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 28 April 2018.
Modern slavery and human trafficking are gross violations of fundamental human rights. Mint Velvet is committed to acting responsibly and implementing and enforcing effective systems and controls to ensure no forms of modern slavery occur in our own business or supply chains.
Modern slavery often takes place through deliberate acts of deception and can be hidden from view. The International Labour Organisation (ILO) estimates annual profits from modern slavery to be $150 billion and those in forced labour to be approximately 25 million .
We cite these statistics to highlight the magnitude of the challenge that confronts governments, business and civil society. Mint Velvet is committed to taking effective action to address human rights infringements within our sphere of influence. Our approach is evolving as we learn more about the risks and challenges, gather robust information and leverage our influence to best effect, with the aim being to ensure the interests of victims of modern slavery are put first.
In 2017 we conducted a review of how CSR was managed across the business with a view to bring the respective areas under one holistic programme, including modern slavery. As a result, we have strengthened our infrastructure and governance to define our approach and ensure we take progressive measures to comply with both our legal duties under the Modern Slavery Act and the values integral to Mint Velvet. We have appointed:
- Kara Groves, Chief Operating Officer, as Board Director with responsibility for Modern Slavery.
- CSR standing committee, which comprises of executives and senior management from across the business. The committee oversees and monitors risks and strategy and meets quarterly. Our medium-term modern slavery strategy was recently signed off by the committee.
- Dedicated CSR team, responsible for due diligence, supplier engagement and driving forward progress on a day-to-day basis. The team reports into Head of Legal.
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 and Ireland, as a franchise in the United Arab Emirates and via a joint venture in Switzerland.
Mint Velvet sources its products from 43 suppliers across 102 factories in countries, including China, India, Vietnam, Turkey, Spain, Italy and Bulgaria.
At a policy level we have a framework that sets out our ethical standards and norms. These include the following:
- Code of conduct, which is derived from ILO conventions
- Whistleblowing policy
- Supplier handbook (all branded product suppliers are contractually bound by the terms and conditions set out in our handbook and includes key ethical policies)
- Anti-slavery and human trafficking policy
- Anti-bribery policy
The policies define and guide workplace and employment standards and business conduct and apply to either our own operations and/or that of our business partners. The framework and individual policies are kept under review to ensure they are effective and capable of addressing new and emerging risks. Where we consider this is not the case, new policies will be developed and robustly communicated to relevant stakeholders.
One of the steps we are taking is to address the risks posed from cotton from Uzbekistan and Turkmenistan, as ongoing concerns of forced labour and / or child labour persist in both countries. We are working across our Buying, Technologists and CSR teams and with our supply base to ensure cotton from these countries are not used in our product. This is supported by increased efforts to trace cotton back to country of origin.
Due diligence is critical to the overall effectiveness of addressing risk and we are evolving our approach. This year we consulted external authorities, including the Ethical Trading Initiative’s Human Rights Due Diligence Framework, the Organisation for Economic Co-operation and Development’s Guidelines on Due Diligence and Verité, a human rights NGO, which provided advice on our approach and relevant risks. In addition, we now have internal CSR expertise on modern slavery, and, as a result, have taken a more multi-dimensional risk-based approach. This uses a range of tools and aims to conduct deep-dive assessments of suppliers. Due diligence involves three steps:
- Mapping suppliers and business partners: This provides geographical and sectoral-level risk information. As with previous years, first-tier product manufacturing facilities are mapped on an ongoing basis. This year we have begun to map suppliers of goods-not-for-resale (GNFR), for example, print and packaging suppliers. We will shortly commence mapping second-tier manufacturers of clothing and accessories (e.g. printers, fabric mills, embellishers, tanneries, etc.).
- Third-party audits: All first-tier manufacturing sites within Mint Velvet’s product supply chain are regularly audited. This involves completion of supplier and factory set-up forms prior to placing orders (all factories must be declared) and the provision of an audit from a recognised independent company. The audits include, but are not limited to, working conditions, health and safety, hours worked, wages and ability to leave work after working shifts. The CSR team review each audit, follow up with suppliers and, where there are findings, work to ensure issues are resolved. Further audits are requested on a regular basis, with a maximum period of two years in between. We are now requesting GNFR supplier audits, which are, again, carried out by recognised and independent audit companies. We believe in working with suppliers over the long-term so that improvements can be made and a better way of life achieved for employees in our supply chain.
- Employee data: We have developed a tool to gain greater granularity of suppliers’ workforces, covering a range of indicators including nationality, contract type, age, gender, etc. This will allow for more rigorous risk analysis and categorisation.
We believe trust is crucial to achieving the goal of decent working conditions. Our buying and technical teams visited several suppliers this year in China, India and Europe. Working conditions were discussed and deeper insight and knowledge of practices gained. In addition, new business contracts with GNFR suppliers include clauses related to modern slavery, including the right to visit and review relevant documents. As a result, we have visited our DC, operated by a third-party, and discussed controls they have put in place to prevent poor working conditions and modern slavery. We also met with a key partner of packaging to talk about duties under the Act and our plans to undertake long-term work in this area.
Inductions of new starters include information and initial training on modern slavery. Key personnel within the business are trained on the risks of modern slavery annually, including the various forms modern slavery takes (e.g. forced, bonded and child labour) and country specific risks. Training and communication is another area where we plan to strengthen our efforts both internally and with business partners.
Mint Velvet is committed to being part of the global eradication of Modern Slavery and recognises 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.
Chief Operating Officer
25 October 2018