FITFLOP MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR ENDING 31 DECEMBER 2017
FitFlop (“we”, “us”) is absolutely committed to ensuring that there is no modern slavery or human trafficking in our business or supply chains; and to preventing modern slavery and human trafficking in our corporate activities. This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the potential risks related to our business, the steps that we have taken during the financial year ending 31 December 2017 and will continue to take, to ensure that modern slavery and human trafficking are not taking place within any part of our business.
OUR BUSINESS AND SUPPLY CHAIN
FitFlop is a global brand, providing footwear and related items to customers and consumers worldwide. Business activities include the design, development, sourcing, manufacture, transport and sale of products. We act as a holding company for subsidiary undertakings in the US and Germany, with our headquarters in London and operational offices in Hong Kong and Ho Chi Minh City.
We source finished footwear (“Tier 1”) from factories in Vietnam and Indonesia. We also work directly with a number of component, material and packaging suppliers (“Tier 2”) globally. We carry out development work in the UK and China. We have established long-term relationships with several of our partners and have built these relationships over many years in most cases. This enables us to gain a deeper understanding of the issues faced by our suppliers.
The primary risk for our business is in association with our suppliers in relation to sourcing from countries outside of the UK, particularly those based in Asia-Pacific countries. As part of our initiative to identify and mitigate risk in our supply chains, we undertake due diligence and audits on suppliers.
We undertake due diligence when considering new suppliers to take on and regularly review our existing suppliers. We assess our supply chain to evaluate particular geographical risks of modern slavery and human trafficking. We work closely with our suppliers to understand their production processes and we make it a contractual requirement that all suppliers (Tier 1 and Tier 2), retailers and distributors we do business with to sign our Code of Conduct (see below). Employees from our London head office and our regional offices in Hong Kong and Ho Chi Minh City regularly visit all our suppliers. This gives us invaluable insight into working practices, processes and conditions across our supply base, allowing us to spot potential issues relating to modern slavery and human trafficking. In most cases we operate in shared factory environments. We work with our industry partners in spotting and addressing modern slavery and human trafficking issues.
We carry out independent, third-party, audits every two years in the factories we use in all Tier 1 and some Tier 2 manufacturing locations. We employ a global specialist auditing firm to evaluate our partners using the SMETA (SEDEX Members Ethical Trade Audit) methodology, considered to be the gold standard and used by many other established, responsible brands.
We analyse the outcome of audits and decide what action, if any, needs to be taken, including providing advice to suppliers through our third-party auditors; requiring, where necessary, the factory to implement corrective action plans. Should suppliers fail to take appropriate action on any corrective measures or where they seriously violate our Code of Conduct, we would consider invoking sanctions against them or terminating the business relationship.
EMPLOYEE/WORKER DUE DILIGENCE
In each country where we employ staff, we ensure our compliance with the relevant employment legislation. We recruit and select our own workers, with the help of reputable recruitment agents, and determine the terms and conditions of their employment. Employees/ workers are free to accept or reject any employment offers made. As part of our recruitment process we undertake checks on all workers to verify their identity, age and eligibility to work in that country.
We always aim to pay our workers a reasonable and fair wage for the job they are doing, and this will be at or above the legal minimum wage in the country they are employed.
We require the same standards from our suppliers and we confirm this through our audits. We also require the same or equivalent standards from our distributor and franchise partners.
We strongly encourage all our workers and business partners to report any concerns related to our activities or activities within our supply chains. Our whistleblowing policy ensures that all workers know that they can raise concerns about how workers are being treated, or practices within our business or supply chain. This includes any circumstances that may give rise to an enhanced risk of modern slavery and human trafficking. This policy is designed to make it easy for workers to make disclosures, without fear of reprisals.
CODE OF CONDUCT
We are committed to ensuring that our suppliers adhere to the highest standards of ethics. We require all suppliers to sign our Code of Conduct, which mandates the following: safe and sanitary working conditions; no forced labour; no child labour; no harassment or abuse; no discrimination; freedom of association and collective bargaining; payment of at least minimum legal wage; and working hours that are not excessive. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the Code and improve their workers' working conditions. Serious violations of our Code of Conduct would lead to the termination of the business relationship.
CORPORATE SOCIAL RESPONSIBILITY POLICY
We are also building a corporate social responsibility policy, which sets out our commitment to preventing human-rights abuses, minimising environmental damage and assuring fair business practices.
As part of our ongoing efforts to identify and mitigate the risks of modern slavery and human trafficking, this year we have made further progress with the following:
- Required two key employees in our Asia-Pacific operations and factory teams to complete training on modern slavery and on audit principles. This ensures constant vigilance, to mitigate risks that spot checks may not uncover.
- Raised awareness of modern slavery issues to all workers by circulating emails that explain: the basic principles of the Modern Slavery Act 2015; how workers can identify and prevent slavery and human trafficking; what workers can do to flag potential slavery or human trafficking issues to the relevant parties within the company; and what external help is available.
- Continuing to review our existing supply chains, evaluating all existing and potential suppliers.
- Continued to build and maintain long-term relationships with our suppliers and clearly highlight to them our expectations of business behaviour.
- Encouraged the reporting of concerns and continue providing appropriate protection for whistleblowers.
We have reviewed our key policies and processes, and as part of our efforts to identify and mitigate the risks of modern slavery and human trafficking, we shall take the following further steps:
- Over the course of the next year, extend our modern slavery training programme to further members of the Asia Pacific operations and factory teams.
- Continue to review our franchisee operations.
- Continue to review our existing supply chains, evaluating all existing and potential suppliers.
- Raise awareness of modern slavery issues to all workers by circulating emails and providing internal posts on our intranet to explain: the basic principles of the Modern Slavery Act 2015; how workers can identify and prevent slavery and human trafficking; what workers can do to flag up potential slavery or human trafficking issues to the relevant parties within the company; and what external help is available.
- Continue to build and maintain long-term relationships with our suppliers and clearly highlight to them our expectations of business behaviour. We will continue to create an environment of trust and transparency with suppliers and develop a deeper understanding of the issues our suppliers face.
- Encourage the reporting of concerns and continue providing appropriate protection for whistleblowers.
We will not support or deal with any business knowingly involved in modern slavery and human trafficking.
APPROVAL FOR THIS STATEMENT
This statement has been approved by the Board of Directors.