Modern slavery act

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. 

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 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.  

Liz Houghton
Chief Executive Officer
6th July 2023

What is Modern Slavery?

Our Business

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 

Policies

Due Diligence

New Suppliers and Factories

Managing Sourcing

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.  

Industry Collaboration

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. 

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 31st December 2021.

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 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.

What is Modern Slavery?

Modern slavey 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 forging 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.

Our business and supply chains

Mint Velvet is a retailer of own brand womenswear, footwear, accessories and girlswear. We operate online, both UK and internationally; via third party websites; through boutique and outlet stores in the UK and Ireland; concessions in department stores in the UK and Ireland.

Mint Velvet sources its products from 44 suppliers across 113 factories in 13 countries, including China, Turkey, India, and across the EU.

We have consolidated the number of suppliers and factories we source from to make more impactful improvements to a smaller number of settings.

Our CSR team and their responsibilities have been streamlined and restructured to ensure key areas of our supply chain are targeted and scrutinized with special attention. This includes developing our escalation procedure for audit report concerns and our CSR team work together to make the best decisions moving forward. We have also overhauled our auditing and supplier visibility review system to ensure key information and concerns are highlighted so appropriate actions can be taken should they be necessary.

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.

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:

Risk Assessment

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. With this in mind, we have started to follow the UNGP’s on Human Rights and try to understand where our most salient risks are and where we can have the greatest impact. 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. Below is an example of key public independent tools that we have used to build our risk assessment:

• Trafficking in Persons Report (TIP) US State Dept
• Verite
• List of Goods produced by Forced and Child labour US State Dept
• Walkfree.org

Mapping

This supports geographical and sectoral-level risk information. 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, reviewing long term targets and developed a more robust risk analysis process for open CAPs to ensure concern areas are highlighted and known to teams who use those suppliers.

Our due diligence process identified one of our suppliers unnecessarily using unauthorised sites without communication to us. We immediately worked with them to understand how this had occurred and put in place an improvement plan.

In-person factory visits

Our CSR team have conducted 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 have continued 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. Where problems were discovered, we worked with suppliers to ensure the best outcome and we hope to continue to take factory visits forward in the next year where this is safely allowed.

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. Though an important tool, we recognise the limits of third-party audits. We are committed to supporting suppliers to continuously improve working standards and exploring ways to go beyond auditing.

Factory Self-Assessment Reports

We have developed a self-assessment form which all of our factories have completed to understand our factories’ responsible sourcing. This includes: awareness of the ETI base code, whether the factory is registered with SEDEX and information on any sub-contractors they may use so we can develop our understanding of our supply base and work to eliminate risks of modern slavery.

Independent ethical auditing

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. This was unfortunately put on pause due to the Covid-19 pandemic but this is a project we are currently reviewing.

China

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.

Industry collaboration

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.

To further our commitment to ethical trade, industry collaboration and understanding our modern slavery risks we will apply to join the Ethical Trading Initiative (ETI) as foundation members in 2022.

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.

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

Key personnel within the business have been trained on responsible and sustainable sourcing which includes the risks of modern slavery and country specific risks by an independent consultant. We are currently reviewing further training for departments.

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.

Key actions looking ahead

In 2022, we aim to:

• Launch our new CSR strategy with long term goals. Including a transparency goal of 100% of product to be traceable to raw material by 2030
• Apply to join the Ethical Trading Initiative (ETI)
• Further define our supply chain tiers and establish long term traceability targets
• Map and engage with specialist NGOs to support our modern slavery strategy
• Enhance our approach by adopting ETI’s Human Right Due Diligence framework

Further ahead, we aim by 2023 to:

• Publish a list of tier 1 production sites
• Map 100% of our tier 2 production sites

This statement was approved by the Board of Directors of Sabre Retail Fashion Limited on 20th June 2022.

Liz Houghton
Chief Executive Officer
20 June 2022

Glossary

UNGP - The Guiding Principles (UNGP) seek to provide an authoritative global standard for preventing and addressing the risk of adverse human rights impacts linked to business activity.

NGO - A non- governmental organisation (NGO) is a non-profit, voluntary citizen’s group which is organised on a local, national or international level. NGOs perform a variety of service and humanitarian functions.

Beyond auditing - Innovative supply chain monitoring, capacity building or worker engagement programmes to help support continuous improvement within supply chains.

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 from 26th April 2020 to 31 December 2020.

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 twelve 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.

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.

Our business and supply chains

Mint Velvet is a retailer of own brand womenswear, footwear and accessories. We operate internationally via third party websites; through boutique and outlet stores in the UK and Ireland; concessions in department stores in the UK and Ireland.

