GAME’s Ethical Trading Practices

Human Rights and Anti-Slavery Transparency Statement

The below statement has been prepared in accordance with the Modern Slavery Act 2015 (the “Act”) and sets out steps taken within the business to prevent slavery and human trafficking.

Our Business and its Supply Chains

GAME Digital Limited and GAME Retail Limited (“GAME”) fall under the ultimate ownership of Frasers Group plc. Prior to its de-listing from the London Stock Exchange in August 2019, GAME Digital Limited was the ultimate parent company of GAME.

GAME operates retail stores and concessions across the UK. The products GAME sells are sourced from a broad range of national and some international suppliers. Physical products range from gaming consoles, software and related accessories to merchandise including apparel. International supplier relationships are managed by our dedicated commercial teams.

Related Policies

When sourcing quality products for our business, we endeavour to partner with suppliers that comply with both the spirit and the letter of the law in relation to the prevention of slavery and human trafficking and share our core principles. These include not participating or working with organisations that operate inappropriate or unfair working practices. We look to ensure that our suppliers maintain satisfactory working conditions and comply with all legal requirements with respect to labour practices, health and safety, human rights and environmental protection standards of the countries in which their businesses operate.

Our values apply equally to all companies across the Group and are set out in our Business Code of Conduct which our suppliers are required to comply with. Our Business Code of Conduct sets out our policy on employees, legislation, child labour, conditions of employment, wages and benefits, health and safety, the environment and modern slavery and human trafficking.

Risk Assessment and Due Diligence

We work with reputable service providers, many of which are also subject to the Act. We take the management of our supply chain seriously and believe that it is important to responsibly select supplier partners.

Significant progress has continued to be made this year to improve the existing processes and controls that monitor modern slavery in our supply chain. This has included improving our modern slavery questionnaire and widening our review to contact all first tier commercial and non-commercial suppliers as part of an assessment of the businesses’ overall exposure to the risk of modern slavery and human trafficking.

All first tier suppliers have contributed their information and additional information has been sourced or requested to enable the business to get a full picture of risk. Each returned questionnaire has been reviewed and suppliers have been categorised as high, medium or low risk based on their responses. As a result of this review, several suppliers have been flagged as potentially being medium or high risk where, for example, their production facilities are located offshore or have failed to provide sufficient information or a completed questionnaire. We are in the process of performing a further risk assessment to determine a suitable action plan on how to treat these suppliers going forwards and, where appropriate, identifying the steps required to carry out audits with an external provider.

Where clear non-compliance with our processes by suppliers has been identified, we have terminated a small number of those contracts.

Our due diligence procedures for supplier on-boarding have also been updated to require first tier commercial suppliers to complete the modern slavery questionnaire prior to commencing a working relationship.

Ensuring Effectiveness

Whilst we have taken steps to analyse the risk that suppliers may pose and were satisfied with the responses to our initial enquiries, GAME will continue to monitor suppliers in this area. Should any instances of non-compliance with the Act arise in relation to any of our suppliers then this will be reviewed, and appropriate action taken.

Related Training

We continue to communicate the requirements of the Act to GAME’s key partners in the UK and briefing sessions have again taken place with the commercial and non-commercial representatives responsible for liaising with suppliers and the wider Group. We regularly communicate to the business updates to related policies that highlight the risk of modern slavery and have implemented a training video on modern slavery, both housed on our e-learning zone.

2020 Action Plan

We are aiming to build on the progress made in 2019, with the following action plan in place for 2020:

• Further investigate suppliers where we have identified as high or medium risk, through engagement or visits to supplier premises, conducted by an external assurance provider.
• Continue the assessment process on first tier, non-commercial suppliers.
• Continue to develop the e-learning programme, tailored to specific audiences in the business, ensuring annual refresher training is made compulsory for certain departments and completion rates monitored.

The above statement was approved by our board of directors of GAME Retail Limited and GAME Digital on 30 January 2020.