Modern Slavery Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (MSA). It sets out the steps Watchfinder.co.uk Limited (Watchfinder, we, us, our) has taken during the 2022/2023 financial year to prevent slavery and human trafficking from taking place in its supply chains or in any part of its business. It also sets out the additional steps we plan to take going forward.

I.Forefront

1.INTRODUCTION

Watchfinder is committed to improving its practices to combat slavery and human trafficking and to ensure that our business and supply chains are free from the same.

2.ABOUT WATCHFINDER

Watchfinder, established in 2002, buys and sells luxury pre-owned watches (the Products). Watchfinder markets, distributes and sells the Products through its own retail boutiques and wholesale channels within the United Kingdom and Ireland.

Watchfinder also provides after-sales care for the Products and offers a repair service in the UK.

II.Organization, structure and supply chain

1.ORGANISATIONAL STRUCTURE

Watchfinder is part of the Richemont group (the Group) and our ultimate parent company is Compagnie Financière Richemont SA, Chemin de la Chênaie 50, 1293, Bellevue, Switzerland. In the UK, our immediate parent company is Richemont Holdings (UK) Limited. The Group owns a number of luxury brands (Maisons) in the Jewellery, SpecialistWatchmakers, Online Distributors and Other (primarily fashion and accessories) sectors. Whilst each Maison within the Group operates as an autonomous business, the Group provides certain centralised support services including in relation to supply chain compliance, sourcing and procurement. Consequently, the Group works with the Maisons to set the required standards and to implement requisite policies and procedures which each Maison and each legal entity within the Group is expected to adhere to.

Locations and employees

Watchfinder has a corporate office which includes an after-sales service centre, which is located Kent. We also directly manage six boutiques within the UK.

We currently have 236 employees.

2.MANAGEMENT STRUCTURE

Watchfinder is managed by an Executive Committee (ExCo) comprising key managers within the business. There are four statutory directors.

3.SUPPLY CHAINS AND PROCUREMENT

As Watchfinder is not a manufacturer of the Products that it sells, sourcing of raw materials is not a direct concern. However, Watchfinder acknowledges that sourcing of raw materials and indirect procurement within many businesses’ supply chains could be susceptible of human rights impacts such as modern slavery. Watchfinder sources its Products directly from consumers and reputable traders.

Raw materials

Watchfinder purchases Products ‘ready-made’ and because we are not involved in the manufacture of the Products, we have limited need for raw materials.

At Group level, the responsible procurement of raw materials such as gold, diamonds, leather, and precious stones is a priority. The Group’s overarching ambition is to improve sustainability in its supply chains.

Responsible Sourcing Organisation

In order to tackle the challenges in terms of human rights, social and environmental sustainability, the Group counts on a team of experts in Responsible Sourcing. This team assists the Group on the identification, assessment, prevention and mitigation of potential human rights abuses thanks to its expertise in the field.

III.Policies in relation to modern slavery

The Group’s human rights commitment is integrated in the Group and Maison core policies, including:

-Richemont Raw Material Sourcing Policy; -Richemont Standards of Business Conduct Policy; -Richemont Supplier Code of Conduct; and -Richemont Corporate Responsibility Policy.

The Group’s policies apply to all our product lines, all our activities and our entire supply chain, especially our suppliers, as their day-to-day practices reflect on our Maison.

Raw Materials Sourcing Policy

The Group operates a Raw Materials Sourcing Policy (www.richemont.com/media/ilci5h3t/richemont-raw-materials-sourcing-policy-en.pdf) (Sourcing Policy) which describes the human rights impacts that can be associated with the extraction, transportation and trade of precious metals, diamonds and gems. The Sourcing Policy clearly highlights the Group’s commitment to respecting human rights and it states that the Group will neither tolerate nor profit from any abusive act. This is reinforced by the Group’s intended implementation of human rights due diligence management systems based on the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Minerals – 5-Step Framework (5-Step Framework): establish management systems, identify and assess risks, risk management, third-party audit and annual reporting.

Standards of Business Conduct Policy

The Standards of Business Conduct (www.richemont.com/media/ngadkqes/standards_of_business_conduct_eng.pdf) delineates specific standards of ethical behaviour expected from employees. The business and human rights section of the Standards of Business Conduct further highlights the Group’s commitment to respecting and promoting human rights as described in the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct.

Supplier Code of Conduct

All relevant Watchfinder suppliers must comply with the Supplier Code of Conduct (www.richemont.com/media/ec3hryfn/richemont_scc_eng.pdf) (the Supplier Code). The Supplier Code sets out the Group’s expectations of suppliers with respect to ethical business practices, labour conditions, employment practices, human rights and environment. It is aligned with the MSA and the main International Labour Organisation Conventions, the Universal Declaration of Human Rights and other internationally recognised labour and practice standards.

