BTA Modern Slavery A4 Presentation 3.Indd
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SUSTAINABILITY AT BROWN THOMAS AND ARNOTTS BROWN THOMAS ARNOTTS MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR ENDING 31 JANUARY 2020 1.0 INTRODUCTION FROM BROWN THOMAS ARNOTTS MANAGING DIRECTOR As part of Selfridges Group, a family-owned, values-led business, modern slavery in all its forms goes against everything we stand for. We do not tolerate modern slavery in our business and supply chains. We expect our supply chain (whether direct suppliers or those that directly or indirectly supply our direct suppliers) to share the same values. As such we have made zero tolerance on modern slavery a requirement of our Ethical Trading Regulations which forms part of the Terms and Conditions of doing business with us. We understand that this is our legal obligation CONTENTS for our business under Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013. The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within our organisation and with our suppliers of goods and services. 2 1.0 INTRODUCTION FROM BROWN THOMAS This is our first Modern Slavery Statement which sets out the steps we are taking to help prevent ARNOTTS MANAGING DIRECTOR modern slavery from occurring in our businesses and supply chains within Brown Thomas Arnotts. It outlines the steps we have taken over the last year (ending 31 Jan 2020) and plans for this year (ending 31 Jan 2021). 3 2.0 WHO WE ARE We have an approach embedded across our business to help tackle modern slavery. This sits within our sustainability and human resources programmes. Our approach focuses on ensuring 4 3.0 PRINCIPLES AND APPROACH OVERVIEW appropriate governance mechanisms, policies and procedures are in place, setting clear expectations for team members and suppliers, and engaging key groups on the issue. We 6 4.0 DUE DILIGENCE PROCESSES know collaboration is key to tackling modern slavery and enabling root cause solutions. We are committed to working collectively across our businesses, with our brand partners and suppliers, as part of the retail industry and wider business community, and with experts. 7 5.0 MONITORING AND REPORTING As a multi-brand retailer, we know our supply chains, which we have limited direct control over and 8 6.0 TRAINING AND COMMUNICATIONS visibility of, are our area of greatest risk. This is why collaboration with our suppliers is so crucial, to help tackle modern slavery together. We remain committed to helping ensure everyone who works for or with us as an employee, on our sites or in our supply chain is respected, protected 8 7.0 COLLABORATION and is able to access support should they need it. We know there is more we can do and we will continue to develop our approach to help tackle modern slavery and protect everyone who works with us. MD Brown Thomas Arnotts, 31/08/2020 SUSTAINABILITY AT BROWN THOMAS AND ARNOTTS 2.0 WHO WE ARE Brown Thomas & Co Limited T/A Brown Thomas and Arnotts Limited T/A Arnotts are part of Selfridges Group of retailers. SHEL Holdings Europe Limited (UK registered) is the ultimate shareholder of the companies which are the shareholders of Brown Thomas & Co Limited T/A Brown Thomas and Arnotts Limited T/A Arnotts. KEY DEVELOPMENTS in Financial Year 2019/2020 We updated our Ethical Trading Regulations (ETR) to be more explicit on our modern slavery and wider sustainability requirements for suppliers. We formalised a Responsible Sourcing system for engaging, capacity building and risk assessing our suppliers on modern slavery and wider sustainability issues. We set targets and KPIs to implement and monitor this. The highlights of what we did are: • We assessed our processes for tackling modern slavery in our •Weengagedandcommencedriskassessmentsofourtop10brands recruitment of direct employees and procurement of goods and andconcessionsbysalesvaluetothebusiness(over180organisations). services. •WeconductedtrainingbywebinarandonetoonewithGNFR,brands •Wemappedalloursuppliersofproductsandservicesandidentified and concessions and provided a supplier pack to support capacity those with the highest potential risk of modern slavery. building. • We engaged and risk assessed all GNFR product and service •Wetrainedourbuyingteamsandprovideda“BetterBuying”Guideand suppliers. packforeachofourproductcategories–fashion,beauty,home,food, restaurant. 