"ASSESSING THE EFFECTIVENESS OF OUR ACTIONS
Our understanding and assessment of the effectiveness of our actions towards managing our risks of modern slavery continues to be evaluated.
To build on the existing risk management measures we currently use as outlined below, the establishment of a robust framework and consolidated regional reporting process, overseen by the Audit and Risk committee, will be established.
The commencement of a cross functional Modern Slavery Working Group with regional representation will assist to strengthen our approach to governance across all regions and give greater insight into understanding how effective our efforts are in driving their intended change. Our policy framework grew with the development of a Responsible Purchasing Policy and accompanying guidance document. Annual training is in place to determine and test its efficacy.
ETHICAL SOURCING PROGRAMME COMPLIANCE
Of the 70 audits we conducted during the reporting period, we oversaw the closure of 55% of non-compliances raised during those audits within the same period. The most prevalent findings related to working hours, social insurance payments and safety. During the reporting period, we did not terminate any factory due to non-compliance with our ethical sourcing requirements.
No claims of reportable conduct were raised through our Whistleblower helpline during the reporting period.
CAPACIT Y BUILDING
Members of our buying and management team received Modern Slavery and Responsible Purchasing training.
Training of further departments at our Head Office planned for the second half of the reporting period was hampered due to COVID-19 and has been re-scheduled to take place in 2021-2022.
NGO benchmarking forms an important tool from which to assess our actions and understand industry best practice. Throughout the reporting period, we have engaged and taken part in industry reports focused on human rights and worker welfare. We view participation in these assessments as useful opportunities for continuous improvement and impact analysis and continue to welcome constructive feedback from our industry peers and stakeholders.
We remain committed to transparency as we progress our strategic objectives and mitigate risks to those most vulnerable in our supply chain and operations."
The company discloses number of audits undertaken in the reporting period (p. 7) and from those the percentage of non-compliances addressed to closure (p. 10)