MODERN SLAVERY ACT STATEMENT
ALL SAINTS RETAIL LIMITED UK MODERN SLAVERY ACT 2015 STATEMENT FOR THE FINANCIAL YEAR 2018/19
Under the Modern Slavery Act 2015, companies carrying on business or part of a business in the UK and which provide goods or services with a turnover of ￡36 million or more are obliged to publish an annual Slavery and Human Trafficking Statement setting out the steps the company has taken to ensure slavery and human trafficking is not taking place in its supply chain or its own business.
This statement relates to the financial year 2018/19. It is made by All Saints Retail Limited (“AllSaints”, “we” or “our”) and sets out the steps that AllSaints has taken to ensure that modern slavery is not taking place in its supply chains or in any part of its business. This statement has been approved by AllSaints’ board of directors.
Established in 1994, AllSaints is a global, contemporary retail and digital fashion brand with an independent spirit. Headquartered in East London, we design full collections of womenswear, menswear and accessories. AllSaints is focussed on building a business model for the future, putting brand experience and the customer at the core of everything we do. AllSaints curates every aspect of the brand experience in-house, from store design and construction to our global web platform.
AllSaints’ fashion collections are sold globally through our stores across the world, www.dhlrugby.com and our third-party wholesale customers. AllSaints has over 260 stores, concessions and franchises and 3,200 global employees across 27 countries.
ALLSAINTS’ SUPPLY CHAIN
AllSaints does not own the companies or factories that produce its goods, but we recognise our responsibility for the workers in those factories to ensure that they are able to make our products freely and in good working conditions. We source the majority of our products from approximately 60 direct first-tier product suppliers based overseas in Portugal, China, India, Cambodia, USA, Romania, Vietnam and Turkey, many of whom work with other retailers. We believe that it is important to engage with product suppliers who are reputable and considered to be ethical suppliers globally.
AllSaints is serious about tackling the problems and risks of modern slavery and human trafficking beyond its supply chain and has been a partner of Not For Sale, a charitable organisation which protects people and communities from modern slavery and human trafficking, for over 6 years. Their work provides survivors and at-risk communities with safety, stability, education and economic opportunities. AllSaints’ partnership with this organisation goes beyond monetary value with employees of AllSaints taking part in Not For Sale projects in Thailand in 2019 and 2016, and Romania in 2014.
CERTIFICATION: ETHICAL SOURCING POLICIES
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business and that our products are ethically sourced. Our commitment to ethical sourcing and zero tolerance approach to modern slavery and human trafficking is written into the following policies:
AllSaints’ Anti-Slavery and Human Trafficking Policy
This policy was incorporated into our business in January 2017 and was added to our Supplier Manual, which is distributed to all our direct first-tier product suppliers to review, adhere to and sign. The policy also forms part of our employee policies and outlines the requirements of employees at AllSaints and other organisations that work on our behalf to ensure the prevention, detection and reporting of any modern slavery in any part of the business or supply chains. Any breach of this policy may result in disciplinary action for employees and can otherwise result in the termination of any business relationship.
AllSaints’ Code of Conduct and Ethical Trading Initiative
We use this code to outline the minimum requirements that all direct first-tier product suppliers must uphold in relation to their workers such as employment being freely chosen, no harsh or inhumane treatment of workers, and ensuring that child labour is not used. This code is based on the Ethical Trading Initiative (ETI) Base Code, which is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice. The code is contained in our Supplier Manual.
AllSaints’ Policy on Cotton Fiber Sourcing from Uzbekistan
This is also contained in our Supplier Manual. It specifically prohibits any direct first-tier supplier of AllSaints’ products from sourcing its cotton from Uzbekistan where there is a significant risk of modern slavery. AllSaints is committed to not knowingly sourcing Uzbek cotton for the manufacture of any of our products until the Government of Uzbekistan ends the practice of forced child and adult labour in its cotton sector.
VERIFICATION: AUDITING AND PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk within our product supply chain, we undertake the following activities:
1) Inspecting, undertaking a compliance review, and auditing new sites of direct first-tier product suppliers prior to production and sourcing. Both announced and semi-announced on-site audits are conducted on an ongoing basis by the AllSaints Sourcing Team to observe compliance with industry standards and AllSaints’ ethical sourcing policies.
2) Continuing to require all direct first-tier product suppliers to complete and sign a supplier profile questionnaire and set up form. This confirms that the supplier has, among other things, a human rights compliance programme in place and complies with employment laws in that jurisdiction.
