MODERN SLAVERY ACT 2015: SLAVERY AND HUMAN TRAFFICKING STATEMENT
INTRODUCTION FROM KIERON TRAYNOR, GROUP CEO – BEST DRESSED GROUP LIMITED
Modern slavery is a crime and a violation of fundamental human rights. Best Dressed Group recognises the importance of combatting the risks of servitude, forced labour and human trafficking in all our operations. Our corporate values centre on the principle that employment should be freely chosen and our processes built on an ethical foundation. We are committed to continuously improving our practices to identify and remediate modern slavery.
We act ethically and with integrity in all our business dealings and relationships and we will strive to further implement and enforce effective systems and controls to prevent modern slavery from taking place in our own business or in our supply chain.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
ORGANISATION OVERVIEW AND TURNOVER
Best Dressed Group Limited is one of Europe’s leading workwear groups, supplying corporatewear and PPE across multiple sectors internationally including hospitality, healthcare, travel, business services and heavy industry. Our specialist Fire division develops fully certified life-saving structural fire fighter suits. Our wholly owned garment factory in Tunisia manufactures workwear and fire suits for the group and for other customers.
We are the parent company to a number of subsidiaries within the Best Dressed Group umbrella and ultimate ownership (Group). The Group has 629 employees worldwide and operates in multiple countries including the UK, Spain, Germany, Holland and Tunisia (as at the date of this statement).
The Group had an aggregate annual turnover of £50 million for the financial year to which this statement relates.
OUR BUSINESSES
Our business is organised into six principle business units and/or operating subsidiaries which operate from various international locations:
1. Ballyclare Limited – UK
Ballyclare Limited is a British designer, manufacturer and distributor of high quality, functional work wear, protective clothing and specialist PPE. They are a trusted producer of structural and specialist firefighting kit and protective clothing for the emergency services and armed forces as well as supplying managed services encompassing garment supply, leasing, repair and laundering.
2. Simon Jersey – UK
Simon Jersey is one of the UK’s leading suppliers of uniforms. Their customers range in size from one member of staff to hundreds of thousands of employees, in every business sector.
3. Ballyclare International
During 2016, Ballyclare has expanded their UK base into the wider European market with the creation of Ballyclare International. Ballyclare International provides customers in the European fire industry with our expertise, knowledge and a range of firefighting kit from structural to technical rescue, wildland and urban search and rescue garments.
4. Orcon/Simon Jersey – Holland
Simon Jersey is one of the leading brands in workwear in the UK and now Simon Jersey is also available in the Netherlands. They specialise in clothes for beauticians, hairdressers and care but will soon expand this range to catering and hospitality. We also sell Orcon® work wear. Orcon® has specialised in industrial workwear and has been supplying innovative workwear since 1913.
5. Uniform Brands SL – Spain
Our Spanish operation provides the full range of Ballyclare, Simon Jersey and Orcon garments into the Spanish market. We commenced our Spanish business during the course of 2016.
6. North Africa – Tunisia
Our Tunisian operation is our own in-house manufacturing base and manufactures a wide range of work-wear (aprons, hats, coats, trousers, overalls, coveralls, jackets, parkas, Hi-Visibility products, seam sealed products and PU products). They serve a large number of customers within Tunisia and continental Europe as well as providing a high quality, short lead time offering to other members of the Group.
We have a zero tolerance approach to slavery and human trafficking of any kind within our business or our supply chain.
OUR SUPPLY CHAINS
As a Group, we source from carefully selected suppliers in Europe and Asia. As well as manufacturing, the Group may also buy in a wide range of products and services across its portfolio and given our international footprint and our wide array of bought in products and services, our supply chains are long and complex.
