Modern Slavery Statement 2022

Thoughts from our Chair, Sharon Flood

Ethical trading, workers’ rights and responsible sourcing are core Seraphine priorities. Our customers are raising the future generation and, as we see it, we have an obligation to play our part in making the world a better place for their children.

With our first Modern Slavery Statement, we take time to reflect on our achievements so far but also acknowledge that we are at the beginning of what will be an ongoing journey of improvement. This journey is set against an ever-evolving, complex global landscape, and this year above others, has been particularly challenging for our workers and suppliers - from Covid-19, to supply chain disruptions and the terrible war in the Ukraine.

In spite of this, Seraphine remains steadfast in its commitment to combat modern slavery and champion human rights, within our own operations, our supply chain and in the communities in which we operate.

Thoughts from Our CEO, David Williams

I am proud of the progress Seraphine has made since our IPO in July 2021 but recognise that recent and continuing global events have a significant impact on workers within our own operations and those of our suppliers. Covid-19 in particular is a palpable global humanitarian crisis and whilst we seem to be over the worst of it, the impacts are still ongoing around the world.

I am very proud that we have strong core values and working practices which have taken root, organically over time. This gives us a robust base from which to further define and develop our Modern Slavery strategy as a part of our over-arching Environmental, Social and Governance strategies.  We know that there is a lot to be done but remain positive and committed to the challenge.

Our People:

We are committed to providing safe working conditions, free from harassment or discrimination, ensuring that all our workers are treated fairly, and that their fundamental human rights are protected and respected.

Recruitment: We have structured our recruitment process to ensure that we engage with potential candidates directly or via agencies that we are confident have appropriate and robust anti-modern slavery procedures. 

We have refined our recruitment processes this year by implementing an Applicant Tracking System to make sure we provide fair and equal opportunities to all potential candidates.  In addition, we have made significant improvements to our interview, selection, referencing, right to work and onboarding processes, ensuring that we maintain high recruitment standards.  

Internal Policies and Procedures: We implement various processes and policies to ensure that our workers’ rights are protected including:

• offering a secure and effective grievance process;
• treating workers with equity and inclusivity, as outlined in our Equal Opportunities Policy;
• constantly monitoring and looking for ways to improve on our Diversity and Inclusion processes, by way of our Diversity and Inclusion Committee;
• providing a secure Whistleblowing hotline and policy to ensure that employees have an appropriate forum through which to raise any concerns regarding our practices, including in relation to workers’ rights;
• maintaining and regularly reviewing our Health and Safety procedures to ensure that our workers are provided a safe and hygienic environment in which to operate; and
• monitoring legislative changes to ensure our processes, contracts and policies are up to date and legally compliant.

Our Supply Chain:

Seraphine is committed to respecting, protecting and championing the rights of all workers throughout our supply chain.

Seraphine seeks to build close, lasting and fair relationships with our suppliers, some of whom we’ve worked with for nearly 20 years. We source our manufacturers first hand, enabling us to ensure that they share our values and commitments; when issues do arise, we are well placed to work closely with them to improve their procedures as necessary.  

Responsible Sourcing Code of Practice: In line with the Ethical Trading Initiative base code ETI Base Code | Ethical Trading Initiative (ethicaltrade.org)and the United Nations Universal Declaration of Human Rights, Seraphine’s Responsible Sourcing Code of Practice (“RSCP”) establishes clear minimum requirements that all our suppliers and sub-suppliers are expected to adhere to in respect of their workforce, including the following:

• Employment must freely chosen;
• Freedom of association and the right to collective bargaining must be respected;
• Working conditions must be safe and hygienic;
• Child labour must not be used;
• Living wages should be paid;
• Working hours must not be excessive;
• Strictly no discrimination*;
• Regular employment should be provided; and
• Harsh or inhumane treatment is strictly forbidden.

Suppliers are also required to complete self-assessment questionnaires and share copies of their own policies and procedures regarding modern slavery prior to onboarding.

Auditing: We monitor compliance with our RSCP with a robust audit programme, which includes ensuring that all first tier (Tier 1) factories are annually audited by reputable third-party audit bodies such as SMETA, Amfori BSCI, WRAP and SA8000:2104.

We also require suppliers to sign up to the Supplier Ethical Data Exchange (“SEDEX”). Suppliers upload their audits to the platform and are provided with a score and key areas for improvement. This is a valuable tool as it allows us to monitor our suppliers and discuss areas for improvement. SEDEX also provides a global view of ethical practices in manufacturing around the world, allowing us to map out specific risks by region and industry. 

Supply Chain Mapping:

Seraphine has embarked on a supply chain mapping exercise, as we acknowledge that greater transparency will help us identify core risks within our supply chain or the regions in which we operate. This year we have completed Tier 1 and 2 mapping and are now focused on extending the exercise into Tiers 3, 4 and 5 (with a particular focus on China).

 

Tier 0	Complete
Tier 1	Complete
Tier 2	Complete
Tier 3	69% complete
Tier 4	56% complete
Tier 5	12% complete

Cotton

We know that certain regions involved in the production of cotton are at greater risk of child labour and forced labour. In particular, we are aware of the concerning reports of bonded or forced labour of Uyghur Muslims and other minority groups in the Xinjiang region of China.

Seraphine is taking steps to diversify our cotton sourcing and to reduce our reliance on cotton generally (40% of Seraphine products currently have cotton content). We have also introduced a strict Cotton Sourcing Policy, which will be kept under regular review, to ensure that we do not source cotton from the following regions:

• Benin;
• Burkino Faso;
• Kazakhstan, Uzbekistan;
• Tajikistan;
• Turkmenistan; or
• Xinjiang region, China.

We have also joined the Better Cotton Initiative (BCI), with a view to increasing our use of sustainable sources of cotton.

Looking Ahead

Over the next financial year we intend to focus on the following:

1. ensuring the entire company, including the Executive Committee, have received training on modern slavery and it’s prevalence in the UK and around the world;
2. educating and training suppliers on our modern slavery requirements, as well as their individual responsibility to combat it; 
3. achieving greater transparency within our supply chain by continuing to map our suppliers;
4. conducting regular reviews within the Modern Slavery Working Group and Executive Committee on the effectiveness of the steps taken to combat modern slavery and human trafficking within our own operations and our supply chain; and
5. considering potential key partners to further our mission to combat slavery and champion human rights in our production chain.

Seraphine’s Modern Slavery Statement was prepared by our Modern Slavery Working Group and approved by the Board of Directors on 21^st September 2022.

David N Williams

CEO

 

 

*discrimination is defined as: treating someone unfairly on the basis of their: age, gender reassignment, their marital status; if they are pregnant or on maternity leave; disability; race (including colour, nationality, ethnic or national origin); religion or belief; sex; or sexual orientation