Jack Wills modern slavery statement May 2018 – May 2019

At Jack Wills 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, one of international stores, or in the factory of one of our suppliers. Our values, which have always been at the front of our minds, are formalised within our Modern Slavery Policy and this statement, reflects our commitment to acting ethically and with integrity in all our business relationships.

This is our third statement and documents our ongoing commitment to preventing modern slavery and our focus areas for the future.

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 1803 employees worldwide with 108 stores across the globe including UK, USA, Hong Kong and Singapore, 6 franchise stores in the Middle East and 1 in the Channel Islands.

Supply chain model

Our supply chain consists of these key areas:

Jack Wills Stores and Online

3rd party eComm partners and franchises

Jack Wills Distribution Center

Products produced for sale by Jack Wills

Goods not for resale e.g. store fittings, fixtures

Suppliers

Our products are sourced from 13 countries worldwide and over 80% of our product is made in 5 countries. We do not own or operate any factories, we have long standing relationships with our vendors some of which have worked with us for 10 years.

  • - We work with 42 suppliers and 103 factories
  • - Our top 10 suppliers provide 75% of our products
  • - Our top 5 countries account for 89% of the product we sell
  • - In 2018 our top sourcing countries were China, Sri Lanka, India, Portugal, Turkey

We map and describe our products produced for sale by Jack Wills as shown below.

TIER 1

Factories where primary manufacturing processes take place

e.g knitting, cutting, linking or sewing

TIER 2

Factories where secondary manufacturing processes take place

e.g embroidery, printing or washing

TIER 3

Fabric and Components

e.g fabric mills, tanneries, hardware and trims

TIER 4

Raw materials

e.g Textile fibre, natural and manmade materials

Policies and verification processes

For both new and existing relationships, compliance with Jack Wills’ Code of Conduct including our Modern Slavery policy is essential. Our Ethical Vendor Code focuses chiefly on the Ethical Trading Initiative Base Code and reflects our commitment to acting ethically and with integrity in all our business relationships. Suppliers and factories must share our non-negotiable values from the get go. Transparency and trust within all business relationships is key to implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place anywhere in our supply chains.

Although our policy has always prohibited forced labour and human trafficking, we specifically raise awareness on and prohibit practices that can result in Modern Slavery such as bonded recruitment programmes and passport confiscation from migrant workers.

As part of our Ethical Trading Programme we require all factories to have a valid third party ethical audit. Audits must be conducted using the SMETA methodology (Sedex Members Ethical Trade Audit). SMETA helps suppliers to share one audit with multiple customers, reducing duplication in ethical auditing.

All new audits are carried out on a semi-announced basis. To help reduce audit fatigue, we accept valid SMETA audits produced for other retailers. We also accept audits carried out by other retailers with recognised ethical trade programmes.

As part of the on-boarding process all of our suppliers and factories must sign confirming that all products adhere to the Jack Wills Ethical Policy which includes the following:

  • - Ethical Trade
  • - Modern Slavery
  • - Environmental
  • - Safety Policies
  • - Animal Welfare
  • - Governance and Compliance Process

A Self Evaluation Questionnaire (SEQ) is also completed prior to factory approval, no purchase order can be raised against the factory until both the audit and SEQ is approved.

Subcontracting

As Modern Slavery most commonly occurs in the lower tiers of manufacturing and base material processing we work with suppliers and factories to declare their own suppliers including dye houses, embroiderers and laundries. This question features in our SEQ which is completed during on-boarding.

We are clear with our suppliers from the very beginning of our relationship that unauthorised subcontracting of orders is prohibited and must be declared to us, with suppliers gaining written permission to use these factories. In the past year we have continued to personally assess lower tiers in Portugal (where we have approved subcontracting) giving us clear visibility, we continue to monitor conditions in these units.

Evaluating risk

When completing our risk analysis of any new supplier or factory, we take into account multiple factors including recruitment practices, geography, product type and legal frameworks using ethical audits and SEQs combined with reports by the ILO, Global Slavery Index and the Business & Human Rights Resource Centre, amongst others. We evaluate recruitment practices including use of agency, contract, temporary and migrant workers, the prominence or lack of labour unions and the use of recruitment fees.

In the past year we have audited all first tier factory sites through either our own assessment visits or 3rd party audits. Maintenance of our factory audit database in connection with awareness of developing global issues has greatly assisted us in identifying which factories are likely to be at greatest risk. Whilst we strongly believe in going beyond compliance through auditing, establishing full visibility of our factory estate has been crucial for us to assess risks within our supply chain.

