Social Responsibility

U.K. Modern Slavery Act 2015
1. Business Overview
J.Crew is an internationally recognized multi-brand apparel and accessories retailer that differentiates itself through high standards of quality, style, design and fabrics. We are a vertically-integrated omni-channel specialty retailer that operates stores and websites both domestically and internationally. We source our merchandise through the use of buying agents and by purchasing merchandise directly from trading companies and manufacturers. Our sourcing base currently consists of over 200 vendors who operate 339 factories in 25 countries. Our top 10 vendors supply 40% of our merchandise. Each of our top 10 vendors uses multiple factories to produce its merchandise, which we believe gives us a high degree of flexibility in placing production of our merchandise. All Agents, factories, and suppliers are subject to the compliance policies set forth in this statement.

2. Anti-Slavery and Anti Human Trafficking Policies
At J.Crew, we believe that we have a responsibility to source our products in a legal, ethical and responsible manner consistent with the highest standards. This includes our commitment to ensure that no forced labor, whether in the form of human trafficking or indentured labor is taking place in any parts of our business or in our supply chain.

To this end all of our associates are expected to act professionally and ethically and comply with all applicable laws where we do business and must certify the Code of Ethics and Business Practices. If associate believes that they are witnessing or suspecting unethical conduct, which they are unable to address with management or HR, they can call “The Open Talk Line” resource that allows associates to report concerns 24/7.

In our supply chain, all of our suppliers, factories and contractors are required to adhere to our Code of Vendor Conduct, which prohibits the use of forced labor of any kind, including slavery and human trafficking. Our vendors are contractually required to comply with our Responsible Sourcing Supplier Guidelines, which outlines our requirement that our vendors need to verify that their own suppliers operate according to our Vendor Code of Conduct principles.

3. Risk Assessment, Due Diligence & Enforcement
We have a comprehensive Responsible Sourcing program in place to evaluate and address risks in our supply chain, including the risk of human trafficking and slavery. Our inspectors are trained in identifying any potential risks of forced labor or human trafficking. We determine our inspection strategy based on country and industry risk as well as previous inspection reports.

We conduct both announced and unannounced inspections of manufacturing facilities. A typical inspection covers code elements ranging from health and safety, wages, working hours to forced labor and consists of document reviews, private worker interviews and a walk-through of the facility. When appropriate, we will also conduct surveillance and off-site interviews. In cases where there is a higher risk of potential forced labor, we will conduct targeted inspections.

Should issues of noncompliance be identified during our inspections, it is our practice to work with suppliers to address these issues. We aim to provide suppliers with the tools they need to improve working conditions, including training and in-factory consultations, and we will conduct re- inspections when necessary to verify improvement.
However, we will terminate a business relationship, if identified issues are not resolved to our satisfaction, if a critical issue of noncompliance is repeatedly identified or if a supplier does not share our commitment to the principles laid forth in the Vendor Code of Conduct.

4. Training & Capacity Building
All J.Crew associates are trained in the Code of Ethics and Business Practices and must complete a refresher online training once a year. Among other expectations, associates are expected to act professionally and ethically and comply with all applicable laws where we do business. Any failure to comply with the Code of Ethics and Business Practices could lead to corrective action, up to and including termination. Associates and management, who have responsibility in managing and monitoring our suppliers, have been trained on the risks of human trafficking and slavery.

In addition to internal trainings, we regularly conduct Responsible Sourcing training seminars for suppliers. These seminars focus on our Code of Vendor Conduct program requirements and other relevant topics, including working hours and overtime, health and safety and management systems. In some cases, we have conducted specialized supplier training focusing on risks associated with migrant labor and additional requirements to ensure fair treatment.

5. Effectiveness
The principles laid out in our Code of Ethics as wells as in our Vendor Code of Conduct aim to clearly communicate our zero tolerance stance towards unethical conduct and any form of forced labor in our business or supply chain.

Our internal grievance mechanisms, as well as our continuous monitoring efforts at our factories help us to identify risks, and to assess whether our guidelines are being followed by our associates and supply chain partners.

Modern Slavery and Human Trafficking are serious issues. Based data from on the International Labor Organization there are currently as many as 21 million affected victims. We acknowledge the risks of forced labor in our global supply chain and understand the importance of the requirements of Section 54 of the UK Modern Slavery Act.

At J.Crew, we are committed to strengthening our internal processes, working with our suppliers as well as industry groups, governments and other stakeholders to develop strategies to address modern slavery and human trafficking in our supply chain. This statement covers the reporting period of February 1st 2016, to January 31st 2017, and has been approved by the Board of Directors of J.Crew Group, Inc. and is made on behalf of all J. Crew subsidiaries including J. Crew U.K. Limited.

Jim Brett, CEO, J.Crew Group