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Anti-slavery and human trafficking statement for year ending 31 March 2018

We opened our first shop in Covent Garden, London, in 1981. From the start, we've been committed to providing a satisfying, safe and supportive work place for all and to ensuring fair and respectful relations with suppliers.

'Slavery, servitude and forced or compulsory labour', as government guidelines say, is 'a crime resulting in an abhorrent abuse of human rights'.

We're committed to preventing acts of modern slavery and human trafficking within our business and supply chain, and impose the same high standards on our suppliers.

Our policies

As part of our commitment to combating modern slavery, we have in place the following policies:

  • Anti-Slavery Policy
  • Anti-Bribery and Corruption Policy
  • Ethical Company Policy
  • Sustainable Purchasing Policy
  • Whistleblowing Policy

All of these policies aside from the Anti-Bribery and Corruption Policy have been updated in the last year as part of ensuring we keep our policies up to date.

We ensure our suppliers are aware of our policies and we enforce a strict code of compliance, including a zero-tolerance policy on slavery and human trafficking. If suppliers fail to comply with our policies we will act on best practice guidance, requiring our supplier to immediately begin remedial action, or exiting the supplier relationship.

Combating slavery in our supply chain

We are privileged to buy a wide range of ingredients from many countries around the world and because our supply chain is global, we take our responsibility seriously towards those involved, both directly and indirectly. Our supply chain procedures are designed to:

  • Establish and assess areas of potential risk in our business and supply chains
  • Monitor potential risk areas in our business and supply chains
  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains
  • Provide protection for whistle blowers

Our Procurement Manager has over the last year been training with the Chartered Institute of Procurement and Supply to best manage our processes regarding slavery risk, and we have begun a project to identify from scratch slavery risk throughout the business value chain to ensure current processes are adequate including all relevant training is in place, aiming for completion before the end of the next financial year.

We already include requirements on ethical treatment of employees in our supplier contracts. The revised contract was sent to our top 20 suppliers (in raw material category, by value) during 2016, and during the last year we have been continuing discussions with suppliers to ensure the top 20 suppliers all have contract terms in place, which we aim to complete in the upcoming year. These terms have also been implemented in our standard terms of business, used for all new raw material suppliers.

Throughout our raw materials supply chain, we require compliance with our Supplier Service Level Agreement, which asks suppliers to update us on their environmental and ethical policies and progress. We seek to buy all goods (from both packaging to raw materials and appliances) from suppliers with a proactive approach to protecting the environment and fair trade practices, and this is committed to in our Sustainable Purchasing Policy.

We visit suppliers of many of our raw materials every year to check performance and monitor compliance with the Service Level Agreement and other policies.

Human rights

'We agree with the government's definition that 'Human rights are rights and freedoms that belong to all individuals regardless of their nationality and citizenship'.

As an ethical and organic health and beauty company, respecting human rights throughout our business is at the heart of our company ethos. We aim to build strong, respectful, long-term relationships with our suppliers, resulting in a robust and resilient supply chain.

We support the Universal Declaration of Human Rights and support the Ten Principles of the Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

To reduce human rights risks in the rest of our supply chain, we've joined the Supplier Ethical Data Exchange (SEDEX), which aims to improve ethical and responsible practices in global supply chains. Its core principle is avoiding unfair or unsafe labour practices, including slavery and human trafficking.

This year we have begun to inform key suppliers we will be requesting or requiring them to sign up to SEDEX depending on the perceived risk.

Certifications

We use certifications that ensure our supply chain complies with the UN Convention for Human Rights and the core standards of the International Labour Organisation. It is included in certain organic standards (such as the Soil Association Organic standard) that there is no forced or involuntary labour, and there is either no child labour or labour does not interfere with their education, and can be rescinded if failing to meet the United Nations Convention for Human Rights. As stated in our Sustainable Purchasing Policy we will always prioritise certified organic ingredients where they are available in reliable volumes at the right quality.

With fair trade certifications the previous points remain true, and it also certifies:

  • Employees have the right to associate, organise and negotiate terms
  • Employees are paid a fair wage

Fair trade is about better prices, decent working conditions and fair terms of trade for farmers and workers that include reliable and long-term commitments to purchasing. We continue to use three fair trade certifications across our ingredient supply chain: Fairtrade Foundation applies to ingredients from developing countries, FairWild applies to wild harvested ingredients, and Fair for Life which applies to any natural ingredient. Where we find sources of quality fair trade certified ingredients that have appropriate quality and reliable long-term availability, we will use them (unless this means organic is not possible) as stated in our Sustainable Purchasing Policy.

We're proud to be the first British health and beauty brand to be certified both For Life (for social responsibility) and Fair for Life (for social and labour impacts) bythe ECOCERT group, having an audit every year to ensure we remain compliant with the standards.

Looking forward

Following a review of our actions to prevent slavery or human trafficking in our business or supply chains, we'll take the following further steps to tackle slavery and human trafficking during 2018/19:

  • Review our policies, processes, and planning based on a risk mitigation approach
  • Continue the roll out of supplier contracts and service level agreements
  • Key suppliers (direct and indirect goods & services) will be required to provide us with information allowing us to assess their risk, typically by signing up to SEDEX (Supplier Ethical Data Exchange) and/or holding fair trade certification
  • Provide training to our procurement function and other areas of the business as is appropriate based on risk the role is exposed to