MODERN SLAVERY STATEMENT – Snide London

MODERN SLAVERY STATEMENT

In compliance with the regulations of both the UK Modern Slavery Act and the Californian Transparency in Supply Chains Act (SB 657), this statement sets out Snide London’s policies and actions relating to the prevention of slavery and human trafficking in our business and supply chain.

We are committed to preventing slavery and human trafficking within our business activities and to ensure that our supply chains are free from modern slavery and human trafficking in any form.
This statement relates to actions and activities during the last financial year 1st April 2017 to 31st March 2018.

ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS

Countries of operation:
Snide London is a modern British shirt maker that retails its products via its own website and through a number of independent distributors

Countries of supply:
Snide sources its products from approximately 10 suppliers. During the year the majority of products are sourced from supplier sites in the UK. The fabrics are purchased from reputable mills in the UK, which meet Snide’s high-quality standards. Snide London exercises caution when approving suppliers to ensure that products are only sourced in countries that respect human rights.

High-risk activities:
Snide London is aware that some of its operations are considered to be at a higher risk of slavery or human trafficking and is working with its supply chain to mitigate these risks. We wants to make global cotton production better for the people who produce it, promoting decent work practices in the cotton fields, specifically banning child and forced labour. Snide is working to increase the amount of cotton bought from better cotton sources.

Responsibility:
Responsibility for Thomas Pink’s anti-slavery initiatives lies with the team of directors. Risk assessments, due diligence and training are carried out by these individuals who then review policies as required and submit any necessary revisions

RELEVANT POLICIES
Snide London has developed the following policies to address human trafficking and slavery in its’ supply chain and business. All policies are available to employees through a central online database.

Employee Code of Conduct:
Snide London’s Employee Code of Conduct sets out the ethical and practical framework within which employees are invited to act. A fundamental part of this is to respect and defend the principles of the UN Global Compact in the workplace, one of these being the elimination of any form of forced or bonded labour.

Ethical Sourcing Policy:
Snide London’s Ethical Sourcing Policy contains direct references to human trafficking and modern slavery. This states that employment should be freely chosen and that no forced, bonded or involuntary prison labour will be tolerated. Suppliers whom engage in or support slavery or human trafficking in any way will not be used.

Whistleblowing Policy:
During 2017, Snide London developed a Whistleblowing Policy which sets out to ensure that protections are in place for those who raise legitimate concerns over wrongdoing within its own operations.

DUE DILIGENCE AND VERIFICATION
Snide London undertakes due diligence when considering new suppliers and regularly reviews existing suppliers, using a variety of tools to assess potential and existing supply chain partners in all tiers.

Code of Conduct:
All suppliers receive a copy of the Snide London Supplier Manual and must sign a declaration to confirm acceptance of the terms and conditions. Incorporated within this is Snide London’s Supplier Code of Conduct and Ethical Sourcing Policy.
Supplier Management and Supplier Ethical Data Exchange “SEDEX”:
Snide London requests and commissions independent 3rd party ethical audits from tier 1, 2 and 3 suppliers. We visit suppliers on a regular basis and conduct 2nd Party SMETA (SEDEX Members Ethical Trading Audits) ethical audits on factories in the UK.

Corrective Actions:
Non-compliances found during ethical audits, whistleblowing or other methods form the basis for Corrective Action Plans (“CAPs”). All suppliers are encouraged to work through their CAPs in a timely fashion and Snide London supports suppliers with their CAPs as required. If critical issues such as evidence of human trafficking are found, business would be suspended until corrected and terminated permanently if the issues are not resolved. Whilst Snide London aims to support suppliers in the resolution of incidences of human trafficking and slavery within the supply chain and recognises that it is not possible to effectively solve the issue without the full cooperation of the supplier.

TRAINING AND AWARENESS RAISING
All staff joining the business attend a company induction where Snide London’s ethical and environmental sourcing policies, including those on Modern Slavery and Human Trafficking, are explained.
Snide London continues to develop training for those who are involved directly with supply chain management, to improve knowledge and awareness of the issues and concerns surrounding Modern Slavery. Snide London also encourages employees to participate in external training programs and seminars on social compliance issues, human trafficking and modern slavery.

BOARD APPROVAL

David Almond

This statement has been signed by David Almond, Managing Director on January 9th, 2018.