3 Modern Slavery Statement, 31/08/2020 SUSTAINABILITY AT BROWN THOMAS AND ARNOTTS 3.0 PRINCIPLES AND APPROACH – OVERVIEW Wetakeariskbasedapproachtotacklingmodernslavery.Itstartswithmappingthepeopleinourbusinessandsupplychain.Thiscovers: • Team members directly employed by us • Team members working for a supplier but are based on our sites • People who work for a supplier elsewhere MAPPING THE PEOPLE IN OUR BUSINESS AND SUPPLY CHAINS OUR BUSINESS OUR PEOPLE WHO WORK ON OUR SITES OUR SUPPLY CHAIN OUR CUSTOMERS 7 Stores Directly employed by us: types of role and seasonality. Direct Suppliers: Over8millioncustomers from around the world •Arnotts,HenrySt,Dublin 1300–1900teammembers Forexample,roleswitha -Over35GoodsNotforResale: •BrownThomas,GraftonSt,Dublin potential higher risk of modern Suppliersthatprovidegoodsor visitedourstoresin2019. •BrownThomas,WilliamSt,Galway Work for a supplier: 3100– slavery can include seasonal services that we use within our •BrownThomas,O’ConnellSt, 4000peopleworkingwithus recruitstodistributioncentres, businessanddonotsell -6privatelabelsuppliers Limerick viaagencies,concessions, contractorsincleaning, •BrownThomas,StPatricksSt,Cork servicesuppliers,contractors security,shopfit/construction/ Indirect suppliers: •BT2,DundrumTownCentre and consultants facilities supports and restaurants. We work with our -Over1,300ownboughtsuppliers: •BT2,BlanchardstownShopping Duetotheseasonaland suppliers of these roles and Brandpartnerswhowebuy Centre flexiblenatureoftheretail any agencies to support them product from to sell in our stores or business,thenumberof mitigate these risks. Regarding on our digital platform. 1 Distribution Centre and people we employ does employmentagencies, -Over350concessionsand Warehouse operatedbyDHL change.Ouraveragenumber weworkbothdirectlyand consignmentbrands:Brand ofdirectemployeesis1300 indirectly with 6 recruitment partners who sell their products in Office, Anne’s Lane, Dublin andpeaksduringNov–Dec agencies to assist in the our stores or on our digital platform. to1900.Wetakearisk hiringofourteammembers Online Digital Platform basedapproachtoidentifying and those of our concession modernslaverybasedonthe partners. 4 Modern Slavery Statement, 31/08/2020 Ourhumanresourceprogrammeincorporatesthemeasureswetaketomitigatemodernslaveryrisk ELEMENTS IN OUR RESPONSIBLE toemployees.Oursustainabilityprogrammeincorporatesmeasurestotacklemodernslaveryrisk SOURCING APPROACH associatedwithoursuppliersandsupplychain.Theapproachesfortheseareoutlinedbelow. Sustainability POLICY HR POLICIES AND PROCESSES GOVERNANCE -Responsiblesourcingisakey element OurCodesofConduct,HRpoliciesand Ourorganisationalandgovernancestructureembedssustainabilityfromthetop GOODS & Services PROCURED processessetoutourexpectationsof,andour andinallkeybusinessfunctions.Wehaveadedicatedsustainabilityteamofthree -Privatelabel,own-boughtand responsibilitiestowards,ourteammembers. toleadourprogrammewithoversightfromourSustainabilityExecutiveGroup. concessions Theseincludespecifyingrecruitmentfeesshould OurSustainabilityExecutiveGroupincludesallexecutivefunctions,ischaired -Servicesandnon-saleGNFR neverbeincurredbyanindividualandsalary products paymentsmustnotgointobankaccountsin byourM.D.andmeetsmonthly.AcrossSelfridgesGroupandalloursister retailers,therearesimilarsustainabilityteams.Theseteamsworktogetherand someoneelse’snamemorethanonceand Organisation without written authorisation from the team have a group wide call monthly to track progress and share learnings. -ManagingDirector member.Thesepoliciesarehighlightedtoall Weworkcloselywithourbrands,concessionsandsupplypartnerson -PeopleDirector newteammembersjoiningourbusiness,and managingsustainabilityrisksandunlockingopportunities.Weengagewith -BuyingDirectors areavailabletoviewatanytimeviathe our suppliers and require them to nominate a senior manager to undertake -HeadofSustainability& ResponsibleSourcingCoordinator BrownThomasArnottsinternalcommunications responsibilityforcompliancewithourEthicalTradingRegulations.Thisisthe platformBASE. daytodaycontactforourResponsibleSourcingteamforcommunicationsin ETHICAL TRADING Regulation bothdirectionsasrequired. -ResponsibleSourcingCodeof Conduct SUSTAINABILITY DUE DILIGENCE -Mappingandriskassessmentof existingsupplierstoKPIs Wearededicatedtooursustainability communities.Todeliverouraim,our haveaResponsibleSourcingsystemto -SustainabilitySupplier commitments,fromworking,buying sustainabilityprogrammehasthree support us manage the environmental Questionnaire andsellingresponsiblytosupporting pillarsofaction–Workresponsibly, andethicalimpactsacrossourbusiness - New supplier assessment ourcommunities.Oursustainability Buy&SellResponsiblyandSupport andsupplychain.Responsiblesourcing procedure visionistoachievePositiveChange Communitythroughcharityand ofproducts,packagingandservices -Monitor andsupportourcustomerstoBuy volunteering.OurSustainabilityPolicy, isakeyelementofoursustainability -Database Better.WeseethisasDoingtheRight annualTargetsandprogrammeto policy,targetsandprogramme. Thing,oneofourcorebusinessvalues. drive continuous improvement are Thisincorporatesmodernslavery TRAINING We’reatanearlystage,butcommitted