MODERN SLAVERY STATEMENT 2020 / 2021 - FatFace

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MODERN SLAVERY STATEMENT 2020 / 2021 - FatFace
MODERN SLAVERY
STATEMENT
2020 / 2021
MODERN SLAVERY STATEMENT 2020 / 2021

OUR COMMITMENT                                                                                                       ABOUT FATFACE
I am so proud of the continued         continue to support our suppliers        Over the course of the last          Founded in 1988, FatFace is a          Since our last Statement FatFace         We report on our Modern Slavery
commitment that FatFace has in         to make improvements to their            financial year, we have initiated    British, family, lifestyle clothing    has undergone a change in                risks and responsibilities as
undertaking due diligence and          working conditions. However, we          a new human rights and modern        brand that is Made for Life. With      ownership, which means we have           part of our sustainability KPIs;
addressing any human rights            have seen a deepening of some            slavery risk assessment of           a unique heritage, FatFace creates     new members of our Group Board           progress against these KPIs is
risks that appear within our           endemic issues such as wages             our top 5 sourcing countries,        sustainable product ranges             representing our new shareholders.       reviewed every 2 months by our
business. Like many businesses         non-compliance and long working          which we have used to identify       across women’s, men’s, and kid’s       This has meant a renewed focus           senior management team and
in the UK and around the world,        hours amongst some suppliers.            priority supply chains for deeper    clothing, footwear and accessories     on modern slavery risks as we            annually through the FatFace
over the past 12-18 months FatFace     Our focus now is to ensure that          analysis. We’re embarking on an      for the whole family to live life      brief those new to our business on       Group Board Audit Committee.
has experienced unprecedented          these issues are rectified, and that     assessment process to understand     in. Our products are designed          our activity in this area. Our new       We’ve also recently moved to
changes to our operations in           workers’ lives are not negatively        the presence of human rights         with purpose and built to last.        shareholders have also prompted          monthly reporting to the Group
our stores, online and in our          impacted in the long term. We’re         risks, including modern slavery      Considered Style. Trusted Quality.     us to undertake a deeper supply          Board of several key sustainability
supply chains. We’ve experienced       working with in-country assessment       and forced labour risks, in 3 of     Sustainably Sourced.                   chain mapping exercise earlier           indicators. This means we’re
disruptions to our critical paths      teams and our manufacturing              our second-tier supply chains                                               in our strategic plan than we            regularly scrutinising our
unlike any we’ve known before, and     partners to achieve this.                in India and Turkey. We’ll be        FatFace is a multichannel retailer,    had originally scheduled, which          performance against targets to
throughout we’ve shown resilience                                               reporting on the outcomes of         with a thriving international          illustrates their commitment to          ensure sufficient progress is being
as well as continuous support for      FatFace tracks a number of key           these assessments in our next        digital business as well as over       understanding and addressing             made and any issues that arise
our manufacturing partners. The        performance indicators to ensure         statement.                           200 stores in the UK and over          modern slavery and human                 are promptly investigated and
vast majority of our partners have     that we continue to conduct                                                   20 stores in the US and a highly       trafficking risks in the supply chain.   resolved.
emerged from the worst of the          proper supply chain due diligence,       I am confident in the steps          engaged social community. We are
pandemic with their businesses         which includes assessing common          we are taking to identify and        a brand with sustainability at its     We continue to take a robust             Our sustainability KPIs cover
and workforces intact, and I believe   symptoms of modern slavery               resolve Modern Slavery risks         core, with a clear strategy around     approach to sustainability, which        our supply chain due diligence
that our approach, supporting our      risks. We report on these KPIs           in our supply chain and we will      three key pillars – product, planet,   is a core part of our business           activities, which is the route
partners and working together, has     to our senior management                 remain fully focused on these        and community. Devoted to style,       strategy and includes a clear            through which modern slavery
contributed to that.                   team every 2 months, to our              activities through our responsible   dedicated to sustainability.           reporting structure into the             symptoms and risks are raised
                                       Group Board at least once per            sourcing programme, working                                                 Operational and Group Boards.            and escalated as business-critical
We also know that the risks
to workers have changed and
                                       year and publicly through this
                                       statement. We are also reporting
                                                                                in close collaboration with our
                                                                                manufacturing partners.
                                                                                                                     OVER 200                               Our Modern Slavery Act 2015
                                                                                                                                                            responsibilities sit with our
                                                                                                                                                                                                     issues. Our Operational and
                                                                                                                                                                                                     Group Boards are experienced
worsened as a result of the            against a number of other                                                     STORES IN THE                          Responsible Sourcing team, which         in managing governance around
pandemic. It is the poorest in
the world that have been
                                       indicators regarding our broader
                                       Sustainability Strategy every
                                                                                                                     UK AND OVER 20                         is led by our Trading Director
                                                                                                                                                            Nick Stevenson, who sits on our
                                                                                                                                                                                                     sustainability and they provide
                                                                                                                                                                                                     vigorous scrutiny of our approach
impacted the most by lockdowns         month. Our KPIs include:                                                      STORES IN THE US                       executive Operational Board.             and progress.
and the health impacts of this
disease, and we are acutely            •     ustaining an appropriate
                                            S

