Anti-slavery and human trafficking statement for year ending 31 March 2019
We love creating natural, organic beauty and health products that are efficacious, in a way that cares for people and our planet. 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.
As part of our commitment to combating modern slavery, we have in place the following notices:
- Anti-Slavery Notice
- Anti-Bribery and Corruption Notice
- Ethical Company Notice
- Sustainable Purchasing Notice
- Whistleblowing Notice
All these policies have been reviewed in the last year as part of ensuring we keep our policies up to date.
We are developing a Supplier Code of Practice which must be adhered to. 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 undertaken training with the Chartered Institute of Procurement and Supply (CIPS) and the Ethical Trading Initiative (ETI) to best manage our processes regarding slavery risk. Over the past twelve months, we have built into our process supply chain assessments to evaluate our suppliers and mitigate risks. This is an ongoing activity.
We include requirements on ethical treatment of employees in our supplier contracts. During the last year we have been continuing discussions with suppliers to ensure key suppliers - based on value and risk - all have contract terms in place, concentrating on the approximate 20% of our suppliers that account for 80% of our direct expenditure. These terms have also been implemented in our standard terms of business, used for all new raw material suppliers.
Our standard supply agreement for indirect goods and services providers has terms on anti-bribery and corruption and modern day slavery terms, as does the agreement with our franchisees and distributers both in the UK and abroad.
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 Notice.
'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.
We have informed all of our direct suppliers that we will be requesting or requiring them to sign up to SEDEX depending on the perceived risk. By having suppliers who are signed up to SEDEX, it allows us to review the risks and take appropriate mitigating action where necessary.
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 Notice 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 use two fair trade certifications across our ingredient supply chain: Fair for Life is an internationally recognised standard that applies to natural ingredients from all around the world, FairWild applies specifically to wild harvested ingredients.
In accordance with our Sustainable Purchasing Notice we will use quality fair trade certified ingredients that have reliable long-term availability unless the ingredient is not organic, and an alternative organic ingredient is available.
We were 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) by the ECOCERT group, having an audit every year to ensure we remain compliant with the standards.
Following a review of our actions to prevent slavery and human trafficking in our business and supply chains, we’ll take the following further steps to tackle slavery and human trafficking during 2019/20:
- Review our policies, processes, and planning based on a risk mitigation approach.
- Continue the roll out of supplier contracts and service level agreements.
- Continue to make progress with key suppliers (of direct and indirect goods & services) by requiring them to provide us with information to assess the supply chain risk, typically by signing up to SEDEX (Supplier Ethical Data Exchange) and/or holding fair trade certification, and evaluating the outcome.
- Continue to provide training to our procurement function and other areas of the business as is appropriate based on risk the role is exposed to. We will roll out training to all permanent employees. The direct procurement team will undertake the CIPS ethical supply training, allowing Neal’s Yard Remedies to receive the CIPS Professional Ethics certification.
- Review our indirect supply chain for goods and services, to roll out the supplier code of conduct, and review the potential use of SEDEX for larger suppliers of this type as well as wholesale customers of ours.
- Confirm targets on percentage of physically processed agricultural ingredients certified organic, and percentage of formulations or relevant product value certified organic. We will also look to procure more fair trade ingredients.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Neal’s Yard (Natural Remedies) Limited and its group companies’ slavery and human trafficking statement for the financial year ending 31 March 2019.
Chief Operating Officer:
Neal’s Yard Remedies