WATCHES OF SWITZERLAND GROUP PLC WATCHES OF SWITZERLAND OPERATIONS LIMITED
WATCHES OF SWITZERLAND COMPANY LIMITED
MODERN SLAVERY STATEMENT 2025
“Treating everyone with respect is a Company value and is at the core of who we are and how we do business. Across our Group, we are committed to working collaboratively with partners, suppliers and other stakeholders to support the aims of the UK Modern Slavery Act and to focus our efforts where we can drive the greatest impact.
We will not work with suppliers who do not comply with our ethical standards and have zero tolerance for modern slavery and human rights abuses in any form, whether within our own operations, across our supply chains, or in any organisations connected to our business.
Our approach is designed to protect individuals from exploitation for personal or commercial gain, while upholding the highest standards of integrity and accountability. This includes strong governance and robust measures to identify, assess, and reduce the risk of labour exploitation.
If issues are identified, we will take action to address them and, where necessary, provide remedy. This Modern Slavery Transparency Statement outlines the progress we continue to make, since publishing our first Statement in 2016.”
B RIAN DU F F Y, CH I E F E XECUTIVE OFF ICE R
This Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the ‘Act’) and sets out the we have steps taken during the financial year 2024/25, to prevent slavery and human trafficking occurring in our supply chains or in any part of our business.
The Watches of Switzerland Group PLC’s (the ‘Company’ or ‘Group’) definition of slavery and human trafficking is aligned to section 54 (12) of the Act. The Group and its subsidiaries and affiliates fully support the aims of the Act and is committed to taking meaningful action to safeguard against the risk of slavery, servitude, forced labour and human trafficking in any part of its business operations or supply chain.
ORGANI SATION STRUCTU RE
The Watches of Switzerland Group is the UK’s largest luxury watch retailer, operating in the UK and US comprising seven prestigious brands; Watches of Switzerland (UK and US), Mappin & Webb (UK), Goldsmiths (UK), Mayors (US), Betteridge (US), Analog:Shift (US) and Hodinkee (US), with a complementary jewellery offering. The Group also owns the exclusive distribution rights for Roberto Coin in the US, Canada, Central America and the Caribbean.
As at 3 September 2025, the Watches of Switzerland Group operated 195 showrooms across the UK and US, including 84 dedicated
mono-brand boutiques in partnership with Rolex, OMEGA, TAG Heuer, Breitling, TUDOR, Longines, Grand Seiko, Roberto Coin, BVLGARI and FOPE. It also has a leading presence in Heathrow Airport with representation in Terminals 2, 3, 4 and 5 as well as seven retail websites.
Watches of Switzerland Group PLC and Watches of Switzerland Operations Limited, are holding companies of Watches of Switzerland Company Limited, with Watches of Switzerland Group PLC being the ultimate parent company. All UK companies within the Group comply with the requirements of the Modern Slavery Act 2015, through the operations of Watches of Switzerland Company Limited. An additional corporate entity operates in Ireland, WOSG (Ireland) Limited.
In addition, the Group operates a number of corporate entities in the United States (US), namely, Mayors Jewelers LLC, Mayors Jewelers of Florida LLC, Watches of Switzerland LLC, Watches of Switzerland (Nevada) LLC, Watches of Switzerland (A/S) LLC, Roberto Coin Inc and Hodinkee LLC. These companies are subsidiaries of Watches of Switzerland Group USA Inc, which is a direct subsidiary of Watches of Switzerland Company Limited.
This Statement is also made on behalf of the subsidiaries and affiliates of the Group and the detailed actions and operations are effective across it.
The Group recognises there are different laws across the world and market practice varies across the territories in which we operate, therefore, what is normal and accepted in one place may not be acceptable/permitted in another. While businesses must comply with local law and regulations, the United Kingdom (UK) Modern Slavery Act also applies to actions outside the UK. Therefore, the Group recognises it is liable under UK law for the actions of colleagues and service providers, wherever they are located.
BRANDS AND BUSINESSES COVERED BY THIS STATEMENT
This Modern Slavery Statement relates to all brands operated by Watches of Switzerland Company Limited in the UK and US:
BUS I NESS OPE R ATION
The Group directly employs approximately 3,200 colleagues globally, who occupy roles in retail outlets across the UK and US, as well as in head office, support centres, repairs centres, jewellery and silver workshops, logistics, warehousing, distribution and ecommerce.
