- Modern Slavery Statement
Modern Slavery Statement
- Statement on Slavery and Human Trafficking - August 2017
The EWM Group - (including Peacocks Stores Limited, The Edinburgh Woollen Mill Limited, Duvetco Limited t/a Ponden Home, Jane Norman International Limited, Proquip Limited, Austin Reed Limited and Jaeger Retail Limited).
- 1. Overview
We are a group of retail clothing, wholesale and textile companies operating primarily from 1000 bricks and mortar stores in the UK and Ireland and we have a growing online business.
We have franchise and concession interests in a number of overseas territories.
The group has 10,000 employees and a turnover of £500M.
This statement is pursuant to section 54, part 6 of the Modern Slavery Act 2015 and sets out the steps that the companies within the group have taken to identify, monitor and remediate any issues relating to slavery and trafficking within our UK businesses and our worldwide supply chain.
We recognise that slavery and trafficking exists and the eradication of slavery and trafficking is a live and ongoing issue which will require constant vigilance. We aim to work in a co-operative and supportive manner with the partners in our supply chain to assist, educate and train where possible and to seek out potential areas of concern and resolve or remediate these in the best interests of the workers affected.
We recognise that while we have controls, measures and reporting procedures in place, there is more to do and development will continue as the macro environment changes and more knowledge and understanding is gathered.
The existing controls are set out below. These measures have currently revealed no issues relating to slavery and trafficking.
- 2. UK employment and supply chain
The group HR function is centrally controlled and managed with appropriate controls and policies to safeguard the rights and welfare of UK employees including policies on Grievance, Bullying and Harassment, Prevent (identification and prevention of radicalisation) and Safeguarding (identification and prevention of abuse of young workers) and Whistleblowing to allow the safe reporting of any abuses.
Employees are paid into their own bank accounts at no greater intervals than monthly.
However, we recognise that our employees could be subject to outside exploitation which may be difficult to identify. We are considering measures which may assist with identifying such risks and we are working on staff education, particularly for staff management personnel to provide them with the tools to recognise exploitation and thereafter provide support.
- 3. UK supplies, non-clothing
We also need to consider other supplies into the business (action for 2017);
- Written and published policy on ethical trading.
- Suppliers are only taken onto the supply base having gone through a detailed approval process that includes site visits.
- Contractors who do maintenance and shop opening work. (Action Group Maintenance Director, underway)
- Suppliers Manual containing details of our clear expectations with regards to the treatment of the people in the factories and other facilities we are supplied from.
- Guidance on the basics of health, safety and welfare.
We check compliance with our requirements by;
- Requiring that suppliers confirm compliance at a senior level.
- Requiring that suppliers complete a SEDEX self-audit.
- Requiring a SEDEX SMETA Audit dated within the last 12 months, including a corrective action plan and progress report.
Each supplier provides a self-evaluation return in a standard format; this includes an ethical evaluation and a plan to deal with any non-conformities.
Where new businesses are acquired into the business a review takes place to learn from their practices or to bring them up to the standards of the practices for the wider group.
- 4. Main UK and overseas supply base
The Group has policies, procedures and practices in place to assist with the identification of issues of slavery or trafficking within the supply chain, these include:
- Food (restaurants and coffee shops) (Action Food Services Director, underway 2017)
- Concessions in Group premises. (For consideration by Anti-Slavery Act Working Group, 2017)
- Contractors who do maintenance and shop opening work. (Action Group Maintenance Director, underway)
Cookies used for this purpose are often placed on our Websites by other organisations, and always with our permission. These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.
To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected, for example your use of in-store purchases.
- 5. Small UK supply base
There is a group of small UK suppliers, predominately providing specialist local produce for the EWM Tourist stores. It is recognised that work is required to ensure compliance with anti-slavery requirements in this area. (Action – Buyer)
- 6. Country offices
We have a number of local offices with locally employed staff who coordinate with the factories. These offices are able to provide local support and reporting to 80% of our supply base.
