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MODERN SLAVERY & CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS STATEMENT

UK Modern Slavery Act 2015 and California Transparency in Supply Chains Act 2010 statement 2019

This Statement has been published in accordance with the Modern Slavery Act 2015 and California Transparency in Supply Chains Act 2010. It sets out the steps taken by REISS LIMITED (“REISS”) during financial year ending 2 February 2019 to prevent modern slavery and human trafficking in its business and supply chain. Reiss Limited is a subsidiary of Reiss Holdings Ltd. The 2019 Statement is written by the CSR representative, approved by Reiss board members and signed by Jonathan Blanchard, Chief Operating Officer.

Reiss initiated the process to become foundation members of the Ethical Trading Initiative in early 2017 and its application was successfully accepted in May that year. Reiss is due to become a full member in early 2019 and will publish its first annual report to ETI. ETI is a leading alliance of companies, trade unions and NGOs that promotes respect for workers' rights around the globe and strengthens Reiss’ commitment to ethical trade and the eradication of modern slavery with expert guidance and support. Reiss is an active and vocal foundation member, involved in many country specific working groups which adds value to its risk management. Reiss contributes to the Turkey, Mauritius and Modern Slavery working groups, engaging with other members and increasing best practices.

In 2018, Reiss manufactured products in 15 different territories including China, Turkey, Portugal, Romania and Italy. These 5 sourcing countries accounted for 90% of our purchasing volumes which saw Reiss consolidate its supply base and focus on strengthening long term supplier partnerships. Other production countries are India, Sri Lanka, Vietnam and Philippines. Reiss continues to explore new sourcing opportunities and in early 2018 began production in Mauritius. Prior to placing any orders and as an integrated business practice, Reiss followed its Ethical Compliance and Due-Diligence programme to adeptly identify challenges and sourcing risks. As with any sourcing region, Mauritius presented challenges such as forced labour, modern slavery and human trafficking. Reiss has identified these challenges and monitors this collaboratively through its supplier partnership and involvement in the ETI Mauritius working group as well as collaboration with ASOS to address migrant workers right to the government of Mauritius.


Structure, business and supply chains

Since its creation by David Reiss in 1971, Reiss has established a design philosophy centred on creating design-led menswear, womenswear and accessories.

Today Reiss is a highly respected, prominent business in the global fashion arena with products developed at its headquarters in central London, employing 1401 employees across its headquarters and retail locations.

Reiss operates in Australia, Canada, France, Germany, Hong Kong, Korea, Middle East, Netherlands, Spain, Switzerland, United Kingdom and the United States, across 192 stores, (including 31 wholesale and franchise shops and 12 internet sites) and has a highly developed e-commerce presence. Reiss manufactures its finished goods through a global network of external suppliers and sources its raw materials through the same network as well as in-house.

Reiss remains committed to ensuring that its operations and supply chains promote safe, fair, legal and humane working conditions. This means we expect the business and our suppliers to abide by local laws, international labour and human rights standards in all countries in which we or they operate.

Our commitment to the eradication of slavery, servitude, forced labour and human trafficking (collectively referred to as modern slavery) in the business and our supply chain is closely aligned with the Modern Slavery Act 2015. We recognise the reality of these issues for all concerned and we have established measures to identify the risks to our business that modern slavery presents. These measures are reviewed annually to ensure best practice.

This statement provides an overview of our work to implement an effective governance framework and our enhanced due diligence process which includes a close review of modern slavery risks and indicative factors in the way we operate and how we source. Responsibility for the Modern Slavery sits with the board and is executed by the CSR representative. Year on year the Modern Slavery Act Statement is reviewed and updated according to agreed improvements for the year to come. 

In 2018, Reiss manufactured products in 15 different territories including China, Turkey, Portugal, Romania and Italy. These 5 sourcing countries accounted for 90% of our purchasing volumes which saw Reiss consolidate its supply base and focus on strengthening long term supplier partnerships. Other production countries are India, Sri Lanka, Vietnam and Philippines. Reiss continues to explore new sourcing opportunities and in early 2018 began production in Mauritius. Prior to placing any orders and as an integrated business practice, Reiss followed its Ethical Compliance and Due-Diligence programme to adeptly identify challenges and sourcing risks. As with any sourcing region, Mauritius presented challenges such as forced labour, modern slavery and human trafficking. Reiss has identified these challenges and monitors this collaboratively through its supplier partnership and involvement in the ETI Mauritius working group as well as collaboration with ASOS to address migrant workers right to the government of Mauritius.

