Modern Slavery Statement
This statement has been drafted and published in accordance with the UK's Modern Slavery Act 2015 (Section 54). The statement is a summary of the steps Hobbs has taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of our business or in our supply chains.
At Hobbs, we acknowledge the importance and severity of modern day slavery and human trafficking. We recognise there are multiple stages of the supply chain, and we make every effort to ensure that slavery and human trafficking is not within our business. Hobbs has a zero tolerance approach towards slavery and human trafficking and continually strives for complete transparency and best practice in our business operations. We expect our staff to be alert to the risk in our business and to report any concern however small, which must be fully investigated by the management team.
Since our first shop opened in Hampstead, London in 1981, Hobbs has grown from a small sought-after, shoe label to a global brand synonymous with the best of British design.
We pride ourselves on a high quality of design and craftmanship ensuring each item offered to our customer meets a high quality standard.
We are a multichannel retailer with 219 stores and concessions across Europe. In 2015/16 Hobbs had a turnover of £110m and we employ over 1000 people.
Ensuring we produce quality products in a responsible way is fundamental to our business. We have a stable supply base and well established relationships with suppliers and manufacturers who share our business values. We have a network of 86 suppliers linked to 130 nominated manufacturing sites. We are proud of the long term relationship we have with our suppliers in Italy and our footwear collection is handmade in our very own traditional factory in Italy.
Countries included in Hobbs live supplier network 2015/16
Policies and Contractual Obligations
At Hobbs we are committed to working in collaboration with suppliers to encourage continual development and best practice. As part of our Supplier Manual we have a Code of Conduct and Global Sourcing Principles, in which we confirm the importance of corporate responsibility to our brand and further support our commitment to responsible business practices both in our own business and within our supply chain.
Our sourcing principles were formalised in 2012 and are continuously reviewed with our most recent revisions implemented in May 2016. Our principles set out the minimum requirements we expect our suppliers and manufacturers to meet, wherever we are operating. Our principles are based on the Ethical Trade Initiative's (ETI) Code of Conduct which is designed to be fair and achievable, covering the principles of international law for best practice in rights at work: no child labour, no forced labour, no discrimination, the right to freedom of association and collective bargaining, wages, working hours, communication of employment, health and well-being.
We operate a Whistleblowing Policy aimed at supporting our employees and also available to others working in our supply chain. We recognise that effective and honest communication is essential if concerns about breaches or failures are to be effectively dealt with. We encourage every employee to speak up about genuine concerns in relation to criminal activity; breach of a legal obligation; miscarriage of justice; danger to health and safety or the environment; discrimination; victimisation or harassment; and slavery and human trafficking. The policy is for all those who work with or within the organisation including those on a permanent or fixed term contract of employment, temporary contract or employed through an agency, independent consultants, contractors and suppliers.
In line with our commitment to continually strive for transparency; in 2016 we drafted a Cotton Procurement Policy for implementation in 2017. We acknowledge the serious concerns about the use of cotton from Uzbekistan and Turkmenistan and the overwhelming evidence of Government sponsored use of forced and child labour in the harvesting of cotton. Hobbs has made the decision to ban the use of cotton coming from these regions. This pledge will stand until the International Labour Organization (ILO) has verified that the respective governments have ended this unacceptable practice.
Our Foreign Migrant Labour Policy explicitly highlights that foreign migrant labourers in our supply chain are treated equally and ethically. Forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery or trafficking of persons shall not be used and will not be tolerated. Our suppliers are required to accept, implement and make known their commitment to our Ethical and Fair Employment of Migrant Workers ‘’Code of Conduct’
In addition, we are in the process of amending our terms with suppliers to include an obligation for them to explicitly support our MSA commitment. We will review our relevant policies by the end of 2016 and ensure the revised versions are sent to all our suppliers. Any supplier that acts in a way which invalidates our MSA commitment will face appropriate action and may ultimately lead to the termination of the contract.
All of Hobbs’ policies have been drafted and developed by subject matter experts and have been signed off by our CEO, Meg Lustman.
Due Diligence and Supplier Assessments
We acknowledge the greatest exposure to slavery and human trafficking lies within our supply chains. In order to mitigate and manage these risks we have continued to focus on open communication and transparency across our supply base, with the continual mapping of our suppliers and product manufacturing sites. All of our first tier suppliers go through a pre-order screening process and are subject to a Factory Approval Procedure which is managed by our Technical team.
The Factory Approval Procedure is for the supplier to demonstrate it meets the minimum standards as set out in Hobbs Supplier Code of Conduct. These include:
- Employment Ethics
- Health & Safety Practices
- Environmental Practices
We have a commitment to only use factories that have been approved by our internal team. The aim of this procedure is to promote best practice across our supply base.
When we begin a relationship with a supplier/manufacturer we follow the sourcing principles below:
- All proposed suppliers/manufacturers must be met in person at Hobbs Head Office or alternatively in the country of manufacturer.
- All proposed suppliers/manufacturers must complete a Supplier & Factory Set Up Form; a Factory Standards Form and provide a copy of a recent independent IRCA social compliance audit report which is conducted in compliance with the legislative requirements wherever in the world the manufacturing operates. These documents are reviewed by a senior member of the Hobbs Technical team and discussed with the proposed Supplier/manufacturer.
