MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2015-16

Shop Direct is the UK’s second largest pureplay online retailer. Our retail brands comprise Very.co.uk, Littlewoods.com and Veryexclusive.co.uk.. We exist for one simple purpose – to make good things easily accessible to more people. Our ambition is to be a world class digital retailer, and we’re well on the way to that. We’re confident that we’ll achieve our ambition by staying true to our purpose and the values that underpin everything we do here at Shop Direct. You can read more about this by clicking here.

As is befitting of our world class ambitions, we at Shop Direct are fully committed to taking action to combat modern slavery and human trafficking within our business and supply chains. This statement outlines the steps we’ve taken to do so during the 12 months up to and including 30 June 2016. It covers both Shop Direct Home Shopping Limited and Shop Direct Finance Company Limited – respectively the retail and financial services businesses within the Shop Direct Limited group of companies.

INTRODUCTION

At Shop Direct, we’re committed to behaving in a responsible way. We operate within strong ethical and environmental standards and are dedicated to being the best possible citizen we can in the communities where we operate.

We’re proud supporters of the UN Global Compact, a diverse group of 2,400 companies and organisations that support corporate social responsibility, and we continue to abide by the Ten Principles in all of our business operations. We are also members of both the Ethical Trading Initiative and SEDEX, and a signatory to the Bangladesh Accord, all of which help to guide and support our CSR activities.

We have an established CSR board of senior stakeholders who meet quarterly. This group is tasked with driving and embedding our CSR agenda across Shop Direct. We also produce an annual CSR report which outlines our progress in this arena. Click here to view our 2015 report.

With our commitment to supporting the Modern Slavery Act 2015, and in line with our ambition to be a good corporate citizen, we’ve recently created a modern slavery and human trafficking policy which we’ll be making visible to all our colleagues. Click here to view the policy.

BACKGROUND – HOW AND WHERE WE OPERATE 

Own brand product
We have a broad and varied supply chain, sourcing both own brand clothing and footwear and home and living products from over 700 factories in 20 countries worldwide.

Branded product
We supply a range of branded products, sourced from branded suppliers across clothing and footwear and home and living ranges.

Non-merchandise product
Our commercial teams focus on the sourcing of goods and services that are purchased across various business categories, including IT, facilities management and advertising. These services are purchased in order for us to function effectively as a digital retailer – they are not offered for resale.

Operations
Our fulfilment centres manage the warehousing, dispatch and returns processing of our products and are located in North Manchester and Wrexham. The Wrexham site is outsourced to a third party logistics provider whilst the other sites are managed in-house. All delivery and returns are carried out by recognised national carriers in the UK and Ireland.

The workforce within our fulfilment centres focused on production comprises a mix of Shop Direct permanent staff and temporary agency workers. All temporary agency workers focused on production are supplied by a single national temporary labour supplier. As in our head office, some areas of our fulfilment operations, such as catering, security and cleaning, are outsourced to national third party providers.

Our core customer service operation is outsourced to a single third party supplier, which provides customer contact handling capability. This is facilitated through two locations based in the UK, and three in South Africa.

Financial services
Shop Direct Finance Company Limited is the sole provider of credit facilities to support our retail offering. This enables customers to spread the cost of their purchases using easy to understand credit products. Our financial services business is based at our head office in Liverpool. We also operate dedicated financial services contact centres in Aintree and Bolton. We also work with two additional UK based debt management partners to deliver these services.

DUE DILIGENCE ACROSS OUR BUSINESSES

Summary
We continue to have strict policies in place on labour, human rights and sourcing. These underpin everything we do here at Shop Direct. Our supplier code of conduct is a key aspect of our relationships with our suppliers and is based on the ILO Labour Standards and the provisions laid out in the Ethical Trading Initiative Base Code.The supplier code of conduct forms a key part of our supplier engagement process. It is a contractual obligation that underpins our terms of purchase, and which all suppliers of own brand products sign before the commencement of business.

In order to ensure we remain focused on our commitment and obligation to prevent modern slavery or human trafficking, we are actively involved in defining the standards and policies at the start of the recruitment process. We continue to be involved in how workers are managed throughout their employment, which includes the environment they work in.

We do not accept or use forced, bonded or involuntary prison labour or child labour. Nor do we demand deposits or hold workers’ identity papers or work with businesses that do. We only work with people who choose to work freely, and demand that our suppliers also do the same.

We have an audit process in place which ensures that:

  • Supplier code of conduct is visible to all employees
  • Whistle blowing policy is in place and implemented
  • Recruitment process has strong controls and checks that are evidenced
  • Appropriate controls are in place for sub-contractor selection and oversight
  • Regulatory websites are regularly checked for sanctions against trading partners

The supply of own brand goods and the steps we’ve taken to avoid risks
We expect all suppliers of  own brand  goods to Shop Direct to comply with our code of conduct. We ensure all factories manufacturing our own brand product have third party ethical audits in place, which are reviewed by our internal CSR team prior to contracts being raised.

As a business, we work hard to understand the risks that affect our supply chain through the use of third party risk mapping tools, collaboration with other organisations and the use of our experienced in-country teams. We understand that there are practices that are unique to some countries and some that span multiple countries in our supply chain, and that it is only by working in partnership with our suppliers, factories and wider stakeholders that we will be able to make a positive impact and start tackling modern slavery.