Mint Velvet sources its products from 41 suppliers across 113 factories in 13 countries, including China, Turkey, India, and across the EU.

Mapping and understanding our supply chain is a key focus at Mint Velvet. We have continued our work by focusing on our key and biggest suppliers requiring all suppliers to reconfirm their factory list and provide further supply chain information where relevant e.g. laundry details. We have also expanded the information we gather to develop a broader and more complete picture of our factories such as worker numbers and production capacity. This exercise has meant our declared factory base has expanded as we have increased our knowledge.

As leather is such a key part of our product offer we have taken steps to map our leather supply chain in more detail. This will be a wider, long term project for Mint Velvet but we have begun to map our tanneries with the assistance of our suppliers. Additionally we have developed a feather mapping profile to ensure we have transparency of any feathers we may source.

We have partnered with a CSR and Human Rights expert to develop our internal strategy and knowledge. With this expertise we have built on our polices and procedures to ensure they are robust in tackling modern slavery. This includes updating our supplier set up process to ensure suppliers are clear on our expectations prior to working with Mint Velvet, developing a risk traffic light system where we can communicate internally the level of risk at each factory, improved our supplier database to increase traceability and have capability to produce reports to improve our escalation procedure for audit report concerns and our CSR team work together to make the best decisions moving forward. We have also overhauled our auditing and supplier visibility review system to ensure key information and concerns are highlighted so appropriate actions can be taken should they be necessary.

We have worked hard to involve the wider product teams in our journey and increase internal engagement. We now have periodic meetings with each department to discuss risk and each department’s factory base to ensure modern slavery is considered across all areas of the business. This is with the aim that everyone is aware of the work going on at Mint Velvet and to encourage a business wide focus on CSR and our factory working conditions.

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.

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:

Mapping

This provides geographical and sectoral-level risk information. We have overhauled our mapping process to include all our factory information in one place, linking this information to all areas of our business to increase traceability and business wide consideration of our supply base. Our database holds only concise and consistent information including how each factory scores against risk. We have developed a risk rating matrix to ensure all audits are judged fairly according to our internal and international standards and we log the improvements made over time.

Our due diligence process and mapping exercise highlighted that a supplier was using many more sites than initially declared. We immediately worked with them to understand how this had occurred and implemented an action plan with this supplier where we have now reached an excellent level of transparency.

Communication with suppliers

Due to the pandemic, which has impacted all corners of the world, we have adapted how we communicate with our suppliers to ensure they are aware of our investment in them and the practices in their factories. Our buying teams have regular video calls and check-ins with suppliers to ensure our valued and long standing relationships are nurtured, prioritised and dialogue remains open. Where problems are discovered, we work with suppliers to ensure the best outcome and we hope to begin making factory visits again as soon as we are able.

Third-party audits and factory risk rating

All first-tier manufacturing sites within Mint Velvet’s product supply chain are regularly audited. Further audits are requested on a regular basis, with a maximum period of two years in between. This involves completion of supplier and factory set-up forms prior to placing orders and the provision of an audit from a recognised independent auditor. The audits include, but are not limited to, working conditions, health and safety, working hours and wages.

The CSR team review each audit and apply a risk rating, where there are adverse findings, we work to ensure issues are resolved and assign an internal follow up deadline. With the development of our more systematic process to chase improvement we are able to ensure active involvement and monitoring of our factory working conditions. This work builds a picture overtime of improvement and highlights suppliers who we may need to pay extra attention to if found to be consistently failing. The status of our supply base is reported to management on a monthly basis including where we have seen great improvement in our risk rating in a short period of time.

Industry collaboration

We have become a member of Textiles 2030, a new voluntary agreement for the UK Textiles Sector building on the work from SCAP 2020 which Mint Velvet joined in 2019. Textiles 2030 is an ambitious UK based and government backed sustainability initiative that aims to transform the fashion and textiles sector through industry collaboration. This is an organisation which allows Mint Velvet the opportunity to build relationships with other members of the industry and work collaboratively. Here, ethical practices are often discussed and there is potential for new ethical requirements for member signatories.

Additionally, Mint Velvet partake in a monthly meeting with brands of a similar size to discuss current topics, including ethical and human rights, within the industry and how each brand is approaching the problem. This offers a fantastic forum for collaboration, idea and information sharing so the industry can work together to tackle modern slavery most effectively.

The above demonstrates Mint Velvet’s commitment to work with industry partners to improve the global supply chain in both sustainability and ethical practices. We continually review external partners that Mint Velvet could collaborate with and will continue to do so into the next year.