Our Company Purpose to ‘WOW our clients, while caring for our colleagues, our communities and our Planet’ reflects our approach to human relations, however, we recognise there is a possibility of human rights risks linked to poor recruitment and management practices, lower skilled roles, low pay, peaks in workforce demand, excessive working hours, poor working conditions, inadequate training and a pressurised working environment. Actions to mitigate against these risks can be found on page 6 of this Statement.
SU PPLY CHAI N
The Group predominantly operates in countries where higher social standards apply and takes care to exercise due diligence in all its’ interactions. However, we acknowledge the highest risk of modern slavery and human rights violations occurs in our international supply chain, specifically if raw materials are sourced from conflict-affected countries, countries with poor human rights protections or countries in an environmentally fragile state.
Salient human rights risks identified within our supply chain include:
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Forced and bonded labour
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Excessive working hours
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Child labour
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Migrant labour
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Gender and discrimination
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Health and safety
*Supplier Partners with an
annual spend over £50K
1 United Kingdom
2 Thailand
3 China (inc. Hong Kong)
4 India
5 Italy
6 Lebanon
7 United States
8 France
2
6
4
4
5
7
3
8 1
SU PPLI E RS OF J E WE LLE RY
3
2
5
1
SU PPLI E RS OF WATCH ES
1 Switzerland
2 Germany
3 China (inc. Hong Kong)
4 Japan
5 United Kingdom
We partner with approximately 1600 Tier 1 stock and non-stock
suppliers* worldwide, including 15 watch and jewellery suppliers.
-
Wages and benefits
Our key suppliers are as follows:
Supplier
Product Type
Production
Rolex Watch Co Ltd
Watches
Switzerland
Patek Phillipe Ltd
Watches
Switzerland
The Swatch Group Ltd
Watches
Switzerland
Breitling Ltd
Watches
Switzerland
LVMH Watch and Jewellery Ltd
Watches and Jewellery
Switzerland and Italy
RLG Europe B.V.
Watches
Switzerland
Roberto Coin
Jewellery
Italy & Thailand
Athos Limited
Jewellery
Thailand
The Group also recognises the risk of Modern Slavery related to service providers we contract with. These suppliers support our organisation within areas including the cleaning of our showrooms and support centres, as well as construction, waste management, events and hospitality.
The actions we are taking to mitigate against these risks can be found throughout this Statement.
POLICI ES I N RE L ATION TO S L AVE RY AND H U MAN TR AFF ICKI NG
The Watches of Switzerland Group PLC Board (the’ Board’), chaired by Ian Carter, has overall responsibility for our business strategy and risk. The Board is supported by a number of Committees, including our Environmental Social and Governance (ESG) Committee, Audit & Committee and Remuneration Committee.
All independent non-executive directors are members of the ESG Committee, which is chaired by Non-Executive Director, Baroness (Rosa) Monckton, MBE. The Group’s Chief Executive Officer, Brian Duffy, is also a member of the ESG Committee and has executive oversight and responsibility for safeguarding against the risk of Modern Slavery within the Group’s business operations and supply chain.
The ESG Committee plays an active role in ensuring relevant ESG strategies, policies and processes are in place. The Audit & Risk Committee works in collaboration with the ESG Committee to ensure salient risks are regularly assessed and monitored.
The following policies relevant to Modern Slavery and Human Rights are in place and regularly reviewed and approved by the Board:
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Anti-Bribery, Corruption and Fraud Policy which include the Gifts and Hospitality Protocols
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Anti-Money Laundering
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Code of Ethics
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Corporate Criminal Offence Policy
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Human Rights Policy
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Modern Slavery Statement
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Supplier Sustainability Standards
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Vendor Code of Conduct
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Whistleblowing Policy
All of the above Polices can be found on our corporate website at thewosgroup.com.
OPERATIONAL INTEGRATION (Working Groups)
People
Planet
Product
EXECUTIVE ACCOUNTABILITY
(ESG Steering Group and Trading Board)
BOARD- LEVEL OVERSIGHT
(ESG Committee)
To further mitigate against human rights abuses in our supply chain, we continue to strengthen our governance mechanisms. An ESG Steering Group, which meets regularly, reports directly to the ESG Committee. This Steering Group is chaired by our Chief Financial Officer, Anders Romberg, and comprises senior leaders, who each have operational responsibility for the management of sustainability risks and opportunities across the Group.
