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MODERN SLAVERY STATEMENT 2025

Feelunique International Limited, trading as Sephora UK Statement made pursuant to section 54(1) of the Modern Slavery Act 2015 in respect of the financial year ended 31 December 2025

Contents

  1. Identification and entity presentation
  2. Organisational structure and supply chains
  3. Policies and governance
  4. Identified risks and findings
  5. Measures and actions
  6. Training
  7. Alert and remediation mechanisms
  8. Assessment
  9. Annual review

1. Identification and entity presentation

This statement is issued for Feelunique International Limited, a private limited company with registered offices at Mowbray House, Castle Meadow Road, Nottingham, England, NG2 1BJ, registered in England and Wales under company number 07883226, trading as Sephora UK.

Sephora UK is active in the Selective Retailing division of the LVMH Group. As of 31 December 2025, it had 681 employees in the UK and Channel Islands (via its subsidiary CICG Limited), and its revenue for the reporting year 1 January 2025 to 31 December 2025 was £266,205,000.

At Sephora UK, we are committed to acting ethically and with integrity in all our business dealings and relationships. We promote compliance with applicable laws and protect the dignity and rights of all people connected to our business.

We strive to work ever more closely with our suppliers to ensure their workforce, and the workforce of their supply chains, are treated in the same way. At the heart of our mission lies a commitment to fostering inclusive workplaces and sourcing products responsibly.

As with all human rights violations, Sephora UK has a zero-tolerance policy regarding any type of forced labour, including modern slavery.

We recognise that stamping out modern slavery and associated risk is an ongoing process. This statement outlines the measures we have in place and the efforts we have commenced to assess and address any risks, including forced and child labour, across our business and supply chains.

2. Organisational structure and supply chains

Sephora UK is a subsidiary of the French company Sephora SAS, which is itself wholly owned by LVMH Moët Hennessy Louis Vuitton SE ("LVMH").

Sephora UK operates physical retail stores and an e-commerce website and a mobile app in the UK, offering beauty products from hundreds of brands to its customers.

Sephora UK does not purchase raw materials directly. Its suppliers in higher-risk sectors, such as on-site service subcontractors and logistics providers, are mostly UK-based, while cosmetics suppliers are located across the globe.

3. Policies and governance

3.1 LVMH Framework

The framework of the LVMH Group is anchored in a defined corpus of international standards:

  • the Universal Declaration of Human Rights;
  • the International Covenants on Civil and Political Rights and on Economic, Social and Cultural Rights;
  • the United Nations Guiding Principles on Business and Human Rights;
  • the fundamental conventions of the International Labour Organization;
  • the OECD Guidelines for Multinational Enterprises (notably Chapter IV on Human Rights);
  • the United Nations Global Compact;
  • the United Nations Declaration on the Rights of Indigenous Peoples; and
  • the United Nations Women's Empowerment Principles.

3.2 Key policies and procedures for our employees

Sephora UK expects all its employees to act with integrity and operate ethically.

Our Employee Handbook sets out our code of conduct, our responsibilities to our people, our whistleblowing policy and our approach to protecting whistleblowers.

Our key policies are:

  • LVMH's Code of Conduct for employees: LVMH's Code of Conduct is designed to provide a common ethical foundation for the Group and its Maisons, outlining the rules to be followed by all employees as they go about their work. The Code of Conduct was signed by all members of LVMH's Executive Committee when it was updated in April 2024, and applies to all employees in each Maison, across every business segment and geographic region. The Code of Conduct reflects LVMH's commitments in terms of ethics, and social and environmental responsibility, along with the recent initiatives taken in these areas, and refers to the charters and policies created within the LVMH Group to address these topics. Available in 25 languages on the LVMH website and on the intranet, it is communicated to all employees, in particular when they join Sephora UK. It also forms part of employee training to promote the LVMH Group's ethical culture and its principles. In addition to in-person presentations on this subject, an online awareness module was rolled out at LVMH Group level in the second half of 2024. It includes sections on "Respecting Fundamental Rights", "Compliance with Law & Regulations", "Promoting a kind, inclusive working environment", "Promoting a responsible approach among partners and suppliers" and "LVMH Alert Line".
  • Training: Sephora's anti-corruption training includes relevant information on "Compliance with Law & Regulations" and "How to report a concern". We raise employees' awareness of the risks associated with modern slavery.
  • Alert Line: our employees have access to the LVMH confidential whistleblowing helpline, which provides a confidential and secure way of reporting. The LVMH Alert Line is accessible here: LVMH Alert Line. Breaches raised through this helpline will be investigated by the LVMH Group Ethics & Compliance Director.
  • Recruitment checks: when hiring employees, checks are made to ensure that they have the right to work in the UK, and references are required and followed up.

