This Modern Slavery statement is published by Sabre Retail Fashion Limited t/a Mint Velvet in accordance with section 54 of the Modern Slavery Act 2015. It covers our statement for the financial year January - December 2022, as well as January - June 2023. Due to organisational changes and the revamping of our internal priorities we are reporting on an extended period of 18 months. We will provide an interim statement in January 2024 to cover the next 6 months and we will then resume reporting on our financial year as of January 2025. This statement was approved by the Board of Directors of Sabre Retail Fashion Limited on 6th July 2023.
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 that value continues to be a priority in the way we conduct our business. We 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 trust and understanding.
Chief Executive Officer
6th July 2023
What is Modern Slavery?
Modern slavery is a term used to encompass slavery, forced and compulsory labour and human trafficking. Modern slavery exists in both developing and developed countries, including the UK and can involve UK citizens as well as foreign nationals. Modern slavery is an overarching term. It is complex, evolving, and hidden.
- Human trafficking - is the process of bringing a person into a situation of exploitation.
- Forced and compulsory labour - all work or service which is not voluntary and is exacted under the menace of penalty.
- Bonded labour - results when workers borrow money to pay fees to recruiters or labour brokers to get their job and then have to spend most of their wages to pay off that debt. Workers are unable to quit despite unfair or illegal conditions because of their debts.
- Slavery - a situation where a person exercises (perceived) power of ownership over another person. The eradication of global modern slavery is a challenge for the whole of fashion supply chain. 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 and work to eliminate the possibility of modern slavery in our supply chain. Mint Velvet – Modern Slavery Statement 2022/23 5 of 18
At the highest level our modern slavery programmes are overseen by our CEO to uphold our social responsibility and human rights standards, with the overall management sitting with our CEO and board of directors. The task of implementing the day-to-day basis of our Corporate Social Responsibility (CSR) vision sits with our CSR and People teams. Our CSR team reports into our Technical Manager, working closely with our CEO and discussing key matters with expert CSR consultants and senior management. Our CSR department covers all areas of managing the impact of our business on both the planet and people who are not direct employees - ensuring key areas of our supply chain are targeted and scrutinised with special attention. We are also in the process of setting up an internal CSR Taskforce to integrate discussions on CSR into all areas of the business, to raise awareness and act on topics such as purchasing practices, traceability, positive social impact and workers empowerment. Our first meeting will take place in the summer of 2023.
Mint Velvet Employees
We have a robust recruitment process which includes our own due diligence checks including 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 work space. These include: - Anti-Slavery and Human Trafficking Policy - Anti-bribery Policy - Disciplinary Policy - Grievance Procedure - Health & Safety - Diversity & Inclusion – Equal Opportunities - Bullying & Harassment - Bribery Act Policy - Whistleblowing Policy
At a policy level, we have a framework that sets out our ethical standards and norms for supply chains. These include the following:
- Code of conduct, which is derived from ILO conventions
- Supply Chain 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
- Sub-contractor and Homeworkers declaration
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. All suppliers are required to read and sign a declaration confirming their compliance with our above standards when they start our new supplier onboarding process.
Addressing the complex issues around human rights takes nothing less than a collaborative approach with stakeholders. We are proud to say that in 2022 we became foundation members of the Ethical Trade Initiative (ETI), a leading alliance for companies, trade unions and Non-governmental Organisations (NGOs) that promotes respect for workers' rights around the globe since 2012. The ETI enables brands to work together with industry experts and improve working conditions for workers in their supply chains. We are on the journey to becoming full members of the ETI in the summer of 2024. Our CSR Coordinator has undertaken a training course looking at ethical initiatives which has been incorporated into our modern slavery approach. In the coming year, the team will undertake further specialist training courses. By investing in this training, it allows key updates and programmes to be passed on to the necessary teams. We have delivered training workshops for key personnel within the business on responsible and sustainable sourcing which includes understanding an audit, the risks of modern slavery, the ETI Base code and country specific risks. We are currently bringing together ongoing training programmes for departments. Mint Velvet remains committed to being a 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.
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: Risk Assessment: We follow the The Guiding Principles (UNGP’s) on Human Rights and try to understand where our most salient risks are and where we can have the greatest impact. With this in mind, we prioritise our work through risk assessment. We acknowledge it is neither feasible nor practical to assess every risk in our supply chain at the same time. We start with reviewing risks by country and industry. We then review risks to workers by sector, nature of work, type of worker and recruitment processes. For example, we try to understand the workforce population, nationalities and if any recruitment agencies are used. We use our existing internal knowledge and various tools to help us understand risks. These are some of the key public independent tools that we have used to build our risk assessment:
- Trafficking in Persons Report (TIP) US State Dept
- List of Goods produced by Forced and Child labour US State Dept
- Walkfree.org Mapping: We acknowledge that the risk of modern slavery is often greater further down product supply chains. Supply chains can be very complex, fluid and informal. We have found it is no easy task when mapping supply chains, but it is an important challenge for the business that we are embracing. We have overhauled our mapping process and developed a more robust risk analysis process for open CAPs to ensure concern areas are highlighted. In the coming year we are implementing an internal Product Lifecycle Management (PLM) system that will create a much more robust mapping system and help share our concern areas with the teams who use those suppliers.