The ETI working groups provide Reiss with expert advice and the platforms are to discuss challenges and best practices with fellow members.

All sourcing countries face their own geopolitical, cultural and legal differences and is partly the reason that Reiss continues to evaluate and monitor supplier compliance through supplier self-assessment forms, third party audits and factory visits. Please find more in the chapter policies in relation to slavery and human trafficking.

All information is recorded and monitored in a central database and is used to map Reiss’ supply chain. In 2017 Reiss successfully mapped its tier one suppliers and has continued updating information in 2018 by adding their subcontractors. Reiss has onboarded 18 new suppliers in China and Europe who have handed over audits and corrective action plans. In 2017 and 2018 the focus has been on our main supplying countries China and Turkey. We therefore have had less visibility on other production countries (see further steps for improvements in 2019).


Policies in relation to slavery and human trafficking

The Reiss Ethical Compliance and Due-Diligence programme (Governance Framework) is an integrated business practice and is a vital foundation for all supplier partnerships. This framework is also applied to Reiss’ own business operations.

Reiss is committed to its Supplier Code of Conduct which is based on the ETI Base Code and covers Worker and Human Rights (This includes Modern Slavery as well as Environmental Protection and Animal Welfare).

Our Modern Slavery Act and Code of Conduct can be found here as well as our Gender Pay gap statement.

The programme sets out our requirements, expectations and guidance, outlining the minimum social standards that must be met. The programme consists of the Reiss Supplier Manual, Self-Assessment Form, Code of Conduct and Supplier Engagement – Terms of business together with supplier audits and its corrective action plans.

Core policies in the Code of Conduct for suppliers and sub-contractors are;

• Modern Slavery is prohibited, and employment freely chosen

• Child Labour will not be used

• Freedom of Association

• Working conditions should be safe and hygienic

• Living wages should be paid

• Working hours should not be excessive

• No discrimination on the work floor

• Regular employment is provided

• No harsh or inhumane treatment is allowed

• Migrants should be employed legally

Together, these documents collect key information on labour practices, working environments, health and safety as well as general ethical trade awareness. Modern Slavery is mentioned directly in our Supplier engagement form and Code of Conduct confirmation. Country region, product category and partnership type are also considered, and combined with an existing factory audit verifies the data provided. These policies are monitored in our database on a regular basis, conversations with suppliers on corrective action plans and 3rd party auditing.

Identification of risks together with steps taken to prevent and manage that risk

The Reiss Ethical Compliance and Due-Diligence programme (Governance Framework) is an integrated business practice and is a vital foundation for all supplier partnerships. This framework is also applied to Reiss’ own business operations. The framework elevates Reiss’ efforts to better detail its sourcing landscape and ability to align itself to the Modern Slavery Act.

Reiss continues to risk assess all suppliers and production sites using information obtained from the Ethical Compliance and Due-Diligence programme. This, in conjunction with business KPI’s and country risk insight from public sources such as the World Bank, United Nations, the Global Slavery Index and ETI membership support Reiss’ approach to risk prioritisation and audit selection. Reiss applies the same approach when assessing risks in its own operations, such as collecting key information about labour practices of its contracted partners. In an effort to further promote greater transparency and traceability, Reiss has initiated the use of Segura systems in our business operations, allowing Reiss to track and trace the orders of lower tiered trim suppliers. It provides an insight into which suppliers order trims and Reiss can follow up non-nominated suppliers.

 

Due diligence processes in relation to slavery and human trafficking in business and supply chains

 

To support Reiss’ due-diligence efforts, all suppliers are required to submit an existing factory audit and based on the supplier’s risk assessment, an ethical audit (with focus on social aspects) may be conducted. These audits assess compliance with our Supplier Code of Conduct and are, amongst other things, intended to identify any modern slavery practices. If issues are identified, appropriate investigative and remedial actions are taken. Reiss supported all factories in ensuring Corrective Action Plans were monitored and completed with appropriate evidence recorded. Reiss audits are conducted by ELEVATE ( https://www.elevatelimited.com/ ) and assessed against the Reiss code of conduct and local labour laws by experienced country local auditors. The structure of each assessment is adjusted to meet Reiss’ objectives, country challenges and supplier history.

