Modern Slavery Act

Modern Slavery and Human Trafficking Statement

Focus International Limited T/A Focus Brands – A Hela Apparel Holdings Company

This statement constitutes Focus Brands’ slavery and human trafficking statement for the year ending 31st March 2024, and has been published pursuant to Sec 54 of the UK’s Modern Slavery Act 2015. The statement will be reviewed and updated annually and will be approved by the Board of Directors.

As a company, we, Focus Brands, have a zero-tolerance policy on all types of modern slavery and human trafficking and are committed to improving our practices against slavery and human trafficking in our business, operations, and supply chain.

About Us

Focus Brands is a market leader with decades of experience in design, sourcing, distribution and promotion for sports fashion and lifestyle brands. We specialise in clothing, footwear, and accessories, building and nurturing leading consumer brands in both the UK and globally.

Our vision is to be the go-to business for brands looking to maximise their potential in a dynamic and ever-changing market.

Our Business

Focus Brands deals with complex global licensing, subsidiaries and distributor networks, and a controlled supply chain. We manufacture our product collection in over 60 factories located in 4 countries through our key suppliers. Our suppliers and our tier 1 production factories are fully mapped and audited for social and ethical compliance by verified independent auditors annually. Focus Brands also monitors non-compliances, working and living conditions, worker and structural safety, applicable local regulations and their remediations through our policies and evidence checked through corrective action plans, and collaborates with independent social welfare organisations.

No subcontracting of production is permitted unless expressed in advance and approved by Focus Brands, and is subject to all standards and requirements as our tier 1 factories.

Our Policies

Our suppliers are bound to abide by our policies in place that monitor modern slavery and human trafficking and ensure business is conducted ethically.

We have identified key risk areas in the supply chain and have created policies accordingly that cover, but are not limited to:

• Supplier Code of Conduct and Global Sourcing Policies
• Restricted Sourcing and Substances Policy (including restricted countries for production)
• Anti-Bribery Policy and Corruption Policy
• Nominated Suppliers – Trims and Packaging Sourcing
• Supplier Manual and Shipping Guidelines

To date, Focus Brands has not been informed of any incidents of slavery or human trafficking – however, we will investigate allegations of any such incidents thoroughly and take the appropriate action as per our supplier terms of contract.

Our Commitment

Focus Brands is continuously working to increase transparency and traceability further down the supply chain, and aims to conduct due diligence visits by both internal employees and external auditors to ensure compliance of suppliers and manufacturers. We are committed to continually monitoring, assessing and combating any slavery and human trafficking in all areas of our business internally and externally in our supply chain and in all cases will address any incidents identified.

CEO

1st April, 2024