All our key policies are available on our intranet and are communicated regularly by email to all employees.

3.3 Key policies and procedures for third parties

LVMH Supplier & Business Partner Code of Conduct

The Supplier & Business Partner Code of Conduct sets out the LVMH Group's expectations of its partners (suppliers, service providers, distributors, franchisees, specialist trades, lessors and any third parties in a business relationship with a LVMH Group entity) and their subcontractors in various areas, regardless of where they are based geographically and where they are located in the value chain.

The expectations concern corporate social responsibility and respect for human rights: banning forced labour, human trafficking and child labour, banning illegal or undeclared work, harassment, discrimination, measures relating to wages, working hours, freedom of association, health and safety, and protecting local and indigenous communities.

We require our suppliers and business partners to sign and comply with the LVMH Supplier & Business Partner Code of Conduct (updated September 2024, available at https://www.lvmh.com/en/ethics-and-compliance/lvmh-supplier-code-of-conduct). We also require that they ensure that their own subcontractors and suppliers do the same when performing activities for Sephora UK or the LVMH Group.

The Code of Conduct also gives each Group entity the right to check that its partners and subcontractors across its value chains comply with these principles. Sephora UK reserves the right to demand that compliance failures be remedied or that the business relationship be suspended or terminated, commensurate with the severity of the violations identified.

Sephora UK also requires its suppliers to complete a due diligence questionnaire addressing compliance with obligations relating to anti-corruption, anti-money laundering, the prevention of terrorist financing and economic and trade sanctions.

We are working to ensure that all contracts with our suppliers contain provisions confirming their compliance with the Modern Slavery Act 2015 and their commitment to ensuring that no unlawful practices occur within their business or any part of their supply chain that is subcontracted to a third party.

Suppliers also have access to the LVMH Alert Line. Breaches raised through this helpline will be investigated by the LVMH Group Ethics & Compliance Director.

These foundational documents are complemented notably by:

  • the LVMH Fair Wage Principles, developed in partnership with the Fair Wage Network and supported by annual salary surveys;
  • the Charter on Working Relations with Fashion Models (2017, jointly developed with Kering), currently being updated to reflect developments in the sector; and
  • the LVMH Anti-Corruption Charter (updated April 2024, available in 20 languages).

The LVMH Supplier & Business Partner Code of Conduct is also available online.

3.4 Governance

Sephora UK has implemented an Ethics and Compliance Committee, which oversees the deployment of the ethics and compliance programme as defined by the Sephora Global Ethics and Compliance department. It includes members of the HR, Legal and Compliance, Finance/Audit and Management teams.

At LVMH Group level, the Sustainability and Governance Committee of the LVMH Board of Directors ensures the implementation and monitoring of systems related to the duty of vigilance and respect for human rights. The Executive Committee upholds the Group's strong commitment to ethics and social and environmental responsibility, including in relation to modern slavery and forced labour.

Following the reporting period, in 2026 the LVMH Group strengthened its governance with the creation of the LVMH Group Vigilance Committee, overseen by the LVMH Group Managing Director and composed of four members of the Executive Committee: the Chief Financial Officer, the Human Resources Director, the Director of Image and Environment, and the General Administration and Legal Affairs Director. Its main responsibility is to set out LVMH's vision and strategic direction in relation to ethics, human rights and the environment, both within the LVMH Group and across all of the Maisons' value chains.

Operational coordination is provided by the Vigilance Task Force, which brings together seven LVMH Group functions (Environmental Development, Social Engagement, Ethics and Compliance, Industrial and Craftsmanship, Purchasing, Audit and Internal Control, and Corporate Affairs) and reports to the LVMH Group Vigilance Committee three times a year. The Task Force is responsible for establishing guidelines and standards applicable to all LVMH Group activities, coordinating and monitoring action plans across the Maisons and formalising the LVMH Group's Vigilance Plan.

