Jack Wills Slavery and Human Trafficking Statement
The Fabric of Jack is all about what we’re made of – what we believe in, what we stand by and what stories we choose to tell. We believe in transparency, trust and loyalty. We are proud to stand by our high quality products and our people, whether they’re working in Head Office, a store in the US or Asia, or in the factory of one of our carefully chosen suppliers. Through the Fabric of Jack we are dedicated to telling the stories of our products and people, knowing that our customers and stakeholders share our values. Our values, which have always been at the front of our minds, are now formalised within our Anti-slavery Policy and this Statement, reflecting our commitment to acting ethically and with integrity in all of our business relationships.
The Modern Slavery Act 2015 introduced changes in UK law focused on increasing transparency and encouraging responsibility in supply chains. Specifically, large businesses are required to disclose steps they have taken to ensure their business and supply chains are free from Modern Slavery or Human Trafficking (that is, slavery, servitude, forced and compulsory labour and human trafficking) (Modern Slavery). Jack Wills is committed to confronting the issue of Modern Slavery head on. This Statement details the action taken to date to tackle Modern Slavery within our supply chain and business operations and outlines our integrated risk strategy.
Jack Wills structure
We are a part of the Jack Wills (Group), and our ultimate parent company is Union Lifestyle Holdings Limited. The Group has 2155 employees worldwide with 89 stores in the UK, USA, Hong Kong, Macau and Singapore, and 7 franchise stores in the Middle East and the Channel Islands. Our products are sourced from the UK, Portugal, Italy, Turkey, India, Sri Lanka, Bangladesh, Pakistan, Vietnam, China and Taiwan and we currently work with 51 suppliers and 87 factories.
Policies and verification processes
Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships. It is our key to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
We are committed to ensuring that there is no Modern Slavery in our supply chains or in any part of our business and operate a zero tolerance policy. Our ethical requirements are detailed further in our Ethical Trading and Sourcing Policy. Although our policy has always prohibited forced labour and human trafficking, we have updated it to specifically prohibit practices that can result in Modern Slavery. We have also updated our Vendor Manual, which contains a Self-Evaluation Questionnaire (SEQ) to ask more specific questions relating to the recruitment of workers. All of our suppliers and factories must sign our Ethical Policy and complete the SEQ.
Earlier this year when we communicated our updated Policy and SEQ, we provided suppliers and factories with a “Toolkit” to help them to understand how Modern Slavery can develop and what they need to look out for when they visit their factories and ‘lower tier’ suppliers.
As part of our Ethical Trading Programme we require all factories to be audited by independent third party ethical auditors. These audits are graded with the Ethical Trading Initiative Base Code and cover issues such as health and safety, underage workers, wages and freedom of association. However as Modern Slavery is often well hidden we go beyond audits to also investigate practices within our factories using a global risk analysis, looking at recruitment practices, geography, industry and legal frameworks. We intend to develop this strategy to investigate targeted factories situated in “Hot Spot” areas that represent a high risk of Modern Slavery.
Within our business operations we have investigated providers that use agency staff and created specific policies on Modern Slavery to be signed by them.
Our global analysis looks at recruitment practices, geography, industry and legal frameworks using ethical audits and SEQs combined with reports by the ILO, Global Slavery Index, the US Department of State Trafficking in Persons Report, Verité, Mapelcroft, amongst others. We evaluate recruitment practices including use of agency, contract and temporary workers, the prominence of labour unions and the use of recruitment fees. The resulting Risk Map tells us where we should focus our investigation efforts.
When evaluating the risk of Modern Slavery, we look beyond ‘first tier’ factories (where the final product is sewn together and labels attached) to the ‘lower tiers’, including mills, weaving units, printing units, washing units and tanneries which have, historically, been audited rarely. We have worked on identifying these units, focusing initially on India and China which are countries with a high incidence of Modern Slavery. We have also pinpointed regions of high risk, such as the Tamil Nadu region in India which has issues of debt bondage for young girls. We have evaluated which lower tier units need to complete our SEQ and intend to extend this transparency further.
Looking past our lower tiers to the raw materials used in our products, a high-risk area is the cotton industry. A particular concern is cotton from Uzbekistan and Turkmenistan, where the governments force hundreds of thousands of citizens to pick cotton. Jack Wills therefore bans all cotton use from Uzbekistan and Turkmenistan.
Monitoring and managing risk and KPI’s
Our strategy to reduce the risk of Modern Slavery starts with setting policies and expectations, mapping risk areas, and then managing this established risk in a variety of ways.
Risk Action Plan
If an audit indicates the existence of Modern Slavery, or if an SEQ indicates practices in a factory that could result in Modern Slavery, this will be investigated further and we could require another independent assessment. If Modern slavery is confirmed, we implement our Risk Action Plan.
Training is a key component in risk management. We have held webinars to train stakeholders in our supply chain about Modern Slavery. We have trained 96% of our suppliers in this way and 93% of the factories which we have direct contact with. Our Toolkit has been distributed to all suppliers to help them understand what Modern Slavery is and measures they can take to reduce any risk in their supply chains.
All Head Office employees and Store Managers have completed interactive online training on Modern Slavery and we have provided practical training for all managers within our Distribution Centre (DC). All Jack Wills employees also receive regular updates in our newsletter.
Protection of Whistle-blowers
It is essential that stakeholders and employees feel able to raise concerns about Modern Slavery. Our Whistleblowing Policy supports anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Modern Slavery is a cross-border and cross-industry problem requiring a collaborative response. Jack Wills works closely with other members of the Ethical Trading Initiative (ETI) to develop ways to tackle Modern Slavery, sharing ideas on approaches to risk mapping, supplier and factory engagement and training.
Jack Wills is committed to being part of an industry wide movement that aims to eliminate Modern Slavery. In the past year we have worked hard to lay the groundwork for our first Modern Slavery Statement, including updating existing policies, writing new policies, making new risk strategies and providing training.
Following a review of the effectiveness of the steps we have taken to eradicate Modern Slavery in our supply chain we intend to take the following further steps:
- Continue ‘lower tier’ mapping to identify threats of Modern Slavery in base material processing
- 100% completion of supplier training on Modern Slavery, providing further support when needed
- Jack Wills is passionate about trading ethically and proud to be open on practices within our supply chain. In 2017 we wish to progress our Fabric of Jack initiative with Modern Slavery practices to give further insight into our sourcing and community projects; http://www.jackwills.com/fabric-of-jack/
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's Slavery and Human Trafficking statement for the financial year ending 1 February 2017.
Union Lifestyle Holdings Limited, Union Lifestyle Ltd, Wills Lifestyle Holdings Limited and Jack Wills Limited
Date: May 2017