Modern Slavery Statement
This statement is made pursuant to the Modern Slavery Act 2015 (Section 54). The statement is a summary of the steps that Hobbs has taken since March 2017 to prevent slavery and human trafficking from taking place in any part of our business or in our supply chain.
At Hobbs, we acknowledge that modern day slavery (as defined by the ILO definition of forced labour and Article 3 of the Palermo Protocol) takes many forms including forced labour, debt bondage, servitude, child labour and human trafficking.
Hobbs has a zero-tolerance approach towards slavery and human trafficking and we continually strive for complete transparency and best practice in our business operations. We expect all of our stakeholders to be alert and proactive regarding the risk of modern day slavery and to report any concern, which will be fully investigated by our Corporate Social Responsibility (CSR) team and independently audited to protect the human and labour rights of workers.
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 exacting standards of design and craftsmanship, ensuring that each item offered to our customer meets the high-quality levels expected of Hobbs.
We are an omnichannel brand with 195 stores and concessions across Europe and America. Hobbs had a turnover of £132m (ex vat) in the 12 months ending March 2018 and we employ over 1100 people. The Hobbs Distribution Centre is located in Park Royal, London.
Hobbs products are designed in-house at our London based head office and Atelier. Our garment range is manufactured using 3rd parties. The majority of our shoes are hand made in our own traditional shoe factory in Italy.
Our Design, Buying, Merchandising and Technical teams all work in collaboration openly and with mutual ambitions that are communicated to all of our suppliers and factories. We believe that working together with our suppliers and factories is key to ensure that we have transparent, robust and sustainable relationships.
We support our commitment to ethical sourcing with regular training, audits and reviews, internally and with our suppliers in order to achieve the high standards expected of the Hobbs brand.
The following table demonstrates the actions to support our commitment to managing the risk of Modern Slavery within our business.
Our Supply Chain
Producing high quality products in a responsible way is fundamental to our business. We have a stable supply base and well-established relationships with our suppliers and manufacturers. For the products which we sell we have a network of (71) suppliers linked to (101) nominated manufacturing sites. We take a strategic approach to our supply base management. We have reduced our number of suppliers over the last year in order to improve efficiency and to enable us to focus on a partnership approach with suppliers who share our business values.
Currently the top 5 sourcing countries for Hobbs products sold in stores and on-line are:-
|Locations||No of Suppliers||No of Factories|
Our supply chain is divided into two channels
- Own brand product for resale in store and online.
- Non-stock items and services which consists of customer deliveries, logistics, procurement, IT, cleaning and customer care.
We acknowledge that the greatest exposure to slavery and human trafficking lies within our supply chain. In order to mitigate and manage these risks we have committed to focus on open communication and transparency, with the continual mapping of our suppliers and product manufacturing sites.
All of our suppliers go through a pre-order screening process and are subject to a factory approval procedure which is managed by our Buying, Merchandising and Technical teams.
We joined Sedex in May 2018 and have encouraged our suppliers to do the same. Sedex provides an online platform to share factory audits. We believe this membership will improve efficiency and transparency whilst enabling us to work alongside other retailers to ensure that the factories we work with complete the necessary audits and follow up action plans.
Policies and Contractual Controls
At Hobbs, we are committed to working in collaboration with suppliers. Each supplier must sign up to our Global Sourcing Principles which includes our Code of Conduct, contained within our Supplier Manual.
Our Supplier Manual will be reissued this year to include a more explicit reference to modern day slavery, and our expectation is that all of our suppliers are aware and alert to the associated risks and will take appropriate action to eradicate any forms of modern day slavery within their supply chain.
Our sourcing principles set out the minimum requirements that we expect our suppliers and manufacturers to meet, wherever they are operating. We are members of the Ethical Trade Initiative (ETI) and our principles are based on the ETI Base Code which is designed to be fair and achievable, covering the principles of international law for best practice in rights at work; employment is freely chosen, child labour shall not be used, no forced labour, no discrimination, the right to freedom of association and collective bargaining, wages, working hours, communication of employment, health and well-being.
