pg. 22
"ASOS recognises indicators of modern slavery such as the following*:
• Recruitment fees, deposits for work and deceptive recruitment practices
• Restriction of movement at work or in accommodation
• Harsh and inhumane treatment
• Withholding worker documentation
• Cash-in-hand, withheld or delayed payments
• No access to grievance mechanisms
• Accommodation tied to employment
• Poor working of accommodation conditions
• Forced or excessive overtime
• Human trafficking
• Lack of work permit"
pg. 36
'Assessment of effectiveness
The next year will bring many challenges as the impacts of the COVID-19 pandemic are felt. ASOS is committed to working with other retailers, brands and organisations to coordinate a sector-wide approach that protects vulnerable workers in the aftermath of the pandemic.
Supply chain transparency is a fundamental aspect of our approach to eliminating modern slavery in our operations, and something we continue to prioritise. With issues as complex and hidden as modern slavery, it becomes even more important to shine a light on problem areas if we are to address them effectively. By mapping our supply chain and sharing information within our sector and beyond, we make it more likely that issues will be identified and addressed. We are proud to have ranked highly among the biggest global fashion and apparel brands and retailers for transparency in the 2020 Fashion Transparency Index, and will continue to work to gain further visibility over the next reporting period.
As we gain more visibility of our supply chain and further risks of modern slavery are identified, we recognise that we will need to continually renew our efforts to minimise negative human rights impacts on vulnerable people in our supply chain. Our responsibility as a brand is to ensure that our due diligence systems are sufficiently robust to avoid complicity with any such abuses and to remediate any instances of modern slavery we identify. We are committed to continuing to increase compliance across the ASOS Brands supply base, delivering on our commitments to the protection of human rights, worker voice and empowerment. We will also continue to engage and share our ambitions with our third-party brand partners.
As a fast-growing global organisation, it’s crucial that we measure how effective our interventions to empower workers, address business impact and engage with policy and legislation are in delivering long-term impact. We must remain particularly aware of emerging risks and be alert to the dynamic nature of both modern slavery and the impacts of our own operations.
Our modern slavery work cannot stand still. We will continue to assess, develop and extend our approach to modern slavery, both in the breadth of approach across the Responsible Procurement programme and Brand Engagement programme, and in the depth of work within ASOS Brands product-sourcing regions. We will continue to work with our partners and other brands to reduce risks of modern slavery wherever they occur."
The evidence above does not show that the company has defined performance indicators against which to measure its effectiveness. Page 22 is about identification of risk (see above) not of KPIs. Page 36 on assessment of effectiveness does not show quantitative assessment through KPIs but qualitative reviews which is not covered in this metric. Finally, whilst the company does disclose number of audits, does not make reference to it being a KPI. Therefore, I have changed the answer to No.
Ethical Trade and Sourcing practices, including human rights and modern
slavery, are key elements of the biannual corporate risk review process,
which is facilitated by the Business Assurance Team overseen by the
General Counsel and Company Secretary on behalf of the ASOS plc Board.
The review is performed across ASOS with the participation of ASOS’
leadership team and management. We report on risks identified, along
with any material changes to risks, to the Audit Committee and in our
Annual Report to investors. (p.9)
Progress report pages 26-27 where it reports number of suppliers they exited, percentage of suppliers that completed questionnaires, number of child remediation programme, etc.
Changes to Yes because of the above on reporting progress