Consumer Conduct Policy

1. Purpose

At Clarks we are committed to providing outstanding customer service and ensuring the satisfaction of our valued consumers. We recognise that from time to time issues may arise that require our attention.

We believe our customers have every right to voice their frustrations, provide constructive criticism and if necessary make an official complaint, in line with our consumer complaints policy. This is helpful for us and enables us to review the feedback and make improvements to our processes and the service we provide our customers ensuring any mistakes do not happen again.

Unfortunately, on rare occasions, our staff face difficult, abusive, threatening and even violent behaviour from customers and members of the public whilst carrying out their daily duties on behalf Clarks which is unhelpful and unacceptable.

This policy outlines the steps that Clarks will take in recognizing and defining the unacceptable behaviour as well as protecting our people from harm and distress when carrying out their work. This ensures a consistent response to anyone that engages in this unacceptable behaviour.

2. Key Principles

We will not tolerate unacceptable behaviour directed towards our people during any form of interaction, including:

• during a phone call
• face to face
• in an email or webform
• on our online Live Chat service
• over social media
• or any other form of communication Clarks International
• Our definition of unacceptable behaviour includes:
• Physical violence, unwanted physical contact, or threats of physical violence or unwanted physical contact.
• Use of inappropriate language, verbal or written, which may cause our people to feel scared, upset, humiliated, intimidated, threatened, offended, or distressed. This could be:
• Remarks that insult someone’s intelligence or character.
• Derogatory or offensive remarks about someone’s sex, age, disability, race, country of origin, accent, religion, sexual orientation, gender reassignment or other protected characteristics
• Harassment or repeated unwanted contact.
• The rallying of family members, friends or supporters to carry out any of the unacceptable behaviour listed above.

3. Policy In Action

Our people in customer-facing roles are trained on how to manage contact with frustrated customers or members of the public and on our official complaints procedure.

If the voicing of the frustrations or complaint progresses into unacceptable behaviour directed at an employee personally, they will do the following:

• Issuing warnings to consumers and set clear expectations for respectful conduct
• If we believe that we have taken every step to resolve a consumers query or complaint we reserve the right to withdraw from any further communication with that consumer in the light of vexatious or malicious behaviour
• Limiting or terminating business relationships with consumers who engage in persistent vexatious or malicious behaviour despite warnings.
• In exceptional cases, security teams in shopping malls and centres will be contacted by a store team member, to escort the consumer from Clarks premises for the purpose of protecting Clarks employees
• In extreme circumstances individuals will be blocked from contacting consumer service agents, consumer executives and retail premises which does not impact their consumer rights
• In severe cases, legal action will be taken to protect employees from harm.