Our Environmental Policy is designed to ensure that our factories meet the required standards with regard to environmental best practice.
As members of the ETI we regularly attend relevant meetings and participate in working groups set up to address labour rights issues. Most recently we have supported their Turkey programme.
We operate a Whistle Blowing Policy which provides reporting channels and guidance for our employees. All staff were provided with an updated summary of our policy and procedures during the first half of 2018. Furthermore, a new online option has been launched across the business enabling all staff to provide anonymous feedback. We encourage every employee to raise genuine concerns in relation to illegal activity; 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 contract basis, independent consultants, contractors and suppliers. Our revised supplier manual details our expectation that all of our suppliers operate a Whistle Blowing Policy for their employees.
Our Foreign Migrant Labour Policy explicitly highlights that foreign migrant workers in our supply chain are treated equally and ethically. The following practices will not be tolerated; forced, bonded including debt bondage or indentured labour, involuntary prison labour, slavery or trafficking of persons. Our suppliers are required to accept, implement and make known their commitment to our ethical and fair employment of migrant workers. Our Third party suppliers must ensure that they are not employing un-registered migrant workers into our sites.
Our Cotton Procurement Policy is In line with our commitment to continually strive for transparency. In 2016 we drafted a Cotton Procurement Policy for implementation in 2017. Hobbs has made the decision to ban the use of cotton coming from any parts of the world where there is evidence of the sponsored use of forced and child labour in the harvesting of cotton.
Due Diligence and Audits
The Technical, Buying, Merchandising and Design Departments manage the supply chain for all products sold by Hobbs. Our suppliers are selected based on required standards across ethical, procedural and commercial criteria. We have a commitment to only use factories that conform to our standards to ensure best practice standards are in place.
We will appoint new suppliers according to the strategic needs of the business. We have a strict set of guidelines to be followed before we can progress.
New supplier Approval Process
The new suppliers are met in person and are required to complete a desktop factory evaluation, upload their latest 3rd party audits to Sedex where appropriate and sign up to our Supplier Manual containing our Global Sourcing Principles , Code of Conduct and Policies.
Once we have approved a supplier or factory we regularly monitor their commitment to ethical trade through workplace visits, assessments and 3rd party audits.
Sedex maintains and collates 'corrective action plans' from 3rd party audits and our internal teams regularly carry out on-site visits. If any 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.
Hobbs reserves the right to terminate a contract where a supplier does not actively engage to address the issue(s) raised.
We have a strict policy prohibiting non-approved subcontracting and the use of non-approved factories is in breach of our terms and conditions. We have a programme in place to conduct semi-announced, announced or unannounced inspections by our nominated 3rd party inspectors. We recognise that these audits only provide a snapshot of factory conditions at that point in time but it gives us an opportunity to monitor transparency and to discuss remediation steps. Factory audits are carried out by reputable 3rd party firms, such as Intertek, SGS and Bureau Veritas.
During our due diligence process we have identified modern slavery risks and as a result put an action plan in place.
|Issue||Description of Risk||Steps Taken|
|Migrant workers:- suspected restriction of movement and document holding||Migrant workers' rights and conditions of employment||Announced Inspection- followed up by an action plan|
|Hobbs Global sourcing Principles:- Suspected suppliers of using un-registered units y||Transparency of additional manufacturing units||Announced inspection|
|On Sedex but no audits uploaded:- Delays in new factory set ups, Factories not being transparent.||Corrective action plans are not visible||Action plan discussed with the supplier to upload within an acceptable timeframe|
Non-stock items and services
We recognise that other areas of our business operations and supply chain also need to be controlled and we work with suppliers of non-stock items and services to ensure the correct processes are in place to protect and support workers. For example, we do not offer any zero-hour contracts for agency workers.
In 2018 we have updated our goods not for resale supplier contracts with a new contract now including our modern slavery policy. All current staff have now been briefed on the Modern Slavery Act and the implications both for Hobbs and for them as individual employees. An on-going programme of communication and training has also been set up.
