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Modern Slavery

MODERN SLAVERY ACT

SABRE RETAIL FASHION LIMITED | MODERN SLAVERY ACT STATEMENT 2019

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 27 April 2019.

Introduction

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.

Mint Velvet was established with honesty as one of its core values and ten years on that value continues to be a priority in the way we conduct our business. We naturally therefore expect honesty to be demonstrated by our suppliers and form the basis for ongoing dialogue to encourage increased transparency and improvements in ethical and environmental standards.

We work closely with our suppliers in order to build long-term sustainable business relationships based on honesty and transparency. We’ve worked with 7 suppliers for at least 6 years who produce approximately 70% of our retail buy.

The eradication of global modern slavery represents a huge challenge to governments, businesses and society alike. Mint Velvet remains committed to taking effective action to address human rights infringements within our sphere of influence. Our approach continually evolves as we discover more about the risks and challenges but we aim to continue to ensure the interests of victims of modern slavery are put first.

Following the establishment of our CSR standing committee and the appointment of our COO as the Board Director with responsibility for modern slavery, we finalised our CSR strategy and have made changes to the CSR team including a new manager and a change of reporting line with the aim of increased transparency within the whole supply chain. As a result we have had a year of consolidation with the new CSR manager bedding in new processes, amending policies and updating the supplier on-boarding process to make it more robust and fit for the future.

Our business and supply chains

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

Mint Velvet sources its products from 52 suppliers across 126 factories in 14 countries, including China, India, Turkey and across the EU.

Policies

At a policy level, we have a framework that sets out our ethical standards and norms. These include the following:

  1. Code of conduct, which is derived from ILO conventions
  2. Whistleblowing policy
  3. Supplier handbook (all branded product suppliers are contractually bound by the terms and conditions set out in our handbook and includes key ethical policies)
  4. Anti-slavery and human trafficking policy
  5. Anti-bribery policy

We recognise that certain production locations present higher potential risks of modern slavery and trafficking due to migrant workers, existing evidence of child labour and bonded labour, higher levels of female workers and refugees. Therefore, during the year we have developed a Cotton Policy, a Migrant Workers Policy and an environmental policy, which are in the process of being rolled out to our suppliers.

The new policies define and guide workplace and employment standards and business conduct and will apply to all our business partners.

Together with the factory audits and our newly developed worker questionnaire, we are hopeful that this will add substance to the content of the audits and serve to highlight/confirm the riskier countries and increase transparency in our supply chain. Where issues are discovered, we work collaboratively with suppliers to ensure the best outcome.

We have also reviewed our Code of Conduct policy to make it more robust and updated our supplier on-boarding process. 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.

Due diligence

Due diligence is critical to the overall effectiveness of addressing risk and we are continually evolving our approach. In relation to our product supply chain our due diligence involves the steps below:

  1. Mapping: 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 continued to focus on ensuring current audits and closed off CAPs and also identifying and preventing unapproved first-tier sub-contracting within our product supply chain. We have also begun to map the second-tier.

    Our due diligence process identified one of our suppliers unnecessarily using unauthorised sites. We immediately worked with them to understand how this had occurred and put in place an improvement plan, which included removing sites that were no longer utilised and re-iterating the requirement for a valid, commercial reason for introducing new factory sites.

  2. 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.

    During the year, we have had initial discussions with independent ethical auditing companies to understand the additional opportunities they can bring to the auditing process in order to facilitate a deeper engagement with our suppliers.

  3. Supplemental worker questionnaire: We have finalised a questionnaire to gain greater granularity of suppliers’ workforces, covering a range of indicators including nationality, freedom of association, contract type, age, gender, etc. This will allow for more rigorous risk analysis and categorisation and we hope this will then assist in highlighting higher risk locations etc. This has already been completed by our largest supplier and will be rolled out to other suppliers next year.

The new CSR team have increased their factory visits during the year and will continue to do so, conducting additional ethical risk analysis at each visited location. Our buying and technical teams again visited several suppliers this year in China, India and Europe using the opportunity to discuss working conditions and gain deeper insight and knowledge of practices.

Goods and services not for re-sale ("GNFR")

We source a wide range of goods and services such as packaging, print, logistics, IT and shop-fitting from third party suppliers. These GNFR suppliers continue to be part of our due diligence processes which requires compliance with the Modern Slavery Act and any contracts with new suppliers include clauses to that effect. During the year we have continued to work through our GNFR suppliers requesting audits from their own supply chains.