We know that a potential risk of modern slavery can start with recruitment fees, so when this was flagged as a potential concern with one of our factories, we had an independent auditor on the ground visit the factory to understand the situation further. We have then since worked with the factory to understand the concerns around this and are supporting them in an improvement plan. After the recent earthquakes in Turkey, we reached out to all our affected suppliers to support them in any way that we can. This includes having increased flexibility with our orders. We are currently reviewing our long-term targets for due diligence and are using our first-hand experiences to highlight our necessary priority areas. In-person factory visits: This year, our CSR team will conduct some overseas and UK factory visits to gain further understanding of our current supply base and to strengthen the substance of ethical audit report findings. Our buying and technical teams are continuing to visit several suppliers this year in China, Turkey and Europe using the opportunity to discuss working conditions and gain visibility and knowledge of practices, being our eyes on the ground. If concerns are unveiled, then we will work with our suppliers to ensure the best outcome.
New Suppliers and Factories
Our Onboarding process:
1. Buying team identify a new supplier/factory and sends our initial supplier set up form.
2. Supplier completes the supplier set up form and proceeds to share an ethical audit, cap and signed declarations.
3. CSR review and risk rate the audit. We flag any issues and ask for evidence of improvement or plans to remediate issues, providing support where we can. If the site is unwilling or unable to improve, we will not proceed with the site.
4. All site information is reviewed by our CSR, Technical, Supply Chain, Financial, Buying and Merchandising teams and can only be signed off once all teams have given their approval.
Third-party audits: All first-tier manufacturing sites within Mint Velvet’s product supply chain must have an ongoing 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. Further audits are requested on a regular basis, with a maximum period of two years in between. Though an important tool, we recognise the limits of third-party audits and are committed to supporting suppliers to continuously improve working standards and exploring ways to go beyond auditing – innovative supply chain monitoring, capacity building or worker engagement programmes to help support continuous improvement within supply chains. We are in ongoing talks with an independent ethical auditing company to conduct in-person ethical audits on our behalf, communicating the findings of their visits to us and developing improvement plans for our suppliers.
We are aware (via media and civil society reports) of the risk of forced labour of Uyghurs and other Muslim minorities in the Xinjiang Uyghur Autonomous Region (XUAR) as well as other regions in China. We have issued a letter to all our suppliers underlining our expectations and forbidding the use of forced labour of Uyghur workers. We will send out an updated declaration in the coming months to ensure our suppliers know that we do not tolerate any forced labour or human trafficking of Uyghur and other Turkic and Muslim majority people in our Chinese supply chain. In addition, we source a wide range of goods and services such as packaging, print, logistics, IT and shop-fitting from third party suppliers. These goods and services not for resale (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. We will continue to work through our GNFR suppliers in the coming year, to request audits from their own supply chains and increase transparency with these third party suppliers.
We recognise it is important to collaborate with others. Businesses cannot achieve their goals alone and only by working with like-minded others, can we achieve greater scale, innovation and impact. Below is an example of key partners we collaborate with. We have been proud members of Better Cotton since 2021. Better Cotton’s mission is to help cotton communities survive and thrive, while protecting and restoring the environment. Better Cotton is sourced via a system of mass balance and therefore products may not contain Better Cotton. We are committed to supporting responsible leather manufacturing across the globe and that is why we have been proud members of Leather Working Group (LWG) since 2021. At Mint Velvet, we are signatories to Textiles 2030, a voluntary agreement for the UK textiles sector. Textiles 2030 is an ambitious UK based sustainability initiative that aims to transform the textiles sector by making science-based targets progress on climate action and by delivering a UK- wide roadmap on circularity. This is an initiative which allows Mint Velvet the opportunity to build relationships with other members of the industry and work collaboratively. Mint Velvet – Modern Slavery Statement 2022/23 16 of 18 We are also signatories of The Microfibre Consortium, working to reduce microfibre release within the textile industry and protect our environment. Building research and gaining knowledge on the microfibre release of our textile production since 2022. Our most recent partnership is with The Good Cashmere Standard. Certifying cashmere to this standard is caring for the well-being of the cashmere goats, protecting the environment and supporting the herders that produce it. To further our commitment to ethical trade, industry collaboration and understanding our modern slavery risks we are foundation members of the Ethical Trading Initiative, aiming to be full members by the summer of 2024. This demonstrates Mint Velvet’s commitment to work with industry partners to improve the global supply chain in both sustainability and ethical practices. We are open to work with other brands to share experiences, support suppliers and identify collaborative projects. We continually review external partners which Mint Velvet could collaborate with and will continue to do so into the next year and beyond.