- 7. Action to engage
Following the Rana Plaza disaster we are members of the Accord set up to provide support and compensation to the victims of the disaster.
All suppliers based in Bangladesh must be signed up to the Accord agreement.
- 8. Area of concern for further vigilance
We consider it prudent to listen to the concerns of NGO’s and to assess what risk there might be within our supply chain in light of reports made.
We actively consider reports from various sources, including SEDEX, of which we are an “A” member.
In the current year we have considered and assessed issues raised in the following areas:
- Factories in Leicester, UK – spot factory visits were carried out by senior staff.
- Turkey – Given the increased risk in Turkey it is planned in the current year to open a liaison office in Turkey to assist with visibility and development of the factories.
- Refugees form war zones.
- 9. How do we know what is going on?
We acknowledge that it is important to know the market well to network with fellow retailers and others in the industry - in other words keep our ears to the ground.
Being knowledgeable about global reporting in this area and the findings of NGO’s, as well as following up any reports made to see if they are also reflected in our supply chain is also important. We have considered the BMI’s risk index by country and mapped this against our existing supply bases. We will also consider it when looking at new supply bases.
We ensure that we know our factories well. The Buyers meet the factory managers both in the UK and by visiting them in situ. It is important to build up a good and close working relationship with our supply partners.
By having a long term relationship with them we have more influence over how the factory operates.
Factory visits are often pre-organised but can also be without warning given the presence of EWM group employees in the countries of the majority of our supply base.
Visits are carried out by:
- UK buying team
- UK and Country based technical/ethical teams.
- Senior management.
A poor SEDEX audit will indicate that follow up work is required. A working group to discuss and deal with the development of the Anti-Slavery Policy has been set up and will meet on a quarterly basis to include representatives from the Sourcing team, chaired by the Group Company Secretary.
- 10. Forced labour indicators
SEDEX have produced Forced Labour Indicators Reports and we will be engaging with SEDEX and have taken part in workshops to understand what the indicators are an how we use them to improve our risk assessment, due diligence and follow up investigations.
We are using the forced labour indicators as produced and defined by the International Labour Organisation (ILO).
- 11. Supply chain depth
Like most retailers we have a supply chain of some length and depth. The Group has first and second tier suppliers (suppliers where we have direct contact) and third tier suppliers where we may not have direct contact as they are suppliers to our factories or are sub-contracted.
We see the majority of the work in relation to rooting out activities in relation to slavery and trafficking as being in the third tier area. This does not, however, mean that we will have less scrutiny on the first and second tier but that we are giving this area some additional focus.
- 12. Strategic areas of development for the next 12 months
Senior management have already attended an ETI (Ethical Trading Institute) course to assist with compliance under the Modern Slavery Act and to assist in the development of strategies to identify poor or illegal practices and to assist with the improvement of the conditions of workers within the supply chain.
The next stages are as follows:
- Raising awareness of the issues at all levels.
- Training the key individuals in the businesses.
- Educating the supply base on the requirements.
- Reviewing the existing policies and guidance for suppliers.
- Developing Red Flag checklists for visiting staff on welfare, health, safety and conditions which would provide early indicators of problems.
- 13. Concluding statement
Our focus will be to maintain a healthy and stable supply chain which benefits all stakeholders and encourages good and fair working conditions where employees are free from harm, threat or harassment of any kind, are paid regularly at a sustainable level and have a mechanism to raise issues.
Where there are issues we will seek to provide the support with the objective that the people in our supply chain are treated fairly, however, where satisfactory improvement is not made and we can find no other way forward, we will move away from an offending supplier.
We will continue to encourage an open and honest dialogue with our supply base and to encourage our teams in direct engagement with the supply base to report issues of concern to the Board, with a focus on improvement.
For and on behalf of the Board of EWM (Topco) Limited and associates.