Modern Slavery Act Transparency Statement for Financial Year 2016/17

Modern Slavery Act Transparency Statement for Financial Year 2016/17

This transparency statement sets out the structure of Phase Eight's supply chain and some of the steps we have taken to ensure that modern slavery and human trafficking are not present in our business operations and supply chains. It covers the financial year ending 1 April 2017 and has been published in accordance with the Modern Slavery Act 2015 (the "Act").



Our Business Organisation and Supply Chain

Phase Eight is a UK-based multi-channel brand. We operate in 26 territories through concessions, solus sites, wholesale, and web. We employ 2116 people, with 1640 employees in the UK and ROI across our 110 stores and 281 concessions, 193 in Head Office and 283 in our international stores across the globe.

Phase Eight works with 100 suppliers with factories across Europe and Asia. Our supply base comprises 45 factories through 45 suppliers, 57 factories through agents, and an additional 10 factories used on the basis of sub-contracting. Our top 5 sourcing countries are China, Romania, Turkey, India and Greece.

Phase Eight is a UK-based multi-channel brand that works with suppliers with factories across Europe and Asia. Phase Eight does not operate the factories that manufacture our product and so we ask all of our suppliers to commit to the to the Phase Eight Code of Conduct ("Code of Conduct") prior to placing orders with them.



Policies and Contractual Controls

The Code of Conduct is based on Ethical Trading Initiative (“ETI”) standards and sets out the minimum requirements we expect of our suppliers in relation to working conditions, pay and employment rights and the prevention of slavery and human trafficking in our supply chains.

The Code of Conduct demands that suppliers apply the same standards to any home workers and third parties used in the production of our garments as they would their own employees. Phase Eight asks its suppliers to work in a transparent way and provide full details of its sub-contractors for monitoring purposes.

We reviewed our Code of Conduct in 2016 to ensure it is in line with the recommendations of the ETI and we are committed to doing so on an annual basis.



SEDEX Membership

In 2016 Phase Eight became members of the Supplier Ethical Data Exchange (“SEDEX”), a not for profit organisation dedicated to driving improvements in responsible and ethical business practices in global supply chains. SEDEX allows suppliers to share the same data with multiple customers, thereby reducing the need for multiple audits and allowing our suppliers to focus on making improvements.

The SEDEX platform also enables members to report on trends across the supply chain and to liaise with one another where indications of forced or bonded labour arise so that these can be followed up.



Factory Audits

The Code of Conduct also sets out our requirements for factory audits from all factories in our supply chain. We request that all new suppliers provide an audit based on a public methodology from a recognised independent organisation, for example the SEDEX Members Ethical Trade Audit (SMETA). Where a supplier is unable to provide such an audit we ask that suppliers fill in our own audit form instead which requires, among other things, details of factory sites, employees, sub-contractors and homeworkers, training and critical safety procedures, staff working hours and wages, and environmental procedures.

In addition to the requirement for all factories to provide audits we will often visit the factories themselves when we visit our suppliers.

We operate a whistleblowing policy aimed principally at our employees but this is also available to our supply chain. All reports will be fully investigated.



Supply Chain Mapping

Phase Eight acknowledges that its supply chain is constantly moving and that suppliers may be added to its chain and others removed in line with Phase Eight’s growth. In 2016 we disengaged from our supplier database all suppliers we no longer work with. We also worked with our first-tier suppliers to ensure we have full clarity of the location of the factories in our first-tier supplier base.

In 2017 we will commence mapping the locations of our second-tier suppliers in conjunction with information provided by our first-tier supply base. We will continue to update our supply chain map to reflect changes to our supplier base.



Training

In 2017 we recruited a Corporate Social Responsibility and Sustainability Executive to work with all brands within the TFG Brands (London) group. Their mandate includes a risk analysis of our sourcing countries and the implementation of additional steps to strengthen supply chain auditing and verification.

Training on ethical buying, social compliance and factory engagement programmes is planned for the buying, design and senior management teams within Phase Eights’ Head Office.

Although we have worked with some of our suppliers for many years we are prepared to move our business elsewhere where problems are raised which cannot be fixed within a reasonable timeframe.

This statement has been approved by the Board of Phase Eight (Fashion & Designs) Limited..