                                                                                                                     OVERVIEW OF OUR CORE PRODUCT SUPPLY CHAIN
aware that many of the workers              corporate governance structure
in apparel and footwear supply         •    Upholding a declaration of
chains fall into this category.              commitment from our suppliers
We’ve been working hard with our       •   Closely monitoring                                                       We aim to establish and                shared duty to have a positive           gives us excellent visibility of
suppliers to make sure that they             performance against our                                                 maintain long-term commercial          social and environmental impact.         our first-tier factories, which
are providing secure employment              supply chain code of conduct                                            relationships with our partners,                                                provides an effective platform for
for their workers and are aware        •     Monitoring risk beyond our                                             based on mutual trust and shared       We know that our business                understanding and addressing
of the proper precautions to                  first-tier suppliers                                                   growth. We have been working           is dependent on our working              modern slavery and human
take to protect them. We’re also       •      Tracking and reporting on the                                         with our top 20 suppliers for a        relationships with our suppliers,        trafficking concerns within
checking to ensure that protective             issues that highlight risks of   Liz Evans – CEO                      combined period of 240 years,          especially in the current global         the supply chain.
measures are in place via our                  or are symptomatic of Modern     September 2021                       with the average relationship          climate. We always seek to work
on-site visits. It is because of our           Slavery, and the remedial                                             time being 12 years. We always         with partners who understand
robust Responsible Sourcing                    action taken                                                          seek out partners who strive to        and share our business values
programme that we are able to          •       Maintaining staff training                                           meet our high quality and ethical      and expectations. The strength
respond to the changes in our                   levels, with a focus on those                                        requirements and recognise our         of our supplier relationships
supply chains so quickly and                    procuring product

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MODERN SLAVERY STATEMENT 2020 / 2021

OUR POLICIES IN RELATION TO                                                                                        We continue to deliver our robust             conditions and freely chosen                    result of failure to engage with our

