17


Kingfisher Modern Slavery Act Transparency Statement 2024/25


Introduction


Suppliers & customer offer


Governance


Policies


Risk assessment


Working with suppliers GFR


Working with suppliers GNFR


Going beyond audit


Whistleblowing & escalation


Employee training


Partnership & collaboration


Looking to the future


GNFR


Goods Not For Resale


These are the goods and services we use to operate our business, such as IT equipment, cleaning, security services, and logistics. They’re sourced from over 11,100 GNFR suppliers in our direct (Tier 1) supply chain.


In 2024, we saw a reduction from the 11,800 suppliers we worked with in 2023. While our supplier base does fluctuate year on year, this large shift in supplier numbers was the result of an internal consolidation exercise to ensure accurate reporting.


We continue to work with suppliers to ensure they comply with our policies. Progress has been made this year in a number of areas:


— Due to the changed global landscape, we have investigated and interrogated our risk within our GNFR supply chain with the help of Slave-Free Alliance, to create our GNFR ethical risk matrix. This piece of work has identified the number of low-, medium- and high-risk suppliers we have in each of our three purchase categories (in terms of spend) and will be used to inform our risk-based approach.


— Based on the risk matrix, we can focus more on our suppliers and target them


based on risk level and spend. This is a significant shift for us as it means we can be more focused in our approach. Next year we can put more of this into practice. We are also shifting our reporting internally to the number of compliant suppliers rather than spend.


— In 2024 we focused on engaging with stakeholders internally. For example, multiple teams, including Responsible Business, Legal Compliance and Finance, worked together to identify suppliers we actively want to work with from a risk-based perspective and to consider where we need more due diligence and where we can have a lighter touch approach. A planned outcome from this work is a preferred supplier list enabling informed decisions across the business.


— We are supporting our suppliers to improve their scores through our EcoVadis Improvement Programme. Responsible Business and Group Procurement teams now hold monthly meetings to discuss ongoing activities and workstreams, ensure alignment and support reporting.


All new GNFR suppliers must adhere to our Responsible Business policies as part of the contract negotiation process, and we embed human rights criteria into new


supplier contracts. The supplier assessment programme for GNFR has two phases, depending on our annual spend with the supplier.


Phase 1: Vendor Engagement Assessment (VEA)


Our Vendor Engagement Assessment (VEA) tool is used to conduct due diligence checks on GNFR suppliers. It must be completed before we buy any GNFR goods or services above £5,000 (or equivalent in local currency) for annual recurrent or one-off estimated spend with:


— A new supplier (VEA takes place during the tender process before the contract is signed).


— An existing supplier where the contract conditions have changed, for example due to a large change in scope of work, goods/ services to be provided in a different country, or a different estimated spend.


The VEA process screens for:


— Integrity (e.g. risks of payment of bribes by third parties representing Kingfisher).


— Data protection due diligence (e.g. processing of customer and colleague personal data by third parties).


— Types of service being provided for goods.


— Information security (e.g. protection of Kingfisher data to be shared with or accessed by third parties).


— Ethical practices (e.g. modern slavery, labour conditions).


— Credit check (for contracts above a spend of £75,000 or equivalent in local currency only).


— Cybersecurity protection.


The VEA process includes a newly enhanced due diligence screening service provided by the Dow Jones Risk Centre platform. This covers risk on corruption, modern slavery, environmental issues, a sanctioned country list, sustainability and issues found available in public sources. We receive alerts regarding any new risks and any concerns are identified and followed up.


If there is a significant regulatory change, new questions are added to the VEA to help ensure continued compliance with relevant requirements.


Screwfix (via Kingfisher’s Global Business Services centre in Krakow) has created a new tool which automates the VEA process, making it easier to use. This will be rolled out to other banners. The Data Protection team has also added generative AI-related questions in the VEA as well as data protection assessments.


We are integrating our new tool with some of the systems we use for due diligence processes, particularly Dow Jones and One Trust, and will use the tool to send specific questionnaires to suppliers based on the research findings.


Phase 2: EcoVadis Sustainability Assessment


We request that suppliers with an annual spend greater than £75,000 complete a regular EcoVadis Sustainability Assessment as part of the tender process, in addition to the VEA process. New contracts include a requirement for the EcoVadis assessment to be completed within 12 months.


EcoVadis is a third-party assessment tool and collaborative platform, used by more than 150,000 companies. It covers four themes:


— Labour and human rights — Environment — Business ethics — Sustainable procurement


Supplier assessments are reviewed by EcoVadis and a scorecard is provided highlighting strengths, weaknesses and risk areas.


The methodology behind EcoVadis’ medal rating system was revised last year, so we are unable to make accurate year-on-year comparisons. The new scoring methodology will be in use going forward.


We have also run all our suppliers’ tax codes through the EcoVadis system, to find any suppliers that have not shared their EcoVadis scorecard.


Historically we have focused on a spend- based approach for prioritising EcoVadis


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