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"We made our first modern slavery statement in July 2016 which detailed the changes the business had made since the introduction of the Act in October 2015, including confirming a company policy on the subject and updating paperwork such as our ethical code of conduct, audits and supplier documentation. We trained relevant colleagues to understand the subject and moreover we opened dialogue with suppliers on understanding the risk in their businesses. Having previously been focused on our primary tier one suppliers, we have developed systems to map,risk assess and audit further down the supply chain tiers, which have been developed overthe last four years. This includes engaging key suppliers to understand their approach to recruitment and the risk of slavery, and expanding our supply mapping to include suppliers who were making things for us that we did not sell, for example our packaging.
In this financial year of July 2019 - June 2020 we have continued to focus on the issue and have taken the following steps:
1. Continued updating our supplier audit database to include modern slavery risk assessments, introducing new data tracking to assess our immediate position.
2. Continued developing best practice assessment for UK suppliers and services.
3. Visited our core clothing suppliers based in Northern and Southern India which may represent only 15% of our global supply base but contribute over 40% to our overall business. Ourin-house team conducted deeper audits on these visits, examining ways of working for recruitment, staff overtime, and HR protocols.
4. Maintained in house training forrelevant teams focusing on supplier onboarding to limit exposure to potentially high-risk suppliers early in the process.
5. Began assessments on our packaging and non-stock suppliers that support business processes. These are all based in the UK and whilst this does not pose a large risk it still forms a part of our overall supply base and is in scope for assessment.
6. Joined the Better Cotton Initiative. Sustainability of the materials we use is a key focus of ourteams. Cotton production, particularly at the beginning of the supply chain at the farm level, can lead to a higher risk of modern slavery occurring. We have made a commitment to use only sustainably sourced cotton in our products by 2025. Whilst using Better Cotton, because it is a mass balance system, does not necessarily directly affect the risk of modern slavery, it can help us by increase the visibility and traceability of our cotton supply chain down the tiers. The cotton producing supply chain who are part of the Better Cotton Initiative are supported in identifying, preventing, mitigating, and remediating forced labourrisks"
I have left the answer Desk Research although the company does not mention using information on modern slavery prevalence to assess risk in their supply chains.