The complex nature of our supply chain can make this difficult to track, but we work in close collaboration with our suppliers to ensure transparency and place greater focus on those areas where we know there is a higher risk.

We have a process in place for the ongoing verification of suppliers’ conformance to the code of conduct, which allows us to evaluate and address risks of human trafficking and slavery. This includes regular audits on a semi-announced or unannounced basis, undertaken by third party organisations, as well as regular announced and unannounced visits by the Shop Direct CSR team. If issues are found at an existing Shop Direct factory, then we work with that factory to put things right.

The supply of branded goods and the steps we’ve taken to avoid risks
When engaging suppliers for the supply of branded goods, we enter into a terms of purchase agreement to which our codes of conduct are appended. If a supplier has not yet signed up to our agreement, we complete a review of their own codes of conduct to ensure they are in line with our own position.

The steps we’ve taken when purchasing non-merchandise goods and services
The purchasing of any such goods is subject to an approval process and, as such it flows through our end-to-end purchase to pay system. Any suppliers must have approved contracts in place that underpin any spending in these areas. For significant relationships, particularly where there is an outsourcing element, offshore locations of our third parties are visited as part of a due diligence activity to ensure that they operate in line with our code of conduct. Any third parties that we work with are required to adhere to this as a part of our business relationship.

The steps we’ve taken to avoid risk throughout our operations
Our colleagues in fulfilment are paid in line with or above market rate for the roles they perform, and salary bandings are reviewed annually to ensure they remain appropriate. As per the Agency Worker Regulations Act, all temporary agency workers are paid comparable rates to their permanent equivalents, ensuring they are also remunerated appropriately. We work in partnership with a recognised national trade union and all our performance targets are in line with the British Standard Institute.

Our third party logistics suppliers carry out regular checks to ensure that any self-employed workers, who are paid per delivery, are able to make a good income, and that any service partners’ drivers are being treated fairly. There are a number of parliamentary and government initiatives already looking at both the ‘gig economy’ as a whole, and self-employed couriers in particular. We are working with our partners to monitor both the sector and our competitors. As part of their overall strategy, our main fulfilment partner has also instigated a project to review its workforce model. All our partners sign up to our code of conduct and are required to conform with employment law and transport regulations.

Our customer service partner has a contractual obligation to comply with our code of conduct, which is based on conformity with the United Nations Charter, Chapter 1X, Article 55, governing international economic and social co-operation with specific reference to workers’ rights and working conditions. We specifically require our suppliers to extend the same principle to all those with whom they do business, including employees, sub-contractors and other third parties.

The steps we’ve taken to avoid risks in our financial services business
Our two UK based debt management partners are sophisticated organisations requiring high skill levels for core functions with FCA licensing requirements, and therefore would be considered low risk. However, we work with our contracted debt management partners to understand the risk of modern slavery and human trafficking within financial services, and we have a detailed audit process in place.

The Shop Direct supplier code of conduct is subject to ongoing audits by our Financial Services Operational Governance Team, who provide ongoing verification of suppliers’ conformance to the code of conduct

OUR COMMITMENT – HOW WE’LL BUILD ON WHAT WE ARE DOING YEAR ON YEAR

Continuous improvement is a key feature of the Shop Direct culture and we are committed to further enhancing our approach to combating modern slavery and human trafficking during our 2016/17 financial year.

In light of the Modern Slavery Act, we will be developing our programme of training and education on modern slavery and forced labour, supported by signposting colleagues who work for our suppliers to the modern slavery helpline.

We have plans in place to collaborate with other retailers to roll out modern slavery training to our internal teams and also to our suppliers and factory sites. We’re researching, consulting and conducting a full training-needs analysis to ensure we provide the right training to the right people.

Training will be designed to ensure that colleagues working in our operations and with our suppliers have the knowledge and skills needed, and are working under consistent internal policies, so that they can take effective steps to reduce the risks of modern slavery. We’ll use this an opportunity to remind people how to report any concerns. All training will align to our internal policies and any legal requirements that have been put in place.

During 2017 we will be issuing all suppliers of branded goods with an updated terms of purchase agreement to ensure that they have visibility of our codes of conduct. Any branded suppliers who have not signed up to our agreement will be asked to provide copies of their own codes of conduct, which we will review to ensure that they are aligned with our own.

We will improve our audit processes to focus more on assessing and further mitigating the risk around modern slavery and human trafficking. Audit schedules of our in-house operations will place more overt emphasis on subcontracting of lower skills roles, such as cleaning and catering..We will also ensure responsibilities have direct line of sight to director level with regular reviews and sign-off.

Our CSR board meets quarterly to ensure we continue to drive our agenda forward. We have recently established a working group with representatives from across our businesses who will meet regularly to update on progress and continue to drive our commitment to combatting modern slavery and human trafficking in the year ahead.

This statement has been approved by the Shop Direct CSR board and our Group CEO, who will review and update it annually.

Alex Baldock, Group CEO.
On behalf of Shop Direct Home Shopping Limited and Shop Direct Finance Company Limited.