Modern Slavery Act
In 2015 the Modern Slavery Act came into force requiring companies to take steps to address the risk of modern slavery within their own operations and supply chains. In accordance with Part Six, Section 54 of the Act, this statement outlines the measures Coast has adopted to comply with our responsibilities.
As is fundamental to our overall approach to ethical trading, Coast recognises business can positively influence human rights. In relation to the Act, we have considered how we can take the most effective action to meet our duties and have decided to focus our efforts on education and transparency. We commit to use our leverage, where it may be needed, to prevent against human rights infringements.
Founded in 1996, Coast is a UK based, multi-channel, occasionwear focused womenswear fashion brand. The brand is sold in 28 countries worldwide via our own stores, concessions, franchise/wholesale partners and websites. We directly employ 969 people across our own operations in four countries. Our supply base comprises 31 suppliers that use approximately 61 factories in eight countries.
Coast’s code of conduct, adopted over 10 years ago, is based on norms defined by the International Labour Organisation and prohibits forced and bonded labour. It remains the cornerstone of our ethical trading strategy. Building on this, in 2010 we banned Uzbek cotton owing to ongoing reports of forced and child labour in Uzbekistan.
Recently we reviewed the effectiveness of our policies in relation to the Modern Slavery Act. In recognition of the fact that foreign migrant and agency workers, in particular, may be vulnerable to abuse, we decided it was judicious to strengthen our efforts and adopted a specific policy on the prevention of forced labour and human trafficking. The policy was developed with the expertise of Verité, a human rights NGO. To illustrate the more descriptive and explicit standards of the new policy, applied to our business and required of our suppliers, some examples are given:
- Terms and conditions of employment must be clearly communicated to workers during the early stages of recruitment (i.e. before contracts are signed)
- Employers must ensure workers have valid documentation before commencing work in a foreign country and these are renewed in a timely manner
- Recruitment agencies/labour brokers, if used, must only charge a reasonable recruitment fee, which only the employer should pay
- Workers must not be required to be present before the start of their shifts nor attend meetings or perform tasks outside of working hours
We should add that, even before the new policy, it is likely our audit programme would have identified if these or similar practices were taking place. There are several advantages to the policy, which can help preclude these practices from taking place in the first place (i.e. before an audit), generate awareness of unfair and unreasonable employment practices with direct partners and potentially help normalise and spread respect for human rights within the wider private sector.
Due diligence and risk management
Coast’s audit programme is the chief means of carrying out due diligence on our suppliers. Within the scope of the audit, contract terms and personnel files are reviewed and the wider recruitment and termination procedure examined. In doing so, this can help determine if there are practices that could constitute or lead to forced labour. We use a range of different tools, including internal audits in China performed by our ethical trading team, third-party assessments commissioned from a limited number of labour specialists and independent audits that are shared with peers to prevent unnecessary and costly duplication of effort. Our buying teams may also visit factory facilities, which provide further observation and scrutiny of manufacturing sites.
We continue to map our first tier supply chain, which forms part of our ongoing ethical trading efforts, and, in doing so, provides us with crucial visibility of where our products are made. All suppliers are required to inform us in advance if they wish to change their production facility.
Within the business we have a whistleblowing policy which is there to encourage the disclosure of unlawful or otherwise business critical information that might not otherwise be disclosed, including the exposure of risk of modern slavery and human trafficking.
Training and capacity building
In preparation for the Act, we attended industry training courses and seminars on how modern slavery can occur and what businesses can do to avoid these abuses.
We regularly run ethical trading courses, including the subject of forced labour, for our commercial teams, and, in particular, our buying teams. We plan to repeat and enhance the training going forward.