This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by REISS LIMITED (“REISS”) during the financial year ending 31st January 2017 to prevent modern slavery and human trafficking in its business and supply chains.
REISS is 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 embraced measures to identify the risks to our business that modern slavery presents. 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. We view the content of this statement as part of a programme that we expect to progressively enhance.
Establishing a Governance Framework
The Reiss ethical compliance and due-diligence programme sets out our requirements, expectations and guidance for suppliers. It encompasses our Supplier Manual, Supplier Code of Conduct, Self-Assessment Questionnaire and Supplier Engagement Terms of Business as well as core production measures, including purchase order terms, labelling guidelines and inspection processes. We expect all our suppliers to understand, sign and comply with this programme. Failure to comply could result in an order being cancelled or goods being rejected. The programme applies equally to production and sourcing and supports our ability to meet the requirements of the Modern Slavery Act.
Supplier Engagement Terms of Business
This year Reiss amended its Standard Supplier Engagement Terms of Business to include additional obligations on suppliers to comply with the Modern Slavery Act and assess the risks of this in their own operations and supply chains. All suppliers were also required to declare all factories and subcontractor units to support efforts of greater transparency, compliance and capacity building in our supply chain. We use this information to structure our audit process as detailed in the Evaluation section below.
Supplier Code of Conduct
Our Supplier Code of Conduct builds on the Ethical Trading Initiative and International Labour Organisation principles, standards and guidelines. We refresh our code every two years. The last update was completed in February 2017 to include additional language on child labour, human trafficking, slavery and anti-corruption, thus ensuring alignment with the intent of the Modern Slavery Act and align with best practice and stakeholder expectations.
Our Code requires that suppliers and factories grant access to both Reiss and third party auditors to perform unannounced audits that check compliance with all core labour rights. It is the responsibility of Reiss suppliers and other business partners to inform their subcontractors about the Reiss Code of Conduct. To date, 100% of our active suppliers have received our code of conduct.
Evaluating Supplier Risk and Compliance
In 2016, Reiss manufactured products in 15 different territories including Asia, Europe, and Latin America. All of these countries face their own geopolitical, cultural and legal differences when implementing our Supplier Code of Conduct. It is partly for these reasons that the Reiss team also evaluate and monitor compliance using self-assessments and third party audits.
Reiss asks suppliers to complete a self-assessment form for each factory and 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.
As part of completing and returning this documentation, suppliers are also asked to submit a copy of their last social compliance audit. This process enables us to identify and approve any factories and sub-contractors before an order is placed, hence contributing to our overall decision making on further compliance assessments and sourcing adjustments.
In 2016, Reiss conducted a risk assessment of all suppliers and factories to evaluate which should be prioritised for audit. The prioritisation process work included country risk insight from public sources such as the World Bank, United Nations and the Global Slavery Index. This inherent country risk insight was combined with knowledge of our supply chain including product category, annual spend and trends, units and level of influence. Our Supplier Code of Conduct and due diligence programme have been designed to help mitigate these risks in partnership with our suppliers.
Our new suppliers and factories / sites are all subject to due diligence checks and, based on higher geographical risks, an ethical audit will be conducted on behalf of Reiss. Such third party audits are also regularly conducted for existing suppliers and factories/sites. 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. During 2016 / 17, we conducted ethical audits (semi-announced) in Europe and Asia, covering the majority of our purchasing volumes for the year. These confirmed that no issues under the headings related to forced labour were present.
Further steps to prevent modern slavery in our supply chain
Reiss is committed to expand its ethical compliance and due-diligence programme. Our goal is to increase our visibility in the supply chains where our products are made and strengthen our relations with suppliers to foster a culture of collaboration and transparency.
To this end, we are now rolling-out a new on-boarding process, evaluating all new suppliers before placing an order, but also completing the auditing process of our current factories globally by the end of 2017. After the audit, we are accompanying and supporting factories in ensuring Corrective Action Plans are followed and completed.
Finally, Reiss has initiated the process to become a member of the Ethical Trade Initiative and join like-minded brands in implementing international positive and ethical sourcing practices.
This statement was approved by the Board of REISS Limited.
Christos Angelides, CEO