SLAVERY AND HUMAN TRAFFICKING                                                                                      Responsible Sourcing programme,               employment. Most of the issues                  programme this year.
                                                                                                                   making sure that annual due                   that we have encountered through
                                                                                                                   diligence 3rd party audits are                the assessment of these broader                 We recognise that human rights
We adopted our definition of           Our primary goal is to achieve      Ethical Trading Initiative (ETI)        in place1 for 81% of our first-               human rights standards relate to                abuses can exist within our non-
modern slavery from the UN             transparency and trust between      Base Code and the UN Guiding            tier factories2 and undertaking               management systems and policy                   product operations. In our last
Guiding Principles on Business         us as buyers and our suppliers      Principles on Business and              more in-depth Verification                    development. It is likely that the              risk assessment, we identified
and Human Rights, which state          so that we can identify issues      Human Rights, both of which             Assessments, follow up and Root               impact of COVID-19 will have                    recruitment and the utilisation
that ‘modern Slavery involves one      and work together to resolve        cover Modern Slavery issues.            Cause Analysis visits at 19 key               affected the focus of assessments;              of contract labour as areas of
person depriving another of their      them. This means that we will                                               sites. We would normally expect               we will continue to monitor the                 potential risk, and we have
liberty in order to exploit them for   continue to buy from suppliers      We have recently updated our            to complete many more visits,                 findings from these sections in                 policies in place accordingly to
personal or commercial gain’.          and factories that may have high    FatFace Way of Life and will            but our work has been hindered                future audit reports and seek                   mitigate these risks.
                                       risk issues, provided that they     be issuing the new version to           by the lockdowns and travel                   ways to improve reporting
We know that human rights              remain committed to making          suppliers and factories over the        restrictions in place in many of              where possible.                                 In 2018 we joined the Better
abuses occur within global             long term improvements.             coming months. We have taken            our sourcing locations throughout                                                             Buying Initiative to allow our
garment supply chains and, as                                              into account changes in our own         the year. Our aim is to focus                 As with previous years, our                     suppliers to anonymously assess
a responsible retailer, we have        We continue to ensure that          operations as well as the changing      resources on completing more                  Responsible Sourcing programme                  our performance and share
a duty to identify and address         suppliers are aware of and          retail and sourcing landscape.          Verification Assessments in the               has identified occasional issues                lessons for FatFace to improve our
these issues within our own            sign our global supplier code       We have included requirements           coming financial year to revitalise           that could be symptoms of                       buying behaviour. We believe that
supply chain. We work together         of conduct, ‘The FatFace Way        to share information about sub-         this programme and continue to                modern slavery, including charges               this is the most powerful way for
with partners such as the Ethical      of Life’ as a way of sharing our    contractors and sub-suppliers           support our partners to achieve               for uniforms and late-payment                   us to improve working conditions
Trading Initiative and The             values and expectations with        within our regular reporting            meaningful improvements in                    of wages and benefits. The late                 in factories, as we know that many
Re:Assurance Network, as well as       our core product suppliers. The     expectations, as well as specifically   working conditions. Where we                  payment of wages and benefits                   of the issues that arise can be
other brands, to improve working       expectations set out in our ‘Way    prohibiting certain processes and       have completed Verification                   are often related to hours worked               caused by commercial pressures.
conditions and reduce the risk to      of Life’ are based on universally   products from high risk regions         Assessments, we have also                     just before national or regional                We have now undergone 3
our business of modern slavery         recognised labour standards         or countries.                           analysed the COVID-19 response                lockdowns, so compliance                        surveys, 2 of which took place
occurring in our supply chain.         including those outlined in the                                             of these facilities, making sure              with local law is the goal for                  during the pandemic. The most
                                                                                                                   that proper safety measures are in            improvements. Where we find                     recent report from this survey
                                                                                                                   place and assessing the factories’            such issues, we continue to                     continued to show areas of

ASSESSING RISKS AND DELIVERING IMPROVEMENTS
                                                                                                                   compliance with our expectations              engage with suppliers to ensure                 positive behaviour, including
                                                                                                                   on wages payments during                      that they are resolved as soon                  the ‘Win-Win Sustainable
                                                                                                                   lockdown periods.                             as possible, and in most cases                  Partnership’. However, our
Our risk assessments show              risks in our second tier as well.   requesting sub-contractor and                                                         we continue to work with the                    performance remains challenging
that our greatest risk of human        Having mapped our core product      sub-supplier information from           Our preferred 3rd party                       factories involved to try to address            in areas such as ‘Sourcing and
rights abuses exists in our core       supply chain against country        our manufacturing partners              assessment standard (Sedex                    the root causes of the issues we                Order Placement’ and ‘Payment
product supply chain. Apparel          specific risks highlighted by the   and comparing this to data              Members Ethical Trade Audit                   encounter. On the rare occasions                and Terms’. We are committed to
and accessories supply chains          Global Slavery Index, we know       that we already held from our           (SMETA)) specifically includes                that our supplier sites refuse to               reviewing our order management
are long and complex, with a           that India, China, Cambodia         Responsible Sourcing programme.         standards on human rights issues              engage in the process of resolving              and purchasing practices
large number of different actors       and Pakistan are the sourcing       The mapping and risk assessment         such as land use, community                   serious labour rights or human                  to ensure that we can make
involved between the production        countries with the highest risk     activities helped us to identify        engagement and management                     rights abuses, we will terminate                improvements to our suppliers’
of raw materials through to the        of modern slavery occurring in      3 ‘priority supply chains’ in 2         systems activity, alongside existing          our business relationship with                  experience of working with us.
product arriving in our stores.        our supply chain. These countries   sourcing countries, with more           human and labour rights issues                them. We did not have any cases                 We’ll include our progress in this
The majority of these actors sit       also form 4 of our top 5 sourcing   to follow as we complete the            such as living wages, working                 of factories that were exited as a              area in our next Statement.
outside of our direct sphere of        locations, with Turkey being the    process. We have commissioned
influence, particularly from the       5th. We therefore chose these 5     our supply chain partners The
second tier of our supply chain        countries to undertake a human      Re:Assurance Network to complete
downward. We continue to               rights risk assessment, helping     a programme of assessments in           1
                                                                                                                    Total number of due diligence audits in place in last reported update to SMT – May 2021. This is not the total number of assessments
focus our efforts on our first tier    us to identify sector and country   the 2nd tier units of our priority
                                                                                                                    undertaken in the reporting year.
supplier sites, but have recently      level human rights risks. We also   supply chains, the findings of          2
                                                                                                                    81% is lower than we have reported in previous statements – this is due to the impact of the coronavirus pandemic on our global supply,
commissioned a programme of            completed a mapping exercise of     which will form part of our next         where sites were closed and not able to undertake their usual annual assessment. The total % of site with a valid audit has increased in
work to assess modern slavery          our deeper product supply chain,    Modern Slavery Statement.                the early part of the current financial year.