Branded suppliers

We have strengthened how we work with our branded suppliers by updating our branded supplier contract and implementing a robust due diligence process when a new brand comes on board. Our contract outlines the minimum expectations and actions required from a brand to ensure all forms of our supplier relationships are covered under by our ethical and modern slavery standards.

Mint Velvet employees

We have a robust recruitment process which includes our own due diligence checks such as checking original documents including 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 are trained on responsible and sustainable sourcing which includes the risks of modern slavery annually and country specific risks by an independent consultant. This year we conducted training with our whole buying, merchandising and design teams to highlight the importance of understanding our supply base and how the business will continue to improve our practices. Our CSR and Human Rights expert also conducted regular, in-depth training with key CSR personnel to ensure our CSR representatives across the business continue to have the skills and knowledge necessary to tackle modern slavery.

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 on 23rd June 2021.

Liz Houghton
Chief Executive Officer
23 June 2021

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 25th April 2020.

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 eleven 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.

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.

Our business and supply chains

Mint Velvet is a retailer of own brand womenswear, footwear, accessories and girlswear. We operate internationally via third party websites; through boutique and outlet stores in the UK and Ireland; concessions in department stores in the UK and Ireland.

Mint Velvet sources its products from 31 suppliers across 70 factories in 12 countries, including China, Turkey, India, and across the EU.

We have consolidated the number of suppliers and factories we source from to make more impactful improvements to a smaller number of settings.

Our CSR team and their responsibilities have been streamlined and restructured to ensure key areas of our supply chain are targeted and scrutinized with special attention. This includes developing our escalation procedure for audit report concerns and our CSR team work together to make the best decisions moving forward. We have also overhauled our auditing and supplier visibility review system to ensure key information and concerns are highlighted so appropriate actions can be taken should they be necessary. Additionally, we are planning to bring on-board a new, industry experienced, team member to further assist in the development of our policies and strategies.

We have made CSR even more of a focus within the brand through sharing our finalised CSR strategy with all product teams and we have developed an online hub where customers and colleagues alike can follow our progress in ethical and sustainable matters. We now also share a bi-monthly newsletter outlining internal CSR updates and information on our supplier base. This is with the aim that everyone is aware of the work going on at Mint Velvet and to encourage a business wide focus on CSR and our factory working conditions.

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.

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:

Mapping

This provides geographical and sectoral-level risk information. We have overhauled our mapping process including only concise information and developed a more robust risk analysis process for open CAPs to ensure concern areas are highlighted and known to teams who use those suppliers.

Our due diligence process identified one of our suppliers unnecessarily using unauthorised sites without communication to us. We immediately worked with them to understand how this had occurred and put in place an improvement plan.

In-person factory visits

Our CSR team have conducted a number of 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 have continued 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. Where problems were discovered, we worked with suppliers to ensure the best outcome and we hope to continue to take factory visits forward in the next year where this is safely allowed.

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.

Factory Self-Assessment Reports

We have developed a self-assessment form which all of our factories have completed to understand our factories’ responsible sourcing. This includes: awareness of the ETI base code, whether the factory is registered with SEDEX and information on any sub-contractors they may use so we can develop our understanding of our supply base and work to eliminate risks of modern slavery.

Independent ethical auditing

We are in 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. This was unfortunately put on pause due to the Covid-19 pandemic but this is a project we intend to action in the next financial year.

Industry collaboration

We have become a member of SCAP (Sustainable Clothing Action Plan) which is an industry-led action plan working to deliver positive environmental and economic outcomes for organisations through commitments brands must meet. This is an organisation which allows Mint Velvet the opportunity to build relationships with other members of the industry and work collaboratively. Here, ethical practices are frequently discussed including talks for SCAP to introduce ethical requirements for its members for 2030. This demonstrates Mint Velvet’s commitment to work with industry partners to improve the global supply chain in both sustainability and ethical practices. We continually review external partners which Mint Velvet could collaborate with and will continue to do so into the next year.

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.

Mint Velvet employees

We have a robust recruitment process which includes our own due diligence checks such as checking original documents including 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 are trained on responsible and sustainable sourcing which includes the risks of modern slavery annually and country specific risks by an independent consultant.

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.

Liz Houghton
Chief Executive Officer
21 October 2020

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:

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.

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.

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 Groves
Chief Operating Officer
25 October 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 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:

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.).

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.

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 Groves
Chief Operating Officer
25 October 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 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 Houghton
Chief Executive Officer
25 October 2017

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 Houghton
Chief Executive Officer
29 September 2016