Reiss recognises audits are a useful tool as part of a wider due-diligence programme however, does not solely depend on them, instead endorses a holistic approach including production site visits and collaborative supplier partnerships. See also chapter ‘further steps’.

 

Training and capacity building

 

Reiss annually updates the business on its commitment to the Modern Slavery Act and developments to the Ethical Compliance and Due-Diligence Programme. Attended by key departments including Sourcing, Technical, Buying, Design, Fabric, and Brand Communications; the business update outlines the requirements of the Modern Slavery Act and Reiss’ commitment. It also encourages each department to assess and improve their own practice and influence. Social Compliance and Modern Slavery is part of the daily business at Reiss. It is discussed during the onboarding process. Currently there are no measures of the effectiveness of these trainings.

 

Supplier Self-Assessment

 

Suppliers are required to complete a self-assessment form for each factory location that produces Reiss products. The Self-Assessment is an integrated exercise providing insight into a factory’s workplace, environmental protection and health & safety policies in addition to subcontracted processes, if any. Suppliers are also asked to submit the most recent factory social audit. Combined, Reiss can detail and approve factories and sub-contractors before an order is placed, which continues to influence our overall decision making on further compliance assessments and sourcing adjustments. A bespoke self-assessment form is also shared and recorded for all contracted partners used in Reiss’ own operations.

 

Supplier Code of Conduct

 

Updated in 2017 with language on child labour, human trafficking, slavery and anti-corruption the Reiss Supplier Code of Conduct is aligned with the intent of the Modern Slavery Act, reflecting best practice and stakeholder expectations. The code of conduct is core to the Ethical Compliance and Due-Diligence programme and has been shared with all suppliers and contracted partners in Reiss’ own operations. As standard, the code requires access to both Reiss and third-party auditors to perform unannounced audits that check compliance with all core labour rights.

 

Reiss also updated its code to include language on responsible recruitment reaffirming its commitment that no worker should pay for a job and the costs of recruitment should be borne not by the worker but by the employer. All suppliers are required to share their recruitment policies as part of the ethical and compliance programme.

 

 

The Reiss supplier code of conduct builds on the Ethical Trading Initiative (ETI) base code and International Labour Organisation principles, standards and guidelines.

 

 

Supplier Engagement – Terms of Business

 

Reiss’ Supplier Engagement – Terms of Business is a principal tool used to communicate the obligations on suppliers to comply with the Modern Slavery Act. The Terms of Business also supports Reiss’ efforts of greater transparency by requiring suppliers to declare all production sites and sub-contractors. Reiss monitors suppliers’ audits and Corrective Action Plans (CAP’s) and we ask ETI base code related questions in a survey each supplier must complete before they receive a first order. 

 

Further Steps

 

 Building on the work conducted over the last 12 months, this year Reiss will focus on mapping fabric mills sourced in-house and suppliers of license partners. Reiss will continue to build transparent supplier relationships which will support its mapping efforts with suppliers who source raw materials on our behalf. It is our aim to have transparency on our 10 main fabric mills and their subcontractors.

Reiss continues to risk assess its supply base and extend its audit programme, encompassing its biggest purchasing volumes for 2019 as well as planning independent audits in the Far East and Turkey. Reiss will encourage suppliers with audits older than 2018 to do an update and aims for the future to have no audits older than 2 years.

 Meetings are planned will local ETI offices to get a better understanding of risks per country (for example Syrian refugees working in Turkey)

We also encourage suppliers to engage with their local ETI office to join workshops and seminars.

Finally, Reiss looks to develop its training programme to include department specific programmes that will provide a wider business understanding of Modern Slavery Risks.

This statement was approved by the Board and executive team of REISS limited.

Signed

 

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Jonathan Blanchard, Chief Financial & Operating Officer

Date: 11/04/2019