, and we select third-party manufacturers who share our commitment to human rights and environmental sustainability.

47 Brand has an operational footprint in the UK through its ecommerce business and its wholesale and retail activity 

47 Brand Policies
47 Brand’s Workplace Code of Conduct is based on internationally recognised labour and human rights standards (the “Code”).  It includes provisions prohibiting all forms of forced labour, such as prison labour, indentured labour, bonded labour and human trafficking.  Our Code requires, among other things, that:

  • Workers retain possession and control of their personal identification documents;
  • No mandatory overtime or excessive recruitment fees are imposed; and
  • Workers’ freedom of movement is not unreasonably restricted. 

All employees are provided with a copy of the Code and are required to adhere to its terms.

Due Diligence 
47 Brand’s Global Compliance Programme puts its principles into practice across our supply chain through:

  • Education and training for workers and suppliers;
  • Announced and unannounced audits of Code compliance;
  • Remediation of non-compliance findings;
  • Supplier sharing of best practices; and
  • Ongoing stakeholder engagement.

Before placing production with any new supplier, we require the supplier to agree to comply with our Code and all applicable laws (applying the higher standards where differences exist).  Our Manufacturing Agreement contractually binds our suppliers to these standards, and we reserve the right to terminate any supplier found to be in material non-compliance.

In addition, we voluntarily participate in the Fair Labor Association (FLA), a multistakeholder nonprofit organisation that evaluates and publicly reports on company social compliance programmes.  Annual public reports on our progress are available on the FLA website.  

Risk Assessment and Management
Our supply chain risk assessment evaluates factors related to human rights, labour rights, and environmental impact.  Key elements of our approach include:

  • Prohibiting production in certain countries in which there are documented widespread government-sanctioned forced labour;
  • Assessing whether suppliers employ migrant workers, who may be more vulnerable to exploitation;
  • Conducting targeted audits where foreign migrant workers are employed, covering all stages of the hiring and employment process; and
  • Requiring that employment terms, safety training, and grievance mechanisms are communicated to workers in their native language.


Measuring Performance
We measure supplier compliance through both announced and unannounced audits, which include confidential worker interviews, management interviews, record reviews, and facility walkthroughs.  Suppliers are evaluated against performance indicators covering hiring, compensation, health and safety, grievance procedures, discipline, and working hours. Where non-compliance is identified, we work with the supplier to address root causes and develop sustainable remediation plans.  Supplier compliance performance is incorporated into each supplier’s scorecard alongside quality, delivery, cost, and service metrics.

Training
We provide training to our employees and suppliers on our Code standards, including education on forced labour indicators and risks, relevant regulations, and how to identify and prevent potential violations. Our social compliance team also participates in industry seminars and stakeholder forums to ensure we are adopting best practices.

Steps taken in 2025 
Over our last financial period ending 31 December 2025, 47 Brand has taken the following steps to support the continuing review and development of our approach:

(a)   Conducted its annual review of this statement and the underlying compliance policies to confirm continued alignment with applicable laws and 47 Brand’s broader compliance program;

(b)   Continued to embed modern slavery and ethical conduct considerations into 47 Brand’s internal compliance framework, including periodic review of related policies and procedures;

(c)    Reinforced employee awareness of 47 Brand’s commitment to ethical business practices through internal communications and onboarding materials provided to relevant personnel;

(d)   Made available confidential reporting channels for employees and other stakeholders to raise concerns relating to modern slavery, human trafficking, or other ethical issues, and continued to review the effectiveness of those channels;

(e)   Continued to engage relevant internal functions – including legal, compliance, and sourcing – in identifying and addressing modern slavery risks across the business;

(f)     Required new and existing factories to complete supplier assessments and undergo third‑party social compliance audits prior to engagement, with timely remediation of any identified issues;

(g)   Continued to require its suppliers to comply with 47 Brand’s code of conduct, which prohibits forced, prison, indentured, bonded, and child labor, as well as harassment and discrimination in the workplace;

(h)   Maintained the right to conduct announced and unannounced monitoring of supplier facilities, including access to relevant personnel, premises, and records, and required suppliers to refrain from retaliation against workers who participate in compliance activities; and

(i)     Continued to monitor supplier performance and required corrective action where appropriate, consistent with 47 Brand’s commitment to continuous improvement of working conditions across its supply chain.

Further Steps 
Throughout the next financial year, 47 Brand will maintain its commitment to preventing modern slavery and human trafficking within its business by, for example, continuing to implement the due diligence and risk assessment and management processes described above. 47 Brand will also continue to measure supplier compliance, through the processes described above. 47 Brand will also consider where any improvements can be made to the Code and/or other relevant company policies, processes and practices and methods to guard against any modern slavery and human trafficking in its operations.

Reporting Concerns
If you have any concerns about modern slavery or human trafficking in relation to 47 Brand or our supply chains, please contact us at customer.care@47brand.eu.

This statement has been approved by the Board of Directors of ’47 Brand Europe Limited. We will continue to publish an updated statement annually.

Alan Jones, Director, 18/09/26

For and on behalf of the Board of Directors

’47 Brand Europe Limited