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MODERN SLAVERY ACT

SABRE RETAIL FASHION LIMITED | MODERN SLAVERY ACT STATEMENT 2017

This transparency statement is published by Sabre Retail Fashion Limited t/a Mint Velvet in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial year ended 30 April 2017.

Introduction

We acknowledge that modern slavery, forced labour, human trafficking and bonded labour (together “Modern Slavery”) is a global issue across all business sectors and are continuously striving to ensure that Modern Slavery does not occur in our business and supply chains.

As part of the retail sector we recognise our responsibility to take a robust approach to Modern Slavery and already have policies and controls in place as part of our ethical policy and core value of honesty. These policies are reviewed annually following valuable input from various departments within our business.

Our business and supply chains

Mint Velvet is a retailer of own brand womenswear, footwear and accessories. We operate internationally online (including on third party websites), through boutique stores in the UK and Ireland, concessions in department stores in the UK, Ireland and the Netherlands, as a franchise in the United Arab Emirates and via a joint venture in Switzerland.

Mint Velvet sources its products from 49 suppliers spread across 78 factories in China, India, Asia and Europe. We operate an ethical policy and pride ourselves on responsible sourcing and our commitment to high ethical standards of our supply chain. As part of our ethical policy, we require that our suppliers follow the ETI base code and insist on complete transparency from all suppliers.

Mint Velvet is committed to working in collaboration with our suppliers to encourage continual development and best practice. During the period, as part of our newly updated and re-issued Supplier Handbook we more robustly addressed the issues covered in the Modern Slavery Act 2015 and work with our suppliers to ensure best practice is followed. We have due diligence processes in place for both new suppliers and new factories in order to risk assess our supply chain.

As part of our due diligence process, we require completion of supplier and factory set-up forms prior to placing orders, the provision of an audit from a recognised independent organisation such as SEDEX and on the rare occasion these are not available we will work closely with the supplier to ensure they are adhering to the ETI base code and our Anti Slavery & Human Trafficking Policy as set out in our Supplier Handbook. We then actively encourage them to move to obtaining an audit as soon as possible.

The audits include, but are not limited to, working conditions, health and safety, hours worked, whether wages are above the legal minimum, ability to leave the premises after work shifts and whether any ID documents are held by the employers.

If any issues are identified in the audits we work with the suppliers to ensure that they are followed up satisfactorily within a reasonable period.

Further audits are requested on a regular basis, with a maximum period of 2 years in between audits, so that we can work with suppliers to better their practices and help achieve a better way of life for employees in our supply chain.

This year we have visited some of our key sites and experienced the efforts our suppliers are making to provide a good quality of life for their workers. We were also informed of other actions by our suppliers, including one of our main suppliers opening a small workshop in a different town to the main factory to avoid out-workers having to spend 2 hours each way commuting and to enable easy access to home at lunch. Another long term supplier actively provides training on ethical standards, including initiatives, and subcontracting policy with the assistance of SGS, a third party company. During these sessions they also pass on customer updates and requirements so all of its supply chain is fully informed and engaged. Finally, a new supplier to us has just started to provide a summer camp for the children of their workers to ensure they have fun, learning activities in a safe environment close to their parents during the long summer holiday.

We recognise that there are multiple tiers of the supply chain which can change with each new order so we will continue to strive for complete transparency by working through the tiers with our due diligence process.

During the period covered by this statement, we have reviewed the risks that are presented by our supply chain for suppliers of services, including outsourced business functions such as cleaners, window cleaners and distribution centre, and goods not for resale. We have worked with those suppliers initially identified as high risk to ensure we either have sight of their policies and procedures to satisfy ourselves that they are also working to ensure compliance with the Modern Slavery Act 2015 and/or have amended agreements to more robustly cover obligations and reporting for Modern Slavery. We will continue this due diligence exercise into the next level of such suppliers next year.

Relevant Policies

All product suppliers are contractually bound by the terms and conditions set out in our Supplier Handbook which includes adherence to our Anti-Slavery and Human Trafficking Policy and ethical policy which requires adherence to the ETI Base Code as a minimum standard. Our Anti Slavery & Human Trafficking Policy was issued to all our product suppliers ahead and independently of the new updated Supplier Handbook to ensure clear sight and understanding of the policy was achieved.

All employees have to follow our code of conduct which makes it clear the actions and behaviour expected of them when representing the company. They are also required to follow our Employee Handbook which includes our Anti Slavery & Human Trafficking; Anti-bribery; and Whistleblowing policies.

Within our business, our recruitment policy covers due diligence on right to work, addresses and proof of identification and we only work with reputable recruitment agencies.

Training

Briefings have taken place for key personnel responsible for modern slavery within the business and this will be repeated annually. During the period, training has been developed for the relevant roles within our business and briefings will be regularly made to key suppliers of services and goods not for resale going forward. Information on Modern Slavery is included in induction packs and, depending on the type of role, the new starter will also be included in the training.

Additionally, we have re-evaluated our approach to supply chain transparency and compliance and following changes in responsibility we are in the process of recruiting for a corporate social responsibility compliance role.

As part of this re-evaluation, we have decided to form a Corporate Social Responsibility Committee with representatives from around the business to ensure a consistent and widespread approach to corporate social responsibility which naturally includes Modern Slavery.

Mint Velvet is committed to being part of the global eradication of Modern Slavery and recognise that in a continually moving business environment we need to continue to improve on our actions and processes in order to fulfil our part of it.

This statement was approved by the Board of Directors of Sabre Retail Fashion Limited.

Liz Houghton

Liz Houghton
Chief Executive Officer