BERLUTI SA
Anti Modern Slavery Statement 2025
Introduction
This Anti Modern Slavery statement is published by BERLUTI SA ("BERLUTI") pursuant to section 54 of the Modern Slavery Act 2015 and was approved by the Board of BERLUTI on 30th June 2025. The statement is updated annually.
Since the publication of its first Anti Modern Slavery statement in June 2017, BERLUTI and its affiliated companies (together the "BERLUTI Group") have continued to strengthen their efforts across their sourcing and operational supply chains to combat modern slavery. The BERLUTI Group has also sought to work ever more closely with its suppliers to ensure that their workforce, as well as the workforce within their own supply chains, including contractors, are treated with respect and dignity.
Pursuing its roadmap, BERLUTI has maintained processes in its relationships with all its stakeholders to ensure they share common standards and principles. In parallel, BERLUTI has continued to implement actions and internal rules aimed at preventing and combatting slavery and human trafficking from taking place in its supply or operation chains.
BERLUTI recognises that its ethical trading program requires constant monitoring and improvement.
Business
BERLUTI, the French parent company of the BERLUTI Group is owned by the LVMH Moet Hennessy Louis-Vuitton SE Group ("LVMH").
BERLUTI is the owner of the BERLUTI trademark and tradename.
BERLUTI sells luxury and high quality products under the BERLUTI trademark including shoes, leather goods, bags, accessories, ready-to-wear, home decoration, etc. (the "Products"), to clients in Europe, including in the United Kingdom, as well as in many other countries worldwide.
Supply chains
Products are mainly manufactured through BERLUTI's industrial subsidiary.
For any sourcing needs, BERLUTI purchases the services and products necessary to run its business directly from local suppliers.
Policies and Practices
BERLUTI's commitment is to act with integrity in all its business dealings and to promote ethical conduct, to ensure compliance with applicable laws and to provide guidance with
respect to business conduct. It has implemented several policies that are relevant to this commitment, which set out what BERLUTI expects from its employees, contractors, and
its external suppliers and their supply chain.
BERLUTI engages in multiple internal and external actions to gauge and combat the risk of modern slavery, including human trafficking occurring in its supply chains, and to assess and manage potential risks related to its supply chain. BERLUTI's due diligence includes internal risk assessments utilizing information gathered from organizations with expertise in social compliance issues, other companies, and various additional external resources.
In the context of the European Union directives regarding duty of vigilance, BERLUTI intensified its audits on direct and indirect sourcing production suppliers throughout its supply chain, to ensure compliance with the below-listed policies and ethical standards. No major issue has been identified.
Key policies and practices are:
1. LVMH Group Suppliers and Business Partners Code of Conduct
In 2024, the LVMH Group updated its Suppliers Code of Conduct to turn it into a wider Suppliers and Business Partners Code of Conduct (the "Code"), in order to include all its external stakeholders.
The Code applies to all LVMH Group Maisons, including BERLUTI. The Code accordingly helps Maisons maintain a consistent approach to their suppliers and supply chains, including in relation to combating the risk of modern slavery.
The Code includes several new and updated commitments to reflect changes in the law and societal norms, notably one new commitment inserted to help protect local or indigenous communities.
The Code requires suppliers to commit to implement an alert line for their own workers and stakeholders. It provides suppliers with access to the LVMH Alert Line where they can raise suspected or witnessed ethical breach, including suspicion of modern slavery.
Penalties for non-compliance of the Code include the right for the Maison to require a supplier to take corrective action and to refuse to take delivery of products until the violations are remedied to its satisfaction, as well as the right to terminate the business relationship (subject to compliance with legal duties and obligations). The Code also includes an audit clause allowing the Maison to conduct an audit, including in the suppliers' premises.
In 2025, the systematic signature of the LVMH Suppliers and Business Partners Code of Conduct remained mandatory in the framework of the suppliers' creation process. According to the LVMH process, no exception is allowed.
2. Supplier and Contractor due diligence
BERLUTI ensures that its new suppliers are carefully chosen for the entire BERLUTI Group and that prior to entering into any new contractual relationship with a supplier or contractor, they commit to comply with the Code.
BERLUTI reserves the right to check adherence of its suppliers and contractors to the principles set out in the Code and to conduct compliance audits at anytime, according to an audit matrix grid shared by the LVMH Group.
Upon reasonable request, BERLUTI can require its suppliers and contractors to supply requested information and grant access to BERLUTI representatives to verify compliance with the requirements of the Code. Suppliers and contractors are obliged to keep proper records to prove compliance with the Code and to provide access to complete, original, and accurate files to BERLUTI's representatives.