3) Continuing to require all direct first-tier product suppliers to agree to and comply with AllSaints’ Anti-Slavery and Human Trafficking Policy, Code of Conduct and Ethical Trading Initiative, Policy on Cotton Fiber Sourcing from Uzbekistan and anti-bribery and corruption terms and conditions contained in the AllSaints Supplier Manual.
4) Ensuring that our employees, contractors and anyone else acting on AllSaints’ behalf are aware of our whistleblowing telephone line and the accompanying whistleblowing procedure/policy so that risks such as modern slavery in our business dealings can be reported in confidence for subsequent investigation. We want to make sure that there are no barriers in reporting any non-compliance with our ethical sourcing policies.
KEY PERFORMANCE INDICATORS
In our previous statement, AllSaints chose to focus on the below actions in order to: (i) ensure compliance; and (ii) raise awareness of the importance of protecting against modern slavery and preventing it from contaminating our business in any way:
1) Ensure that all current and new direct first-tier product suppliers sign up to our revised Supplier Manual, which includes the Anti-Slavery and Modern Slavery Policy (“Policy”) and amended terms and conditions of supply to include modern slavery and anti-bribery provisions.
All relevant first-tier product suppliers have signed up to the revised Supplier Manual and any new suppliers are required to sign up to the revised Supplier Manual as part of AllSaints’ supplier onboarding procedure.
2) Incorporate our Anti-Slavery and Human Trafficking Policy into our standard form employee contract and into our induction process for all individuals who work for us and provide training when considered necessary for existing employees.
This Policy is widely available and accessible by all colleagues across the business as part of AllSaints’ internal policy system.
AllSaints has trained its internal teams deemed to have a higher risk of exposure to issues arising from modern slavery and human trafficking. We are committed to ensuring that these individuals are adequately informed about modern slavery and equipped to raise any concerns they might have.
In the coming year, AllSaints’ Sourcing and HR Teams will provide training to additional personnel in the organisation deemed “medium risk” in terms of their potential exposure to issues arising from slavery and human trafficking.
The Policy also forms part of AllSaints’ new starter onboarding process to ensure that all new employees are trained and aware of AllSaints’ stance on the issue from the outset.
3) Instigate a formal training programme to teach relevant staff, including Buying, Merchandising and Sourcing teams about the risks of modern slavery and how to effectively monitor and prevent it. We will also ask our direct first-tier product suppliers to provide training to their staff, suppliers and providers.
As above, training has been rolled out to AllSaints teams most likely to be exposed to the issues arising from modern slavery and human trafficking . Going forward, this training will be provided to the teams who are deemed “medium risk” and we will continue to incorporate training into our new starter onboarding sessions. AllSaints has also requested that our first tier product suppliers provide relevant training to their staff, suppliers and providers.
4) Initiate a formal process of unannounced, semi-announced and announced audits and consider the possibility of appointing an independent third-party company to carry out such audits.
A senior member of the AllSaints Sourcing Team has conducted an unannounced vendor visit, as well as a number of announced visits. The team member has also carried out visual checks of the factories when visiting vendors on site.
AllSaints is now a member of Sedex, a global organisation which allows its members to manage performance around labour rights, health and safety and business ethics through the sharing of data.
5) Continue to work with Not For Sale to support their efforts to protect people and communities from human trafficking.
AllSaints continues to support Not for Sale, with employees volunteering their time to take part in the Not For Sale project in Thailand earlier this year. AllSaints are also continuing to encourage vendors to commit funds and make pledges to Not for Sale in the future.
AllSaints hopes to achieve the following in the coming year:
1) Appointment of a dedicated Corporate Social Responsibility (CSR) Manager.
AllSaints has advertised for this role and hopes to appoint a suitable candidate in the coming financial year. Once appointed, this individual will be responsible for continuing to protect AllSaints’ business from modern slavery and human trafficking.
2) Train “medium risk” teams within AllSaints on modern slavery and human trafficking.
Following roll out of the relevant training to teams which were deemed most likely to have exposure to issues stemming from modern slavery and human trafficking, we will be rolling out this training to teams with a “medium risk” of exposure to such issues.
AllSaints is always looking to deepen our insight into how our supply chains function and what their working practices are, and continuously strive to strengthen our own internal approach towards addressing modern slavery and human trafficking.
AllSaints remains committed to tackling the problem of modern slavery, human trafficking and servitude in our global society, and we will continue to take steps to mitigate the risk and prevent the occurrence of the same in any part of our business. We hope to build upon the progress we have already made in connection with this aim.
Approved by the Board on 1 November 2019.
Peter Wood – Chief Executive Officer and Director
All Saints Retail Limited
See our previous statement here.