Within most Maisons, Maison Vigilance Committees act as the operational relay of this framework. They are composed of the various functions involved in duty of vigilance issues and oversee the rollout of the vigilance approach at Maison level. The LVMH Group's vigilance approach is also supported by several communities of correspondents within the Maisons (in particular the Purchasing, Environment, CSR and Operations communities) who are fully involved in implementing the vigilance framework as part of their respective activities.

4. Identified risks and findings

The LVMH Group's risk mapping is built on the OECD Due Diligence Guidance for Responsible Business Conduct and on the United Nations Guiding Principles on Business and Human Rights.

The methodology used as well as a synthesis of priority risks identified by sector are described in the LVMH Group 2025 Vigilance Plan.

At present, Sephora UK believes risks lie notably with low-skilled or outsourced workers. Since many of these workers are not employed directly by Sephora UK, we ask all our suppliers and partners to sign the LVMH Supplier & Business Partner Code of Conduct to raise awareness of our standards, and we reserve the right to perform audits to gain more visibility over their working conditions and employment terms.

5. Measures and actions

The LVMH Group considers it important that the Maisons and the Group's partners abide by a shared body of rules, practices and principles in relation to ethics, corporate social responsibility and environmental protection.

The Convergence programme, which aims to engage the LVMH Group's partners in social and environmental issues, is based on the following main steps:

·       mapping of the LVMH Group's Tier 1 partners, and assessment of gross social and environmental risks based on the country, type of activity and the value of the corresponding service;

·       third-party assessment conducted through the EcoVadis platform, which evaluates suppliers on four criteria: environment, labour and human rights, ethics, and responsible procurement. In 2025, 2,838 suppliers were included in this assessment process;

  • on-site audits conducted by specialist independent firms. All workforce audits conducted at supplier sites include a systematic exchange with a representative sample of employees. In 2025, the LVMH Group conducted 4,630 on-site audits at 4,216 suppliers and subcontractors (versus 4,066 audits in 2024 and 2,021 in 2023) of which 1,973 were conducted at Tier 2 suppliers and beyond, notably in response to risks identified in Italy. Audits result in one of four ratings: satisfactory, needs improvement, needs major improvement, or unacceptable;
  • close monitoring of corrective action plans following audits: where non-compliance is identified, corrective action plans are systematically drafted with the supplier and their implementation monitored by the buyer responsible for the supplier relationship;
  • operational visits to partner sites, in addition to audits, in order to check the work environment and working methods, production capacity and traceability of work in progress, to ensure compliance and greater transparency in the supply chain;
  • active involvement in cross-sector initiatives covering high-risk areas: beyond individual supplier relationships, the LVMH Group actively participates in cross-sector multi-stakeholder initiatives in high-risk areas, including the Responsible Jewellery Council (RJC), the Responsible Beauty Initiative (RBI), the Responsible Mica Initiative (RMI), Action for Sustainable Derivatives (ASD) and the Utthan embroidery initiative in India, which in 2025 covered 3,700 workers and guarantees them a living wage and access to health insurance.

Sephora UK has identified certain suppliers considered to present elevated risk and has reviewed its contracts and practices accordingly.

In 2026, Sephora UK plans to roll out a dedicated modern slavery training programme to further strengthen awareness and risk identification across the business.

6. Training

"Responsible Procurement" training is provided to LVMH employees in direct relationship with suppliers, enabling them to be vigilant in their interactions with suppliers so that they can identify potential signs of non-compliance with LVMH's Supplier & Business Partner Code of Conduct.

In keeping with the aim of providing support and fostering continuous improvement, the LVMH Group and its Maisons regularly offer their suppliers training on responsible procurement.

In particular, the decision was made in 2021 to create an LVMH-wide training programme on this subject. The aim of this training is to equip employees who work with suppliers and subcontractors with a deeper understanding of responsible suppliers, responsible products and responsible purchasers. The training gives participants an understanding of the various risks associated with the working conditions of workers in the supply chain.