Mint Velvet employees

We have a robust recruitment process which includes our own due diligence checks such as checking original documents such as passports and rights to work, as necessary, and where we work with recruitment agencies, we always ask for their modern slavery policies and processes.

All Mint Velvet employment contracts directly incorporate policies designed to protect worker rights and promote a safe and fair supply chain. These include a Code of Conduct, an Anti- Slavery and Human Trafficking Policy, an Anti-bribery Policy and our Whistleblowing Policy.

Training

Inductions of new starters include information and initial training on modern slavery. Key personnel within the business were trained on responsible and sustainable sourcing which includes the risks of modern slavery annually and country specific risks by an independent consultant. We intend to roll this out to both our product and GNFR suppliers next year.

Mint Velvet remains committed to being part of the global eradication of Modern Slavery and recognises that in a continually moving business environment we need to maintain and evolve 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.

Kara

Kara Groves
Chief Operating Officer
25 October 2019

SABRE RETAIL FASHION LIMITED | MODERN SLAVERY ACT STATEMENT 2018

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.

Introduction

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.

Policies

At a policy level we have a framework that sets out our ethical standards and norms. These include the following:

  1. Code of conduct, which is derived from ILO conventions
  2. Whistleblowing policy
  3. Supplier handbook (all branded product suppliers are contractually bound by the terms and conditions set out in our handbook and includes key ethical policies)
  4. Anti-slavery and human trafficking policy
  5. 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

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:

  1. 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.).
  2. 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.
  3. 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.

Training update

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.

Kara

Kara Groves
Chief Operating Officer
25 October 2018

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

Liz Houghton
Chief Executive Officer
25 October 2017

SABRE RETAIL FASHION LIMITED | MODERN SLAVERY ACT STATEMENT 2015/2016

This statement is published in accordance with section 54 of the Modern Slavery Act 2015 for the period 29 October 2015 to 30 April 2016 and sets out the steps taken by Sabre Retail Fashion Limited t/a Mint Velvet (“Mint Velvet”) to ensure that modern slavery and human trafficking is not taking place in its business and supply chains.

Introduction

We know that modern slavery, forced labour, human trafficking and bonded labour (together “Modern Slavery”) is a global issue across all business sectors and are committed to working to ensure that Modern Slavery does not occur in our business or supply chains. As part of the retail sector we recognise our responsibility to take a robust approach to slavery and human trafficking and already have policies and controls in place as part of our ethical policy and core value of honesty. These are administered by the Company Secretary, the Supply Chain Coordinator and HR together with additional, 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, through boutique stores in the UK, 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.

Since 30 November 2015, Sabre Retail Fashion Limited has been wholly owned by Mustard Global Limited. Mint Velvet sources its products from 40 suppliers spread across 70 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. We require that our suppliers follow the ETI base code and insist on complete transparency from all suppliers.

We have due diligence processes in place for both new suppliers and new factories in order to risk assess our supply chain. We have carried out checks and audits on all our first tier suppliers and constantly follow up on all issues and work with factories to improve conditions for workers. 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. Further audits are conducted on a regular basis so that we can work with suppliers to better their practices and help achieve a better way of life for staff in our supply chain.

During the period covered by this statement, we have continued with the audit process into our second tier to gain visibility of wool suppliers, print houses and embroiderers.

During this current year, we are increasing our focus on our supply chain for suppliers of services and goods not for resale which will include extending our existing due diligence to more comprehensively cover modern slavery.

Relevant Policies

We have communicated our Anti-Slavery and Human Trafficking Policy together with our Anti-Bribery Policy to all our product suppliers and throughout our business. We will be extending this communication to our suppliers of services and goods not for resale during this current year. We also operate a Whistleblowing Policy within our business so employees can report any concerns and appropriate action can be taken.

All employees have to follow a code of conduct which makes it clear the actions and behaviour expected of them when representing the company.

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

Initial training, from a 3rd party company, Stronger2gether, and briefings have taken place for key personnel responsible for Modern Slavery within the business. Within the course of this currrent year, we will develop training for the whole of the business which will cover modern slavery, ethnical trading and anti-bribery and briefings will be rolled to key suppliers of services and goods not for resale.

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

Liz

Liz Houghton
Chief Executive Officer
29 September 2016