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MODERN SLAVERY STATEMENT 2020 / 2021

HOW WE REPORT ON MODERN SLAVERY RISKS                                                                            TRAINING AND DEVELOPMENT
WE ANALYSE HUMAN                    them on the human rights risk
                                    assessment and supply chain
                                                                        requirements. We are also
                                                                        exploring an NGO partnership
                                                                                                                 All members of the Design, Buying
                                                                                                                 and Merchandising (DBM) teams
                                                                                                                                                         has been delayed due to the
                                                                                                                                                         impact of COVID-19 on our
                                                                                                                                                                                             We’ll also be undertaking training
                                                                                                                                                                                             on purchasing practices in light
RIGHTS ABUSES AND                   mapping activity, which helped      to critique our programme and            participate in training that outlines   business, with many members         of the findings of the 2021 Better
                                    to secure additional funding for    approach, initially focusing on          the principles of our code of           of staff being on furlough for      Buying survey results. This will
NON-COMPLIANCE                      us to complete the proposed         the supply chain mapping and             conduct, and the implications that      portions of the financial year.     help us to implement any changes
AGAINST OUR CODE OF                 assessment programme.
                                    The primary source of external
                                                                        human rights risk assessments
                                                                        that we’re undertaking in our
                                                                                                                 human rights abuses can have
                                                                                                                 upon our supply chain and the
                                                                                                                                                         We’re committed to increasing
                                                                                                                                                         the training participation of our
                                                                                                                                                                                             to the product development and
                                                                                                                                                                                             buying process, which we hope will
CONDUCT THROUGH THE                 oversight for our programme is      2nd tier. We’ll report further on        people in it. We hold an induction      commercial colleagues in the        positively impact on the experience
IMPLEMENTATION OF                   through our membership of the
                                    Ethical Trading Initiative (ETI).
                                                                        the progress of this potential
                                                                        partnership in future Statements.
                                                                                                                 for all new DBM team members to
                                                                                                                 introduce them to the team and
                                                                                                                                                         coming months and utilising
                                                                                                                                                         e-learning modules to roll out
                                                                                                                                                                                             of our suppliers.

FATFACE’S RESPONSIBLE               In the past we have reported                                                 brief them on our work.                 training to colleagues in other

SOURCING PROGRAMME.                 annually against the ETI’s
                                    principles of implementation,
                                                                        We will also be publishing our first
                                                                        Environment & Social Governance
                                                                                                                 Our planned training programme          business functions as well.

                                    as well as submitting detailed      Impact Report in the 2021/2022
We report to our commercial         progress reports against our        financial year, which will give
leadership team every 2 months,     objectives. The ETI has changed     a much more detailed view of
as well as reporting to the Group   its reporting requirements to       our activity across our whole
Board through the annual Audit      require members to report           Sustainability strategy, including our
Committee. Our most recent          publicly on their activity, which   Responsible Sourcing programme
presentation to the Board updated   we will do in line with their       and modern slavery risks.

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FatFace, Unit 1 Ridgway,
Havant, Hampshire, PO9 1QJ
023 9244 1100, fatface.com
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