Delivery of this training programme began in 2022, and was further reinforced in 2023 and 2024, with sessions having taken place in France, Italy, North America and Asia. The content of this training was updated in 2025.

Sephora UK has trained all members of its management committee on their duty of vigilance obligations, raising awareness of human rights and forced labour risks. Further modern slavery training for a wider audience of Sephora UK employees is planned for 2026.

7. Alert and remediation mechanisms

LVMH encourages a culture of dialogue and communication within the LVMH Group. Any employees and external stakeholders who have questions about how to interpret internal regulations or have any ethical concerns are invited to make this known or ask for advice.

The LVMH Group has also implemented a whistleblowing system to collect and process reports submitted in good faith of illicit behaviour or behaviour contrary to its internal principles of conduct, which aims to protect whistleblowers and prevent potential negative effects on society.

Any current or former employee of the LVMH Group and any external LVMH Group stakeholder (including suppliers, subcontractors, etc.) can make a report from anywhere around the world. Reports can be submitted via the Maisons' internal channels (Human Resources and Ethics & Compliance officers) or via the LVMH Group's online platform, "LVMH Alert Line". This secure, centralised platform protects whistleblowers' anonymity and can be accessed in 15 languages, notably from the LVMH Group's website (https://www.lvmh.com/en/ethics-and-compliance/lvmh-alertline).

LVMH's Alert Policy sets out the reporting channels that exist within the LVMH Group as well as the rules governing how reports are received and processed. These rules detail how reports are screened, how corrective measures are taken where a breach of the LVMH Group's rules is identified and how whistleblowers are protected (in compliance with Directive (EU) 2019/1937 of 23 October 2019 relating to whistleblower protection and with French Law No. 2022-401 of 21 March 2022 aimed at improving whistleblower protection). Under the Alert Policy, whistleblowing investigations must be entirely confidential and independent, be completed within a reasonable time frame and be proportionate. The Maisons' Presidents are responsible for implementing this policy in their respective organisations.

The Alert Policy and whistleblowing system are explained in the Code of Conduct, and each Maison uses displays, written communications and other awareness-raising actions to make employees and external stakeholders aware of the system and policy. In addition, the Alert Policy is shared on LVMH's website and the intranets of the Maisons. The online training module related to the Code of Conduct, developed for all LVMH Group employees, also describes the reporting channels available and provides access to the Alert Policy. Furthermore, the Supplier & Business Partner Code of Conduct signed by the LVMH Group's business partners explains that suppliers and partners can use the LVMH whistleblowing system and contains a hypertext link to the LVMH Group's Alert Policy.

When an incident is reported on the LVMH Alert Line, it is received by the LVMH Group's Ethics & Compliance Department and then passed on to the Ethics & Compliance Officer of the Maison concerned for processing. As an exception, to ensure that reports received are treated impartially and objectively, some cases are handled by the LVMH Group if:

·       the incident reported relates to the governing bodies of the LVMH Group or the Maison concerned;

  • there is a potential conflict of interest or a situation that could compromise the impartiality of the Maison's Ethics & Compliance Officer; or
  • the report contains allegations of possible retaliation following a report handled by a Maison.

The LVMH Group ensures that there are no disciplinary measures or retaliation against whistleblowers who have reported an incident in good faith, or against anyone who has assisted them:

  • Human Resources ensures that the whistleblower does not experience any retaliation;
  • any person carrying out retaliation is subject to disciplinary procedures; and
  • those responsible for handling the reports are strictly required to maintain confidentiality and must sign a confidentiality agreement.

The Maisons issue regular communications about the whistleblowing system, notably when welcoming new employees, through training sessions, either in person or using communication materials such as displays or awareness videos. Employees are informed in particular about how they can access the system and the fact that the LVMH Group prohibits any retaliation against whistleblowers using the system in good faith. The effectiveness of these communications is reflected in the significant increase in the number of whistleblowing reports received through LVMH Group channels each year.

Internal guidelines specify the rules of the Alert Policy and the best practices to be adopted by employees in charge of processing and investigating reports received. These employees undertake regular training, which, among other aspects, covers the principles of confidentiality and impartiality to be applied during internal investigations, and the need to protect whistleblowers.