Where deficiencies are identified during an audit, BERLUTI's suppliers and contractors are required, within a certain timeline, to improve and correct such deficiencies. Counter audits are carried out to check the remediation measures implemented by the suppliers following the action plan provided by BERLUTI.
BERLUTI requires its staff, suppliers, and their supply chains to engage in and promote honest and ethical conduct, act in accordance with our values and culture, comply with all applicable laws, rules and regulations in their own area and act responsibly, with due care, competence and diligence when dealing with staff, customers, suppliers, agents, and intermediaries.
As such, BERLUTI has amended its Terms and Conditions and template contracts to make suppliers more accountable for the conduct of their eventual subcontractors. The signature of a contract or the Terms and Conditions is a mandatory prerequisite without which BERLUTI would not enter into relationship.
3. Staff/ Employees
• Training and Awareness
According to the guidelines from the British Standards Institution, specifically BS 25700:22 titled "Organizational responses to modern slavery - Guidance", it is acknowledged that practices of modern slavery are possible across all nations and sectors of industry. Additionally, it highlights certain elements that may heighten the likelihood of such exploitation. These include discriminatory practices rooted in ethnic background, gender identity, social caste, tribal affiliation, religious beliefs, as well as issues surrounding bribery and corruption.
In response, the LVMH Group launched a new dedicated e-learning module campaign, in 2024, related to anti-corruption and anti-bribery, and the LVMH Code of Conduct, to help its and its Maisons' employees prevent, and sanction bribery or corruption. A record of attendance is maintained and completion has been strictly monitored throughout 2025. Most exposed population have all followed the training.
In 2023-2024, BERLUTI provided specific anticorruption training to employees with direct responsibility for supply chain management and supplier selection in particular. This will be renewed in 2026.
The purpose of BERLUTI's ethics and compliance training program is to ensure that BERLUTI is promoting a working environment where all individuals are equipped with the ability to identify unethical or potentially unethical practices as they perform their day-today work.
• LVMH Employees’ Code of Conduct
The LVMH's Employees' Code of Conduct, signed by all the Group's employees (including BERLUTI's employees) and received and signed during all new staff onboarding, demonstrates BERLUTI's ambition for its staff to act with, and commit to, integrity in the conduct of its business in an environment that is free from all form of unethical behaviour including forced or compulsory labour, child labour, slavery, human trafficking, discrimination, corruption and harassment and therefore provides a common framework of values and principles to provide guidelines to its staff.
In 2024, the LVMH Group has also updated its Employees' Code of Conduct along with the publication of a brand new Anticorruption Charter. This has been communicated to all BERLUTI employees at worldwide level in 2024. In 2025, the adherence and signature of BERLUTI newjoiners to the Code of Conduct is monitored.
The Employee Code of Conduct is available in 25 languages and is divided into three chapters: 1) a committed Group; 2) a responsible employer and 3) a Group with integrity.
Each employee must personally comply with these commitments in all circumstances. Any failure may be subject to disciplinary measures and sanctions proportionate to the
seriousness of the actions. Such sanctions may include dismissal.
• Whistleblowing Policy /Internal Alert Systems
All members of staff or external partners with inquiries regarding the interpretation of our company's internal policies, or who wish to raise ethical concerns, are encouraged to voice their concerns or seek guidance through our whistleblowing alert system. Our whistleblowing system aims to encourage all members of staff or external partners to identify and raise concerns of past, present, or future wrongdoing, whether suspected or witnessed, including in relation to modern slavery within BERLUTI Group or our supply chains, using appropriate, confidential channels.
In addition, any employee who becomes aware of a breach of applicable laws or regulations, our Code of Conduct, or any directives, procedures or policies issued by BERLUTI and/or the LVMH Group, is encouraged to report it to the Human Resources department or directly to their Maison's Ethics and Compliance Officer.
In addition, the LVMH Group provides all employees and associated parties with access to the LVMH Alert Line, a digital platform which ensures anonymity and security for those wishing to report, in good faith, any breaches of legal obligations or internal ethical standards. The persons authorized to receive and process alerts, as well as their content, are contractually bound by strict confidentiality obligations.
In 2025, all employees continued to have access to the whistleblowing alert system and received regular reminders of the principles set out in the Employee Code of Conduct whenever new communications regarding BERLUTI's ethics and compliance policies were circulated internally.
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes BERLUTI's Anti-Modern Slavery statement for the financial year ending 31 December 2025.
The Board of Directors of BERLUTI has approved this statement and it has been duly signed by the following director:
Jean-Marc MANSVELT
Président du Directoire – Berluti SA
Date: 30 June 2026