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 to UK law with a challenge directed at businesses to increase transparency and encourage responsibility in their supply chains. Specifically, large businesses are required to disclose steps they have taken to evidence efforts they are making to ensure their business and supply chains are free from Modern Slavery and 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, highlighting progress made since our first Statement last year, 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 1856 employees worldwide with 97 stores in the UK, USA, Germany, Hong Kong and Singapore, and 7 franchise stores in the Middle East and the Channel Islands. Our products are sourced from the UK, Portugal, Italy, Romania, Turkey, Tunisia, India, Sri Lanka, Pakistan, Vietnam, Myanmar, Taiwan, China and the Philippines. We currently work with 53 suppliers and 84 factories across these sourcing regions.
Policies and verification processes
For both new and existing relationships, compliance with Jack Wills' Vendor Code of Conduct including our Anti-slavery Policy is essential. Our Ethical Vendor Code focuses chiefly on the Ethical Trading Base Code (see further detail on our Ethical Trade homepage) 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 known 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 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, age of workers, wages, working hours 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.
This year we have updated our internal policies with further requirements on areas of corruption such as bribery and tax evasion and reissued our Ethical Trading and Sourcing Policies to all suppliers. We took this opportunity to provide our internal teams with training on our Ethical Trading on-boarding requirements and the importance of traceability and reassurance through using these documents. All of our suppliers and factories must sign our Ethical Policy and complete the Self Evaluation Questionnaire (SEQ) before purchase orders can be raised against the factory.
Within our own business operations we have audited providers that use agency staff and created specific policies on Modern Slavery to be committed to by them. We have also continued to include terms within all new contractual agreements across the business which set out our expectations and raise the profile of compliance with the Modern Slavery Act.
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. The resulting Risk Map tells us where we should focus our investigation efforts.
In the past year we have audited all first tier factory sites (where the final product is sewn together and labels attached) 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 worked on identifying these units, focusing initially on factories in India, China, Pakistan, Turkey and Portugal which are countries with a high incidence of Modern Slavery or prevalence of subcontracting. 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 in the coming year.
This year we have begun work to fully trace our animal fibre supply chain to investigate both conditions for the animals and workers, this has been challenging due to the dominance of sourcing agents who act as supply chain middlemen. These agents source from multiple mills or farms (dependant on product type) and are generally unwilling to share details of their lower tiers for fear of factories cutting them out of negotiations. Despite this, in 2017 we were able to trace our wool and feather & down supply chain back to country of origin and hope to reflect that success within leather sourcing over the next year.
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 prohibited. In the past year we have personally assessed lower tiers in Portugal (where we have approved subcontracting) and provided tools for our office team in country to manage continued monitoring of conditions in these units.
We have developed further monitoring to provide enforcement to this policy along with additional support and communication to suppliers in the wake of global crises such as unregistered Syrian refugee workers in Turkey. Through our ongoing monitoring programme, in the past year we have discovered unauthorised subcontracting in China. This issue was found within a factory of a long term partner and we have worked with this supplier to address the issues in the chain of production which led to sub-contracting, which in this instance was due in part to a late order with short lead times. Following our assessment of the circumstances and meeting with the supplier, we were able to move forward positively and for mutual trust to be re-established.
The above example provides a valuable lesson on how purchasing practices can be one of the largest contributing factors to factory non-compliances, sourcing issues and an increased risk of Modern Slavery within undeclared production sites. In 2018 we plan to provide the buying team with training on the impact of damaging purchasing practices to raise awareness within the business.
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.
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. 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.
This year we have also joined 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. The Sedex annual conference is attended by both suppliers and buyers and gives key insights into the ever developing world of ethical trading and is a fantastic forum for ideas and best practice sharing.
The above networks allow for a greater opportunity to collaborate with other brands on both proactive initiatives and the best action to take in response to developing threats. If we encounter any issue in a factory our first step is always to cross reference the information collected through our SEQ on which other brands are sourcing there and to contact them to discuss their experience. We have found this invaluable to provide greater awareness and perspective of challenges both brands and factories are facing.
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.
We have also investigated 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. Suppliers have also received webinar training and specific examples of practices considered to constitute Moderns Slavery or forced labour in their region of production in order to bring the policy to life.
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 and for the buying teams on the impact of purchasing practices.
Protection of Whistle-blowers
It is essential that all 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.
Jack Wills remains committed to playing an active part in an industry wide movement that aims to eliminate Modern Slavery and increasing our efforts year on year to achieve this. In the past year we have worked hard to develop the steps identified in our first Statement, including increasing business awareness, strengthening internal processes and improving visibility of our supply chain.
In review of the steps we have taken so far to target Modern Slavery within our supply chain, in the coming year we intend to continue our work on the below:
Continue 'lower tier' mapping to identify threats of Modern Slavery, particularly in base material processing
Connect with disclosed lower tier sites with the support of our Suppliers to complete our Self Evaluation Questionnaire (SEQ)
Conduct further in-market investigation for high risk areas with more visits to factory sites
Hold internal business training on Modern Slavery with focussed training delivered to the distribution centre and the buying teams.
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 28th January 2018.
Union Lifestyle Holdings Limited, Union Lifestyle Ltd, Wills Lifestyle Holdings Limited, JW Germany Limited and Jack Wills Limited
Date: May 2018