The Ethics & Compliance training programmes held in April and May 2025 provided ongoing training to 135 compliance officers on how to handle whistleblowing reports and apply the LVMH Group's internal whistleblowing investigation methodology. Similarly, in addition to Maison-specific training, in 2025 the LVMH Group trained over 300 human resources employees and directors tasked with handling whistleblowing reports within their Maisons.

Reports received are handled in compliance with the LVMH Group's Alert Policy and, where applicable, give rise to whistleblowing investigations – conducted in compliance with the relevant legal framework – and corrective actions, such as training, awareness initiatives, reminders about internal rules, termination of the business relationship with a LVMH Group partner, and disciplinary procedures, which can extend to employee dismissal. Alerts and the resulting corrective actions can be used to help improve risk identification and prevention procedures, as part of a continuous improvement approach specific to the LVMH Group's ethics policy.

In 2025, 2,280 reports were received via the LVMH Alert Line and other reporting channels specific to LVMH Group Maisons and entities (compared to 1,744 reports received as of December 31, 2024, via the same platforms and channels). The increase in the number of reports each year is testament to the growing understanding and uptake of the LVMH Group's whistleblowing system among employees and external stakeholders.

As of December 31, 2025:

·       74% of reports received during the year had been closed (the remaining reports, which were mainly received in the last quarter of 2025, were still being processed) and 47% of those closed reports were wholly or partly justified;

  • 51.3% of reports received contained allegations relating to human resources topics;
  • 77% of the 1,145 reports received specifically through the LVMH Alert Line were submitted anonymously; and
  • 64 reports received through the LVMH Alert Line were submitted by LVMH Group suppliers or subcontractors.

Sephora UK promotes access to the LVMH Alert Line via its intranet, in-store communications and regular email communications to all of its employees, both in stores and in offices.

8. Assessment

The LVMH Group tracks and publishes a structured set of quantitative vigilance indicators, updated on a regular basis and reported in the Universal Registration Document.

For 2025, key indicators include:

  • 4,630 on-site supplier audits at 4,216 suppliers and subcontractors (up from 4,066 audits in 2024 and 2,021 in 2023), of which 1,973 at Tier 2 and beyond;
  • 2,838 suppliers covered by EcoVadis assessment, with approximately 75% of reassessed suppliers improving their score;
  • 2,280 reports received across the LVMH Alert Line and the Maisons' internal channels, of which 1,145 via the Alert Line;
  • 99,495 employees trained in health and safety;
  • €44.1 million invested in health and safety; and
  • €288 million invested in improving working conditions.

The LVMH Group also relies on dedicated measurement tools:

  • The LVMH Global Pulse Survey, most recently conducted in 2024, with responses from over 145,000 employees across 18 languages, identifies workforce-related risk factors relating to employee engagement and well-being, the working environment and career development.
  • Annual salary surveys, conducted under the LVMH Fair Wage Principles in partnership with the Fair Wage Network, monitor compliance with the LVMH Group's living wage commitments; in 2025, the LVMH Group reported that all its employees were paid an adequate wage in line with CSRD requirements.

At Sephora UK level, during the reporting period we:

  • continued our efforts to classify supplier risks and map key parts of our supply chain to identify and improve our understanding of modern slavery risks;
  • continued to ensure that permanent employees acknowledge the applicable employee Code of Conduct. The number of permanent employees who have done so is tracked at least annually as part of the Ethics and Compliance Committee review; and
  • continued to raise awareness within our labour supply chains through the LVMH Supplier & Business Partner Code of Conduct, due diligence process and reporting channels.

In 2026, we will:

  • further develop our supplier risk classification and supply-chain mapping work to improve our understanding of modern slavery risks;
  • roll out a dedicated modern slavery training programme for Sephora UK employees; and
  • continue to strengthen awareness within our labour supply chains through the LVMH Supplier & Business Partner Code of Conduct, due diligence process and reporting channels.

9. Annual review

Sephora UK is committed to continually reviewing its policies, procedures and controls to mitigate the risks presented by modern slavery.

This statement will be reviewed and updated annually to reflect progress made in addressing the requirements of the Modern Slavery Act 2015.

This 2026 statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ended 31 December 2025 by Feelunique International Limited, trading as Sephora UK.

This statement has been approved by the Board of Directors.