Cotton Policy

DAKS Simpson Group Plc (“DAKS”)

1. Introduction

DAKS recognises it has a responsibility to ensure sound social, ethical and environmental practices within its own operations and supply chains and that is the reason it has made commitments in this area in this DAKS Cotton Policy (this “Policy”). We are also committed to ensuring that all our procurement practices are carried out in the most sustainable and responsible way possible and this includes the responsible procurement of all raw materials sourced to produce any product involved in the DAKS business. DAKS understands the huge environmental and social impact the cotton industry has, globally. We also understand the responsibility we, as a consumer of cotton have, to ensure that the sourcing process is carried out with minimal negative impact on the environment and community at every stage of the supply chain. DAKS has set a target with the aim for the end of 2020 to have all of its main suppliers to sign up to this Policy, where possible.

2. Policy Requirements

We understand that cotton is an internationally traded commodity and that raw cotton sources are not always easily identifiable. However, with this Policy we are aiming to ensure that all materials used in DAKS products are sourced in compliance with the following principles:

2.1 Uzbekistan and Turkmenistan

DAKS will not knowingly accept any cotton or material that includes cotton that has been sourced from Uzbekistan and Turkmenistan. We will work to meet this commitment through mapping our directly procured supply chains and will work to support our service providers to undertake the same.

2.2 Traditional, civil & human rights and labour standards

DAKS will not accept violations of traditional, civil and / or human rights or non-compliance with labour standards as set out in ETI guidelines and in line with the UN Guiding Principles for Business and Human Rights.

2.3 Transparency

DAKS requires honesty and transparency from all suppliers. We recognise the complex nature of global cotton supply chains and the subsequent challenge associated with assuring 100% traceability from primary production level to finished product. In order to ensure sustainable sourcing throughout the supply chain, we aim to require our cotton to be traceable back to mill level and try to encourage our suppliers to continue mapping down to the primary production level, wherever possible. All available information relating to the supply chain and the environmental and social impacts pertinent to DAKS sourcing must be available for DAKS’s review upon request.

2.4 Legal compliance

To the best of DAKS knowledge, all sourcing methods will operate in compliance with all applicable local, national and ratified international laws and regulations.

2.5 Chemical use

DAKS understand that the nature and severity of impact caused by chemical use will vary depending on the geographical location and nature of production and processing sites. Wherever possible, DAKS requires suppliers to communicate that chemicals used during the production process will be used responsibly and that the storage, handling and disposal of all hazardous materials and waste will be done responsibly and legally, minimising respective potential environmental impacts. DAKS tries to encourage the use of biological or mechanical alternatives to pesticides where possible.

2.6 Water management

DAKS recognises the considerable water demand made by its cotton products. All suppliers are encouraged where possible, to conduct a water resource requirement and consumption assessment. This should consider the impact of water use and discharge. The aim of such an assessment should be to identify opportunities to reduce water consumption and mitigate the risk of any negative impact on water quantity or quality, ensuring no impact on biodiversity in the local area.

2.7 Greenhouse gas emissions

Suppliers are encouraged where possible to report to DAKS and set time bound targets with the aim of continually working towards reducing greenhouse gas emissions from their primary production, manufacturing or processing plant. This Policy’s requirements are relevant for suppliers at primary production level. DAKS’s ambition in this area is for its direct suppliers to work towards ensuring compliance throughout their own supply chains.

2.8 Protection and conservation of natural biodiversity and ecosystems

DAKS’s ambition in this area is for its direct suppliers to work towards ensuring compliance throughout their own supply chains of the following:

• Sourcing operations or production will not take place in areas deemed to be, to include, or be responsible for the maintenance of, high conservation value areas.

• Sourcing operations or production will not take place in areas where clearance of primary forest has taken place.

• The potential impact of sourcing operations on the existence and conservation of any threatened or endangered species will be identified and where relevant, the risk of negative impact will be

• Sourcing operations will ensure that the local biodiversity, natural habitat and ecosystem functions in the local environment are protected at all times.

• Pollution will be minimised throughout the production process and production waste must be managed responsibly. Organic waste should be reintroduced to the farm etc. wherever possible and feasible.

• Production will respect ecologically sensitive areas by keeping sufficient buffers which are actively managed and restored. Buffers to public areas like roads and human settlements will be
maintained, where applicable.

• Production sites will diversify their systems to increase environmental and economic sustainability.

2.9 Soil Management

As a matter of best practice production, DAKS would aim to have its suppliers develop a Soil Management plan in order to protect soil from erosion and degradation as much as possible, maintaining the productivity and long-term viability of soil used in the production of cotton. This may involve the soil structure (e.g. availability of surface and ground water), organic matter content, nutrient status and microbiological health.

2.10 Pesticide and fertiliser use

DAKS would aim where possible for any Producer to adopt measures to improve the crop’s resilience against pests and its economic viability. Fertiliser application will be based on evaluation of needs by taking soil-borne nutrients, soil conditions and input from non-mineral sources into account. Fertiliser and pesticide will be stored, handled and disposed of safely and in a manner that does not pose a risk to water pollution or health risk to those who apply it. Primary producers will strive to reduce the amounts of pesticides used over time and records of use are to be kept up to date.

2.11 Water use

DAKS would aim where possible that water used for irrigation of cotton fields stems from sustainable sources, will be recharged wherever possible and will be deemed safe for crop, soil and human health. Measures to optimise water use for irrigation will have been scoped and adopted.

2.12 Community Engagement

DAKS where possible, encourages suppliers to ensure there are open and effective lines of communication with key stakeholders in the local communities in which sourcing takes place. This communication should be known to the local community and used to inform the supplier on pertinent local issues relating to cotton production and also as a means for workers and farmers to report any issues or grievances to the DAKS supplier. Community engagement will also be used to identify opportunities to provide local employment where possible.

3. Certification and Accreditation

DAKS recognises the Better Cotton standard, as a sustainable source of cotton. We understand the complexity of cotton supply chains and the challenge that exists in ensuring 100% responsible and sustainable supply. DAKS will where possible encourage its suppliers to support Better Cotton within our supply base, wherever possible. More information on Better Cotton is available on the following link:

4. Principles of Implementation

As a form of good practice DAKS is aiming to keep a record of all cotton and cotton product suppliers and endeavours to monitor the performance of all suppliers of products covered by this Policy through direct communication, desk based review and, where relevant, third party verification. We are committed to periodically reviewing this Policy to ensure it is up to date, relevant and conducive to driving continuous improvement throughout our supply chain. In order for suppliers to effectively implement this Policy, DAKS is in the process of encouraging them to:

• Communicate this Policy throughout their own supply chain, to mill level at a minimum.

• Confirm in writing a willingness to comply with this Policy.

• Demonstrate traceability and legality of all cotton sources down to mill level at a minimum.

• Provide evidence of efforts to ensure that cotton and / or processed cotton goods are not procured from Uzbekistan.

• Provide documentary evidence confirming Better Cotton, has been sourced where possible and relevant for DAKS product.

• Ensure DAKS representatives, including third party auditors are given uninhibited access to sites used to produce DAKS goods and that all documentation is accurate and complete.

• Accurately and transparently communicate when these standards are not being met or are unlikely to be met and when support is required to meet these standards.

• Ensure transparency of performance against DAKS’s target to sustainably source critical commodities and demonstrate a proactive commitment to support DAKS in achieving its targets through conformance with this Policy.

Updated August 2018