pg. 12-13
"SECTION 4: ACTIONS TAKEN TO ADDRESS MODERN SLAVERY RISKS
To manage the risk of modern slavery, Best & Less Group has in place a rigorous Ethical Sourcing Strategy. Ethical sourcing is a complex matter, that reaches the global retail environment and requires a commitment from world organisations and factory owners themselves to achieve systemic change. At Best & Less Group, the movement towards ethical sourcing is not new, and is something we have worked towards for over six years.
The program includes:
• Stringent supplier selection which includes aligning with suppliers who also supply to larger retailers including Walmart, Primark, Next, H&M, Aldi.
• Ethical Sourcing Code (ESC) which outlines the code of conduct and policies in relation to social, environmental and standards of compliance that we require from our business partners. The ESC covers thirteen points and each one represents the values of our business. Our code is translated into Chinese and Bengali and is displayed in our factories for all workers to read. The ESC can be viewed on our websites.
• All new and renewed merchandise supplier contracts include specific clauses on modern slavery.
• Onboarding, supplier training and communications is provided to all suppliers. Onboarding processes include the requirement for all suppliers to sign and agree to abide by the ESC prior to working with us. Suppliers are also provided with regular training either in- person through our office in China or via video conferencing. In FY20 we conducted 6 training sessions with 250 participants. Training included:
• Living Wages capacity building workshops
• Ethical Sourcing Code and policy awareness training
• Compliance and auditing protocols
• Sustainable Packaging
Furthermore, our team are in regular communications with our suppliers to ensure adherence to the ESC.
• Our Global Auditing Program undertaken by an independent third party to review the ethical, social, and environmental factory conditions and mandates alliance to the ESC. Best & Less Group audits all tier one merchandise manufacturers bi-annually and reports to the Board on key measures including the number of manufacturers who are non-compliant, the number of manufacturers with critical breaches, the nature of any critical breaches, what remediation is require, the speed of improvement and what ongoing monitoring is in place. Best & Less Group have a zero tolerance for modern slavery and those suppliers found to have such a breach are immediately terminated and receive no further orders unless they can demonstrate remediation of their processes.
In FY20, 217 tier one merchandise manufacturers were audited with all factories compliant overall. Some areas of improvement were identified including appropriate record keeping, use of safety equipment, compliance to newly introduced legislation and evidence of compliance to the ESC. Corrective actions plans are in place and Best & Less Group are working with suppliers to agreed timelines to achieve the required improvements. The factories we work with were found to be also fully compliant with Social Compliance Initiatives and have passed many other audits such as BSCI, SEDEX, WRAP, Disney, and Walmart.
Our aim was to also audit all tier two factories during FY20 however this was put on hold due to the COVID-19 pandemic. This program will be re-initiated once it is safe to do so.
• In-line and final inspections are conducted in factories regularly by our team and third party inspectors in country to ensure standards are maintained. If issues are identified, appropriate investigative and remedial actions are taken.
• Worker Engagement including interviews and worker voice surveys.
• Inspections of wage records and purchasing practices.
• Company-wide grievance mechanisms enable employees to report issues as outlined in our Whistle-blower policy and Grievance policy. Team members are encouraged to voice their concerns without fear of retribution and with full confidentiality. In FY21, the Group launched a Worker Voice Grievance Hotline (December 2020) which will enable workers within our direct merchandise suppliers to access similar grievance mechanisms. Best & Less Group has commenced an awareness campaign for all locations in which we operate, including factories posters to ensure workers are aware of and can access this program."
pg. 14
The evidence above does not respond to this metric and I did not find evidence of the company reviewing its business indicators for modern slavery purposes. Therefore, I have changed the answer from Yes to No.