As a result, the Group applies a proportionate response whereby we concentrate on those products and services of the highest value, importance or risk (whether that risk is identified by product and/or service category or geographical location) (Risk Based Approach) when assessing the potential for modern slavery within our supply chains.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are working towards harmonisation of procedures across the Group, using the Risk Based Approach as the foundation, which are driven by the unique requirements of the product category based on its own activity streams. That said, the goal and approach is broadly consistent across the Group.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. During 2017 we adopted our Group Anti-Slavery and Human Trafficking Policy which reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to strive to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
In addition to our new Anti-Slavery and Human Trafficking Policy, each Group member has a number of longstanding and complimentary polices which have dovetailed together to form a tapestry of compliance in this area. For example, certain of our subsidiaries’ Codes of Conduct, Whistleblowing Policies and Corporate Social Responsibility Framework all help underpin our efforts to mitigate the risk of modern slavery within our supply chains.
We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our processes when on-boarding new suppliers, where possible we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we ensure that our suppliers will hold their own suppliers to the same high standards.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we utilised our Risk Based Approach to identify those suppliers of particular interest as far as modern slavery is concerned. Again, our approach varies between our Group companies but representative actions are as follows:
• We conduct due diligence on our suppliers ranging from desk top analysis through to on site due diligence visits
• On an ongoing basis we monitor our suppliers’ adherence to the mandated policies and principles to ensure continued compliance with our ethics.
• We utilise third party audits and due diligence (such as the Fairwear Foundation) to confirm our suppliers’ adherence with the law, policies, procedures and general compliance.
• We ensure that we have in place appropriate terms and conditions with all of our suppliers.
• All new suppliers must complete a questionnaire covering topics such as remuneration, child labour, forced and compulsory labour.
We have in place systems to:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.
SUPPLIER ADHERENCE TO OUR ETHICS
We act ethically and with integrity in all our business dealings and relationships. To ensure all those in our supply chain and contractors comply with our standards we have in place a supply chain compliance programme within our various subsidiaries, for each member of the Group to reflect the varying nature of their activities.
We have personnel on hand to assist with any risks arising out of modern slavery within each operating business, which cover, and can involve, the following departments and resources:
• Quality and compliance.
• Human resources.
• Procurement.
• Sales.
• Group General Counsel.
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training on our various policies to our staff on an ad hoc basis.
OUR EFFECTIVENESS IN COMBATTING SLAVERY AND HUMAN TRAFFICKING
During the year, we conducted a review of sourcing and upgraded to centres of excellence in core product areas such as tailoring and beauty tunics. We managed the transition progressively away from a small number of suppliers identified as potentially failing to meet our high standards.
IMPROVEMENT ACTIONS DURING THE NEXT FINANCIAL YEAR
As part of the process of preparing this statement, we have identified a number of areas that we feel might benefit from a review to ensure that we are as effective as we can be across the Group at combating slavery in our supply chains. Consequently, we have conducted an internally facilitated review to bring insights on the ways that the Group can improve its processes towards tackling slavery and human trafficking. As part of that review, we shall:
1. Look at the ways that best practice can be shared internally within the Group. We have identified that certain Group companies are not as evolved as others in terms of processes and compliance on this issue and we shall look at ways in which we can be more consistent across the Group, particularly in overseas jurisdictions;
2. Evaluate our internal training and ascertain if it can be improved including awareness of our policies;
3. To assess our KPIs on monitoring and capturing any issues as regards slavery and human trafficking;
4. Review our whistleblowing policies to ensure that they are fully compatible with our new our Group Anti-Slavery and Human Trafficking Policy;
5. Identify any other general areas of improvement that may be made and to ensure steps are in place to continually monitor, evaluate and improve Group policies as a whole.
6. Reduce the number of suppliers in our supply base to allow better focus on our key suppliers.
7. Ensure that our suppliers include compliance with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes in their agreements with their direct subcontractors and suppliers.
8. Conduct a critical review of our grievance procedures to ensure that anyone who raises genuine concerns that modern slavery of any form may be taking place in our own organisation or our supply chain can do so without suffering detrimental treatment.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2017.
Kieron Traynor, Group CEO
Best Dressed Group Limited
Date: November 2018