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
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:
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:
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
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;
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;
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:
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;
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:
The LVMH
Group also relies on dedicated measurement tools:
At Sephora UK
level, during the reporting period we:
In 2026, we
will:
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.