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Kingfisher Modern Slavery Act Transparency Statement 2024/25


Introduction


Suppliers & customer offer


Risk assessment


Given the size of our global supply chain, we adopt a risk- based approach, prioritising the most significant human rights and modern slavery risks.


Our ongoing due diligence processes continually mitigate and address human rights risks within our business and supply chains, and we collaborate with suppliers, peers, industry bodies, non-governmental organisations (NGOs) and governments to raise standards.


Across the Group


To focus our activities, we prioritise and frequently review the salient human rights risks identified as part of the Saliency Assessment.


Saliency Assessment


We continue to utilise the Saliency Assessment conducted in 2020, as the identified salient issues remain relevant to our business, operations and global supply chains. The assessment involved a detailed risk and gap analysis to understand where salient risks are most likely to occur within our business and supply chain. It was informed by engagement with nearly 100 colleagues across the organisation, findings from our materiality assessment (which examined 25 key raw materials used in our products), external human


rights frameworks (such as the UN Guiding Principles on Business and Human Rights), external risk assessment tools, and ongoing engagement with civil society and industry organisations including Slave-Free Alliance, ELEVATE and allianceHR.


These findings confirmed that our most significant human rights risks are present within our supply chains, particularly at the raw material extraction and product manufacturing stages. These are:


Modern slavery


Child/underage labour Freedom of association/ collective bargaining


Health and safety Wages/working hours Land rights Depletion of natural resources Impact of climate change Air, water and land pollution Discrimination


Human Rights Gap Analysis


In 2023, as part of our ongoing partnership with Slave-Free Alliance (SFA), we requested them to conduct an independent Human Rights Gap Analysis, identifying good practices and areas for improvement across our operations and supply chain. This review assessed our approach to modern slavery and labour exploitation risks, ensuring alignment with relevant legislation and industry best practices.


Slave-Free Alliance engaged with key internal stakeholders, including the Human Rights and Modern Slavery Working Group, alongside teams from Responsible Business, O&S (GFR), Group Procurement (GNFR), Logistics, Legal Compliance, Internal Audit/Risk, People/HR, Inclusion and Diversity, and banner Sustainability leads.


This aligns with the previous Saliency Assessment findings, confirming those risks remain relevant.


The gap analysis process also helped us identify vulnerable people groups that may be found within our supply chains and operations: indigenous communities, migrant workers, minority ethnic groups, agency and temp workers, children and young workers, female workers and remote/isolated workers. Additionally, the salient human rights issues previously identified in our Saliency Assessment were confirmed as still relevant key risk areas within our supply chains.


To address the findings from the gap analysis we implemented the following updates:


— Human Rights Policy update: We revised our Human Rights Policy to clarify our expectations regarding ethical standards for third-party marketplace suppliers. These requirements are now embedded within the marketplace Terms & Conditions, which outline the minimum standards all sellers must meet to operate on our platform.


— Legislative preparedness: We commenced preparations for upcoming European legislation, including the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).


— Internal alignment and implementation: We strengthened collaboration between Group and retail banners. This included issuing detailed work instructions from Group to banners, outlining what policy compliance looks like in practice and how it should be applied operationally.


Ongoing approach


We continue to integrate gap analysis recommendations into our approach to modern slavery, ensuring we prioritise vulnerable groups and implement targeted policies, programmes and activities to mitigate risks. The Saliency Assessment remains a relevant tool in our ongoing approach to supplier engagement and our ‘beyond audit’ programmes, which aim to address wider issues and root causes in our supply chain.


The gap analysis process also helped us to identify vulnerable people groups that may be found within our supply chains and operations.


Indigenous Communities Migrant Workers Minority Ethnic Groups Agency and Temp Workers Children and Young Workers Female Workers Remote/Isolated Workers


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


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