Although we have established full visibility of our first tier sites, in order to continue assessing the risk of Modern Slavery, we must look beyond first tier factories to the lower tiers, including mills, weaving units, printing units, washing units and tanneries which have, historically, been audited rarely. We have started working with our top suppliers to identify these units, focusing initially on factories in India, China and Portugal which are countries with a high incidence of Modern Slavery as a result of subcontracting. We will be evaluating which lower tier units need to complete our SEQ and intend to extend this transparency further in the coming year.

Monitoring and managing risk and KPI’s

Our strategy to reduce the risk of Modern Slavery begins with requiring compliance by all business partners with our clear policies and expectations, assessing where risk may be found and then managing these risks through a variety of different methods, a range of which we have set out below:

COLLABORATION

Modern Slavery is an inherent threat to all countries and industries and as such it can be best tackled through collaboration. Jack Wills has been a member of the Ethical Trading Initiative (ETI) for over 10 years and works with the ETI and other corporate members to develop ways to tackle Modern Slavery, sharing awareness of new and developing issues, ideas on approaches to risk mapping, supplier and factory engagement and training.

In March 2019, Jack Wills was one of the brands attending CEO forum on Modern Slavery hosted in the House of Lords by ASOS to identify and address shared risks in the apparel sector.

We also submit an annual statement to the ETI which includes information on our actions taken to counter Modern Slavery and we receive direct feedback and suggestions based on this report.

We are members of Sedex (Supplier Ethical Data Exchange) which is a relationship led platform to assist suppliers in sharing their key factory information and audits with us. Our primary purpose for using the platform is to increase our visibility of both primary and lower tier suppliers which will enhance our risk mapping and action planning in the coming year.

RISK ACTION PLAN

If an audit indicates any risk of the existence of Modern Slavery, or if a SEQ indicates practices in a factory that could result in Modern Slavery, this will be investigated further and we could require another independent assessment, collaborative action or an alternative form of investigation. If Modern Slavery is confirmed, we implement our Risk Action Plan, which consists of a mitigating process which will vary depending on where within the business, either our own operations or within our supply chain the slavery was found.

If required, we would investigate factories independently if there is evidence of serious document falsification which could cover up instances of Modern Slavery. If this is confirmed, and there is no legitimate reason for the conflicting information, we consider this to be a zero tolerance issue. We are always keen to assist factories to develop in their ethical journey but our relationship cannot function without trust and a lack of transparency results in immeasurable risk.

SUPPLIER AND BUSINESS TRAINING

Training is a key component in risk management and our focus to date has been on raising awareness of Modern Slavery, how our employees and suppliers can recognise it and what to do if they suspect Modern Slavery is taking place.

Our Modern Slavery toolkit has been distributed to all suppliers as part of our Ethical Trading and Sourcing Policies to ensure they understand what Modern Slavery is, our prohibited practices and measures they can take to reduce any risk in their supply chains.

All Head Office employees and Store Managers annually complete interactive online training on Modern Slavery. In the coming year we plan to run targeted training sessions in our distribution centre with a focus on logistics and agency staff.

All new employees both in store and head office as part of the Jack Wills commitment to our Value of Integrity complete three short e-learning modules prior to starting this is making sure that all of our people feel safe and operate safely at work, and work with the upmost commitment to ethical trading and compliance with the law.

  • - Health and Safety
  • - Ethical Trading (including Modern Slavery)
  • - General Data Protection Regulation

CONTINUOUS IMPROVEMENT

Jack Wills remains committed to drive continuous improvement of standards within our business and supply chain, increasing our efforts year on year, we continue our work on the below:

  • Provide on-going guidance and support staff on training needs, focussing on delivering training to the distribution centre and buying teams, especially new starters.
  • Continue to further our efforts on ‘lower tier’ mapping to identify threats of Modern Slavery within the supply chain to improve traceability where we currently have little or no visibility.
  • Continue to establish working relationships and seeking guidance with external retailers/brands, Non-Governmental Organisations (NGOs) and expert organisations on modern slavery.

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 3rd February

Jack Wills Modern Slavery Statement was prepared by our Ethical Trading dept and approved by our CEO on 11th June 2019

Suzanne Harlow

Chief Executive Officer