UK Modern Slavery Act 2015

1. BUSINESS OVERVIEW

Diane Von Furstenberg is an internationally recognized multibrand apparel and accessories retailer that differentiates itself through high standards of quality, style, design and fabrics. We are a vertically integrated omnichannel specialty retailer that operates stores and websites both domestically and internationally. We source our merchandise by purchasing merchandise directly from trading companies and manufacturers and through the use of buying agents. Each of our vendors uses multiple factories to produce its merchandise, which we believe gives us a high degree of flexibility in placing production of our merchandise. All agents, factories and suppliers are subject to the compliance policies set forth in this statement.

2. ANTI-SLAVERY & ANTI-HUMAN TRAFFICKING POLICIES

At Diane Von Furstenberg, 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 to ensure that no forced labor, whether in the form of human trafficking or indentured labor is taking place in any parts of our business or in our supply chain.

In our supply chain, all of our suppliers, factories and contractors are required to adhere to our Code of Vendor Conduct, which prohibits the use of forced labor of any kind, including slavery and human trafficking. Our vendors are contractually required to comply with our Responsible Sourcing Supplier Guidelines, 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 labor 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 labor 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 labor, 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 reinspections 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. 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 toward unethical conduct and any form of forced labor 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 Labour Organization, there are currently as many as 21 million affected victims. We acknowledge the risks of forced labor in our global supply chain and understand the importance of the requirements of Section 54 of the UK Modern Slavery Act.

At DVF-SIERE, 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. This statement covers the reporting period for the fiscal year ending 31st of December, 2020, and has been approved by our senior management.