Vendor Code of Conduct
Our Group Vendor Code of Conduct (the ‘Code’) sets out our minimum requirements across human rights, labour, environment, anti-corruption, integrity, business ethics, data security and social impact, which must be applied in addition to compliance with all relevant national and international laws and legislation.
Our Code is aligned with our Company Purpose and the Ethical Trading Initiative (ETI) Base Code, which is founded on the conventions of the International Labour Organisation (ILO).
The Code sets out 12 principles in relation to upholding human rights:
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Employment is freely chosen
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Freedom of association and the right to collective bargaining are respected
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Working conditions are safe and hygienic
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Child labour shall not be used
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Living wages are paid
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Working hours are not excessive
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No discrimination is practised
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Regular employment is provided
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No harsh or inhumane treatment is allowed
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Responsible environmental practices
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Zero tolerance of conflict products
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Zero tolerance of bribery and facilitation payments
All suppliers must read, sign and adhere to our Vendor Code of Conduct or publish an equivalent commitment which embeds basic business ethics principles, including adherence to local and national laws and regulations, specifi¬cally laws related to business ethics, responsible sourcing, human rights and environmental responsibilities.
Anyone with genuine suspicions about the contravention of our Vendor Code of Conduct is expected to report their concerns through our confidential global Whistleblowing platform, called Safecall, which has an independent reporting facility and is available in key languages for our organisation demographics.
Human Rights Policy
Our Human Rights Policy is approved by the Board and reinforces our commitment to protecting the enjoyment of human rights for all. This Policy was developed in accordance with the International Bill of Human Rights (comprising the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights).
In implementing this Human Rights Policy, the Group commits to:
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The ongoing assessment of our impact on human rights in our operations and supply chain
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Taking prioritised action to mitigate human rights risks in our operations and supply chain
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Ensuring grievance mechanisms, including a confidential whistleblowing reporting process, are strengthened to enable everyone we impact to raise concerns
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Remedying any adverse human rights impacts we cause, contribute to, or are linked with
Supplier Sustainability Standards
Our Supplier Sustainability Standards provide supplier partners with comprehensive guidance in relation to the high standards and common practices we expect throughout our global supply chain and in all our dealings.
These Standards support our Vendor Code of Conduct by detailing our expectations in relation to labour exploitation and human rights. Where relevant, supplier partners are required to:
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Respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Fundamental Rights at Work.
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Adopt and Implement the Organisation for Economic Co-operation and Development (OECD) 5-Step framework, as a management process for risk based due diligence for responsible supply chains of minerals from Conflict-Affected and High-Risk Areas (CAHRA’s).
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Ensure all polished diamonds originate from rough diamonds and are fully compliant with the Kimberley Process Certification Scheme (KPCS) and the latest World Diamond Council System of Warranties.
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Ensure all gold is sourced from bars accredited under the London Bullion Market Associ-ation Good Delivery Scheme or the UAE Gold Good Delivery Scheme.
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Take a zero-tolerance approach to bribery, corruption, money laundering or the financing of terrorism.
Our Vendor Code of Conduct, Human Rights Policy and Supplier Sustainability Standards are subject to an annual review and subsequent approval by the ESG Committee.
Compliance with our Vendor Code of Conduct and Supplier Sustainability Standards is supported by agentic AI, con¬figured to assess a supplier’s level of alignment with our requirements and expectations. For more information, see page 8.
PROGRESS I N 2024 / 5
During the reporting year, we continued to take meaningful steps to tackle modern slavery and human rights risks in our business and supply chain.
October 2024 • Great Place To Work®in the UK and US
March 2025 • New Procurement Policy and
Procedures
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Revised Supplier Sustainability Standards
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Agentic Al supplier screening
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Requirement for supplier audits of manufacturing sites
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SFA training for senior leaders
May 2025 • New supply chain management system
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Partnership with the Jewelers Vigilance Committee
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July 2025 • Global Procurement Analyst appointed
August 2025 • Escalation Process Workshop
September 2025 • Top 30 Places to Work in the UK