We help fashion businesses flourishing grow with everything from securing intellectual property rights to renegotiating agency agreements and commercial leases.
Introduction
On 25 September 2020 a report on the independent investigation of poor work practices of Boohoo’s suppliers in Leicester was published. It is likely to result in many fashion businesses looking again at their compliance with the Modern Slavery Act and ensuring compliance by those in their supply chains – factories, suppliers, agents, distributors, franchisees, outsourcers and subcontractors.
Today we provide a compliance checklist as a starting point for all involved in the business of fashion.
The business
The Modern Slavery Act (“the Act”) requires a business with a global group turnover of £36 million or more to make an annual slavery and human trafficking statement. As such:
The supply chain
If you meet the £36m threshold you should assess your business operating model and whether it involves:
Separately, are there any particular issues with suppliers, trade unions or other bodies representing workers that should be disclosed in the annual statement?
Policies
The primary objective of your anti-slavery and human trafficking policy should be to try to prevent slavery and human trafficking in your business and your supply chain.
As such:
Whistleblowing
Does your business have a whistleblowing policy? If so:
Management
It is important that the manager who is responsible for ensuring compliance with your slavery and human trafficking policy is rapidly identifiable by everyone in the business.
This individual should be responsible for:
Does the business ensure that this individual is suitably resourced and financially incentivised?
How does management deal with policy breaches? Does the compliance programme ensure that next steps are identified?
Controlling the risk
You must ensure that due diligence is undertaken to identify risk areas and activities, properly consider those risks, and then manage those risks going forwards.
Have you determined:
Keeping track of your compliance
You should seek to create a set of standards against which you regularly measure your business and your supply chain’s performance. It is not enough to just put policies in place. Often what is perceived as a risk one month can change a few months later.
As such:
Measuring your performance and reviewing the standards regularly helps to monitor risk.
Educating and training your workforce
It is not enough for only management to be involved in the control of the risk of modern slavery and human trafficking. The more aware and educated your workforce are in being able to spot risks and issues, the better for your overall compliance prospects.
As such:
We help fashion businesses comply with the Modern Slavery Act
Compliance with the Modern Slavery Act is compulsory for businesses with £36m or more in global turnover and that compliance therefore extends to those in their supply chains. If you would like help in setting up or reviewing the effectiveness of your Modern Slavery Act policies and systems for compliance, please contact us.
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