MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT 

2021

01. Introduction

Aromatherapy Associates recognizes its responsibility to address and mitigate the risk of modern slavery and human trafficking in its
operations and supply chains. This statement sets out our commitment to eradicating these abhorrent practices and describes the actions we have taken through the end of our fiscal year, August 31, 2020. This statement meets the requirements of the UK Modern

Slavery Act 2015 and the California Transparency in Supply Chains Act of 2010.

 

Through this statement, we confirm our commitments to the Consumer Goods Forum (CGF) resolution against forced labour and to

the Employer Pays Principle, which state that every worker should have freedom of movement and that no worker should be indebted

or coerced to work or pay for a job.

02. Structure, Business & Supply Chains

Corporate Social Responsibility is embedded in our drive to operate both a sustainable and profitable enterprise and is at the core of our
everyday work.

We regularly review our Corporate Social Responsibility program, policy statements and progress toward achieving our 12 commitments, including our commitment to drive responsible sourcing practices throughout our supply chain, protecting human rights and engaging with suppliers around ethical and environmental issues.

We recognize that the goal to eliminate modern slavery can be achieved only through long-term partnership and collaboration between businesses, non-profit groups and governments.

 03. Policies

As part of the WBA group, Aromatherapy Associates follow the Code of Conduct and Business Ethics available on the Governance section
of their website, which provides the foundational standards for all aspects of our business and applies to all of our employees and operations globally.

The Code makes clear our commitment that: “(w)e will also strive to ensure that slavery and human trafficking is not taking place within any of our supply chain business partners and will not tolerate such activities either within the supply chain or within any part of WBA’s business.” The Code further sets forth the responsibility of every employee to help ensure all of WBA’s global activities meet our high standards for behaviour and business ethics, and establishes accountability for compliance with law and policy.


These issues are also addressed in their Human Rights Policy Statement and in their Supplier Code of Conduct, which were published on their corporate website in January 2021, and which state our opposition to the exploitation of workers through any form of forced or bonded labour, slavery, human trafficking or other labour practices that involve harsh or inhumane treatment.


With regard to our own labour practices, the WBA Code of Conduct and Business Ethics and our corporate values of trust and inclusion set
forth our standards for a diverse and inclusive workplace that provides a safe and healthy environment and that complies with or exceeds
local law. The WBA Global Human Resources Policy requires an effective program be in place to help address the reporting, investigation,
and disposition of any potential modern slavery claims within our own business while also ensuring compliance with labour laws involving
migrant and foreign national workers.As we are a global company with businesses in many countries, local policies provide additional guidance and detail on these issues. However, local policies may only inform Aromatherapy Associates if their standards are equal to or stricter than those of WBA.

Regarding potential violations or concerns within our supply chains or our own workforce, our Code of Conduct and Business Ethics provides confidential reporting helplines managed by external service providers that can be used to report any concerns. These contact points are available 24 hours a day, seven days a week and in a number of languages. Any reports are thoroughly

 

 04. Supply Chain Due Diligence 

As described above, Aromatherapy Associates’ permanent working group on modern slavery considers more fully our company’s risk of
exposure to these practices and risk mitigation activities. Following a previous review of potential exposure to modern slavery, the group
developed a continuing action plan targeting the highest risk operations through a phased approach.


Aromatherapy Associates works with multiple service providers to facilitate risk and compliance due diligence reviews of business partners
globally. These reviews may include active monitoring for adverse media regarding modern slavery and other issues.
New suppliers are assessed prior to onboarding and then actively monitored for a minimum of one year. Existing suppliers will be monitored
on an ongoing basis.

Our commitment to eliminating modern slavery starts with focusing intensely on our owned brands supply chain where we believe we can have the greatest impact. This includes maintaining and continually assessing and enhancing our well-established program of supplier assessment, which is delivered through our own ethical trading auditors or a small number of pre-approved third-party assessment bodies.
Our ethical trading experts across the globe meet on a regular basis to ensure the program remains effective and drives best practices
throughout our supply chain.


We ensure our owned brand suppliers are fully aware of our standards and expectations. This is achieved through supplier manuals, contracts, technical agreements and mandatory ethical compliance assessments. Suppliers must further agree to provide evidence of their related compliance programs, which should also include a process for assessing the ethical standards of their own supply chains. Analysis of our assessment program shows levels of compliance with our ethical trading standards are significantly higher for existing sites than for new
sites. This reflects increasing understanding and commitment from our supply chain to maintaining our standards.


We also have in place a formal escalation process whereby any modern slavery “Zero Tolerance” violations or other serious violations
of our standards that we become aware of are reported to the senior management team within 24 hours, along with the results of any
investigations.


In fiscal year 2020, the WBA group conducted more than 900 ethical compliance assessments on new and existing suppliers. Our assessment
ratings are defined by the severity and/or number of incidents of noncompliance identified during the assessment process, these are currently defined as:


- Satisfactory and Needs Improvement: Meets our ethical trading standards expectations but could require differing levels of remedial
corrective actions


- Critical: Falls below the expectations of our ethical trading standards and requires immediate remedial action to address the critical
incidents of noncompliance to enable new or ongoing business relationships


- Zero Tolerance: Issues identified that are not accepted or tolerated by our businesses and are related to incidents of the following but
not limited to:


• Child Labour


• Convict/Indentured/Forced Labour


• Corporal Punishment


• Slavery and Human Trafficking


• Acts of Bribery


• In all cases we view these issues as Zero Tolerance.