MODERN SLAVERY & CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS STATEMENT

UK Modern Slavery Act 2015 and California Transparency in Supply Chains Act 2010 statement 2018.


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 3rd February 2018 to prevent modern slavery and human trafficking in its business and supply chains.

 

About Reiss

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 product developed at its headquarters in central London, employing 1551 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 155 store and concession locations 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 and in-house.

Our Commitment

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.

Governance Framework

The Reiss Ethical Compliance and Due-Diligence programme (Governance Framework) is an integrated business practice and a vital foundation for all supplier partnerships and applied to Reiss’ own business operations.
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, these documents collect key information on labour practices, working environments, health and safety and general ethical trade awareness. Country region, product category and partnership type are also considered and combined with an existing factory audit, verifies the data provided.
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 this year is expanding its efforts to include second tier suppliers such as sub-contracted processes used for embroidery, printing and fabric mills sourced in-house.
The framework elevates Reiss’ efforts to better detail its sourcing landscape and ability to align itself to the Modern Slavery Act.

Supplier Self-Assessment

Completed annually, suppliers are required to complete a self-assessment form for each factory location that produces Reiss product. 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 is able to 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.
This year, Reiss 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.

Risk Assessment

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. Part of Reiss’ risk prioritisation this year is to expand its supply chain mapping into its second-tier suppliers and fabric mills sourced in-house. Reiss applies the same approach when assessing risks in its own operations, such as collecting key information about labour practices of its contracted partners.  

Supplier Audits

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 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. During 2017, Reiss continued its independent audit programme covering 50% of our purchasing volumes for the year with audits conducted in China, Turkey and Ukraine confirming that no issues under the headings related to forced labour were present. Reiss supported all factories in ensuring Corrective Action Plans were monitored and completed with appropriate evidence recorded. Reiss audits are conducted by ELEVATE 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.

Sourcing Landscape - Supplier Risk and Compliance

In 2017, 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. Reiss continues to explore new sourcing opportunities and in late 2017 began sourcing in Mauritius. Prior to placing any orders and as an integrated business practice and detailed above, Reiss followed its Ethical Compliance and Due-Diligence programme to adeptly identify challenges and sourcing risks. As with any sourcing region, Mauritius presented challenges which Reiss has identified and monitors collaboratively through its supplier partnership and involvement in the ETI Mauritius working group. The ETI working group provides Reiss expert advice and supports and the platform to discuss challenges and best practices with fellow members. All sourcing countries face their own geopolitical, cultural and legal differences and is partly reason that Reiss continues to evaluate and monitor supplier compliance through supplier self-assessment forms, third party audits and factory visits.

Business Updates

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.

Ethical Trading Initiative Membership

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. 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. Reiss is due to become a full member in early 2019.

Further Steps

Building on the work conducted over the last 12 months, this year Reiss will focus on mapping its second-tier suppliers, such as sub-contracted units used for embroidery and printing processes and also fabric mills sourced in-house. Reiss will continue to build transparent supplier relationships, which will support its mapping efforts with suppliers who source raw materials on our behalf.

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.  

 Reiss continues to risk assess its supply base and extend its audit programme, encompassing its biggest purchasing volumes for 2018.

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: 24/05/2018