- All suppliers/manufacturers are issued with a Hobbs Supplier Manual during initial discussions outlining our full terms and conditions of engagement including the Code of Conduct and business policies by which we operate.
- Suppliers/manufacturers are asked to sign an agreement of compliance to our principles and responsible sourcing code of practice (please refer to the Code of Conduct), prior to the confirmation of production commitment.
If a factory is found to be in violation of the Supplier Code of Conduct, Hobbs will work closely with the supplier and/or factory to improve standards. The development will be closely monitored and to an appropriate time frame.
Once we have accepted a supplier, we actively monitor their commitment to ethical trade through workplace assessments (audits). Hobbs has a customised monitoring database to collate all corrective action plans (CAP) from our 3rd party audits and on-site visits carried out by our internal team. The database is a systematic way for us to record, and better understand, the patterns in identified areas for improvement, enabling us to support suppliers through measurable timescales.
Workplace assessments are carried out by reputable 3rd party firms, such as Intertek, SGS and Bureau Veritas. During 2015 the number of primary sites risk assessed totalled 43 and the total number of sites inspected was 27. The on-site inspections highlighted 10 factories which Hobbs' consider to have breaches against our principles. We are committed to working with these factories to put remedial plans in place.
Locations of sites inspected in 2015:
Hobbs reserves the right to cease supply and terminate our contract where a supplier does not address the issues raised.
We understand the limitations of traditional ethical audits and are looking to collaborate with leading experts and other stakeholder organisations to support us, and our supply chain partners, to enhance our risk assessments and audits in 2017.
Assessing and Managing Risks
Over the past year we have increased our focus on slavery and human trafficking within our business operations at Board Level and through our Corporate Responsibility (CR) Steering group. The CR Steering group is chaired by our Chief Executive and has members from across the organisation including Buying and Merchandising, Design and Marketing, Technical and Creative Development, Logisitcs, Property and Human Resources.
The CR Steering group is responsible for highlighting and supporting strategic priorities, investing in training for all staff and communicating the company's ethical standards and procedures to both internal and external stakeholders. We are currently in the process of developing internal KPIs to further encompass our zero tolerance approach to slavery and human trafficking within our broader sustainability strategy.
Hobbs joined the ETI in December 2012 and since then has been an active member and has established a small network of ethical trade partners within the SME groups to enable peer exhange and collaboration on supply chain issues. In 2016 Hobbs completed its first ETI Foundation level report which outlines the policies, plans and management systems we have in place to effectively implement ethical trade programmes throughout our business and supply chain.
We have performed a comprehensive supply chain mapping exercise and have 100% visibility of our primary suppliers. We recognise in our supply chain that the countries with the highest number of people in slavery and human trafficking are China and India (Based on the findings in the Global Slavery Index 2016: http://www.globalslaveryindex.org/findings/) and have taken steps to mitigate these risks. We will continue to assess risks within our wider business operations and plan to broaden the scope of our supply chain mapping through 2017 to include non-clothing procurement and facilities providers to further enhance our transparency and awareness across business functions.
Slavery and Human Trafficking Communication
We recognise the importance for all Hobbs' employees to be aware of the risk of slavery and human trafficking. We are working with external experts to support our senior staff and board members in understanding the the importance of slavery and human trafficking in our business operations. This information will be rolled out to all employees in 2017 through our induction programme and via our business update meetings. We will also inform our suppliers on the implementation of relevant policies via our annual/on-site supplier visits.
Upcoming actions to prevent slavery and human trafficking
With support from our CEO and Department Heads we will affrim our zero tolerance towards slavery and human trafficking to all our service providers and suppliers. Department Heads from Buying and Merchandising, Design and Marketing, Technical and Creative Development, Logisitc's, Property and Human Resources will be responsible for disseminating Hobbs position on slavery and human trafficking to their relevant staff and stakeholders.
We acknowledge that we cannot solve the problem of slavery and human trafficking alone. We are a committed member of the ETI and are looking into working with more collaborative partners to support our commitment of continuous improvement and transparency.
Monitoring our Effectiveness
Slavery and human trafficking risks are not static and our efforts must continue. We plan to review our actions and measure the progress we have made on an annual basis.
In order to assess our effectiveness for preventing slavery and human trafficking, we will review the following key performance indicators and will report on them in future Modern Slavery statements;
- Training of staff and suppliers on slavery and human trafficking
- Stakeholder engagement and collaborations with others
- Actions taken to strengthen our risk assessments and supply chain mapping
- Disclosure of the total number of non-compliances were in relation to slavery and human trafficking
- Remediation plans for our suppliers where slavery and human trafficking risks have been identified
This statement was approved by the Board and Ms Meg Lustman, Chief Executive Officer at Hobbs
Name: Ms Meg Lustman
Date: 7th February 2017
If you have any concerns or questions regarding our MSA statement, please contact our Customer Services Team: Email: firstname.lastname@example.org, Telephone: 0203 095 3939.
- Young Worker & Child Labour Policy
- Please see full policy here Young Worker & Child Labour Policy
- Cotton procurement policy
- Please see full policy here Cotton Procurement Policy
- Whistleblowing Policy
- Please see full policy here Whistleblowing Policy
- Foreign Migrant Labour Policy
- Please see full policy here Foreign Migrant Labour Policy