MODERN SLAVERY ACT STATEMENT
ALL SAINTS RETAIL LIMITED UK MODERN SLAVERY ACT 2015 STATEMENT FOR THE FINANCIAL YEAR ENDED 31 JANUARY 2017
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 £36m 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 ended 31 January 2017. 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 obsessed with 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’ fashionwear is sold globally through our stores across the world, www.allsaints.com and its third-party wholesale customers. ALLSAINTS has over 230 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, Brazil, 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 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 (www.notforsalecampaign.org), a charitable organisation which protects people and communities from modern slavery and human trafficking, for over 5 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 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 source 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) Inspect, undertake a compliance review, and audit new sites of direct first-tier product suppliers prior to production and sourcing. Both announced and semi-announced on-site audits are then conducted on an ongoing basis by the ALLSAINTS Sourcing Team to observe compliance with industry standards and ALLSAINTS’ ethical sourcing policies.
2) 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) 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 terms and conditions contained in the ALLSAINTS Supplier Manual.
4) In 2013, we set up a whistleblowing telephone line with an accompanying whistleblowing procedure/policy (updated in 2015) that applies to employees, contractors and anyone else acting on ALLSAINTS’ behalf 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.
In the forthcoming financial year, we intend to take the following further steps to: (i) ensure compliance; and (ii) raise awareness of the importance of protecting against modern slavery 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 new Anti-Slavery and Modern Slavery Policy and amended terms and conditions of supply to include modern slavery and anti-bribery provisions.
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.
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.
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.
5) Continue to work with Not For Sale to support their efforts to protect people and communities from human trafficking.
ALLSAINTS remains committed to tackling the problem of modern slavery, human trafficking and servitude in our global society and will continue to take steps to mitigate the risk and prevent the occurrence of the same in any part of our business.
Approved by the Board on 19 July 2017