We also recognise that Modern Slavery is a risk within the construction and procurement function. Suppliers we employ operate in numerous sectors and we seek assurance from all of these suppliers that they have read and understood Hobbs policies and The Modern Slavery Act. Where labour and working conditions could play a factor in the delivery of non-stock items, we ensure correct processes are in place to enable safe working practices.
In addition to the above, we expect our suppliers to confirm that;-
- They have taken appropriate steps to eliminate modern slavery within their own function.
- They hold any sub-contractors to account over modern slavery and enforce the act at all levels.
- They pay their employees at least the national minimum wage.
We direct all new suppliers to our policies on our website and conduct due diligence against any new supplier to maintain our MSA intent. Where we are sourcing manufacture from outside the UK, we would ask for references specifically in terms of labour and working practices.
Assessing and Managing Risk
Over the past year we have continued our focus on slavery and human trafficking within our business operations at Board Level and through our Corporate Social Responsibility (CSR) Steering Group. The CSR Steering Group is chaired by our Chief Executive and has members from across the organisation including the HR Director, Buying Director, Senior Technical Manager, Property Manager, Head of Operations and Head of Buying.
The CSR Steering Group is responsible for reviewing all ethical policies, highlighting and supporting strategic priorities, identifying training needs across the business, and ensuring that there is robust communication and policy compliance in place. We monitor our policies and ensure adherence during factory visits, supplier meetings and through our audit programmes. The CSR Steering Group meets on a quarterly basis.
We assess risks within our wider business operations on an ongoing basis and have worked closely with our logistics providers to ensure that there are modern slavery policies in place.
Mapping our product manufacturer supply chain is an essential piece of work supporting the management of risk. We have a supplier database which enables us to map all of our tier 1 suppliers.
We are keen to maintain long term relationships with our existing suppliers and the aim for 2018 is to start mapping our supply base beyond tier 1.
Upcoming actions to prevent slavery and human trafficking
With support from our CEO and Department Heads, we will affirm 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, Logistics', IT, Property and Human Resources are 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 human rights, slavery and human trafficking alone. We are a committed member of the ETI and work in collaboration to actively support continuous improvement and transparency.
Training and communication
We recognise that all Hobbs' employees should be aware of the risk of slavery and human trafficking. We have rolled out training for all Head Office and Warehouse staff regarding modern slavery awareness and risk. We have issued a modern slavery awareness leaflet to all staff.
The Modern Slavery Act has been an opportunity to embed a greater understanding of human rights within our product supply chain and to extend the awareness of the issue internally across departments.
All of our heads of departments have been briefed and engage in regular discussions on human rights and modern slavery through our CSR Steering Group. In order to monitor the effectiveness of our training our HR department sends out regular questionnaires to all of our employees and we are in the process of setting up bi-annual reviews.
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 have set the following key targets for the following year:-
Summary of KPI’s 2018/2019
- Update and reissue Hobbs Supplier Manual to explicitly reference Modern Slavery, the potential risks and necessary actions to be taken by each supplier. The updated Supplier Manual will be issued to all current and new suppliers.
- Development of a Whistleblowing Policy and procedure for all HO and Store employees. The launch of our 'Speak in Confidence' online tool, landed this year for all our head office staff.
- Work with our third-party auditors to add an additional element to our social compliance audits. This addition to include a direct reference to Modern Slavery and inform supply chain workers of our Whistleblowing Policy and Procedure.
Next steps and milestones;
- By 2020 a review and update of due diligence and mapping for 2nd and 3rd tier suppliers.
- Increase in the number of audits carried out by our third party auditors, also to use 3rd party audits where incidents are suspected or raised so that these can be investigated.
- Map Chinese suppliers and associated factories for Social Insurance Compliance.
- Investigate effective Remediation Policies, working with our peers and joining up with NGOs as appropriate to establish how we can support our suppliers and their workforce in the event of non-compliance.
This statement was approved by the Board and Meg Lustman, Chief Executive Officer at Hobbs
Name: Meg Lustman
Date: September 2018
If you have any concerns or questions regarding our MSA statement, please contact our Customer Services Team: Email: firstname.lastname@example.org