Suppliers with whom we contract directly will also be required to adhere to the Supplier Code. During the year, the code of conduct was updated to reflect the developed changes on the Speak Up tool. The code is available in 13 languages on the Group's website.

Corporate Responsibility Policy

The Group also operates a Corporate Responsibility Policy (www.richemont.com/media/hfzpaqu0/richemont_cr_policy_16052019.pdf) which serves as a common framework for all business activities across the Group.

Separately to this the Group publishes a Slavery and Human Trafficking Statement which contains further information and can be viewed here: slavery_human_trafficking_statement.pdf (richemont.com) Watchfinder’s business is centred around the circular economy, promoting sustainable and reliable distribution of luxury watches.

Watchfinder also provides its part-exchange service through 80 boutiques globally (both Watchfinder and third party operated.

Further information about Watchfinder’s part in the circular economy is available in Group’s sustainability report, which can be found here: https://www.richemont.com/media/zimbq1ew/richemont-esg-report-2023-en.pdf. Besides the different policies that the Group has, it recognises that criminal organisations, who are often behind illicit trade, are also complicit in child labour and modern slavery crimes. The Group is a member of the Transnational Alliance to Combat Illicit Trade (TRACIT), an independent, private sector initiative to drive change to mitigate the economic and social damages of illicit trade.

In terms of governance sustainability is firmly embedded at the highest governance level of the Group through the Governance and Sustainability Committee, which reports its actions to the overall Board. Established in March 2021, this committee reviews all management proposals regarding our sustainability roadmap, including those related to human rights. It is also to be highlighted the appointment of the Group’s first Chief Sustainability Officer in 2022 who joined the Senior Executive Committee in 2023.

The Group also cascades through the Watchfinder the commitment of Group on respecting human rights, and recognizes the role that all of its employees play when it comes to preventing and mitigating any adverse impact. In this sense, all new Watchfinder employees are asked to read and acknowledge the Group’s Standards of Business Conduct mentioned in this statement.

At the time of publishing this statement, the Group is developing a range of training modules, which will showcase why human rights are relevant to everyone. The training will also be made publicly available and support the implementation of the Richemont Speak Up Platform. Also, a mandatory training on Modern Slavery and Human Trafficking is available for all Group employees. This course will introduces learners to ways of recognizing human trafficking and how international, complex organizations can positively impact human rights. Alongside generic training for all employees, risk mapping helps to direct the content of tailored training programmes and the identification of specific teams or groups of employees who will receive training on specific topics.

The Richemont Speak Up Platform is an integral part of the Group’s ethical infrastructure. In June 2022, the internal Richemont Speak Up Platform was launched to replace the Group’s previous whistleblowing process and procedure. The Speak Up Platform allows employees to report concerns through a telephone call or an online form, with an option for anonymity. These reports are sent to the Richemont Speak Up Taskforce, a group of coordinators from relevant functions within the Group.

To promote the Speak Up Platform, Richemont launched a general awareness campaign via the Group’s intranet and provided Groupwide training. In FY23, 28 385 Group employees completed the training on Speak Up relating to report concerns and how these concerns are dealt with. The platform is available to all global operating entities, including all Maisons. Concerns are confidentially addressed and individuals who report issues are supported. Richemont has a zero-tolerance policy for any retaliation to anyone who makes report in good faith or participates in an investigation. A concern can be reported to the Speak Up platform through the online process or via telephone and the status of an existing question or concern can be checked on the platform. The Speak Up platform is accessible on the intranet for employees and will be made available on the Group’s external facing website and can used by external stakeholders such as suppliers, clients, business partners and the wider public. This allows a broader range of individuals, regardless of location, to voice their concerns and contribute to the Group’s ongoing commitment to transparency and ethical conduct. The extension of the Speak Up Platform to external shareholders took place in May 2023 and we are aware that this action is beyond the reporting timeframe, but we consider relevant to mention it here.

IV. LOOKING AHEAD

Both Watchfinder and the Group are planning to expand their expertise in the field of human rights with dedicated teams and close collaboration with operational teams on due diligence related matters. Given the scale of our operations and the ongoing cycle of our due diligence process, we expect our statement to evolve. More information about future plans at a Group level can be found in the Sustainability Report, and in the Group Slavery and Human Trafficking Statement.

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Watchfinder’s slavery and human trafficking statement for the financial year ending 2023. It was approved by the board on 07-Mar-2024 and the information contained in this Statement is accurate as of that date.

……………………………………………
Patrick Addor
Director, Watchfinder.co.uk Limited

07-Mar-2024