Corporate Social Responsibility
Modern Slavery Act Statement
1.1 This statement is produced in accordance with section 54 of the Modern Slavery Act 2015.
1.2 L.K.Bennett is a British brand with a global reach. We provide accessible luxury shoes, handbags and apparel to women who seek a wardrobe for every occasion. Our commitment to quality and integrity flows through not just our products, but the way we do business.
1.3 We as an organisation understand the growing threat of modern slavery and take seriously our responsibility to mitigate slavery and trafficking in the retail sector. We are continuously reviewing and improving our practices to ensure that we are a socially and ethically responsible business.
2. Who are we?
2.1 L.K.Bennett Group Limited is a private, limited company with a UK ownership. It is the ultimate parent company of our trading entity, L.K.Bennett Limited, which since its inception in 1990, now turns over around £100 million per year. We have small subsidiary companies in Europe and the USA, and through retail, wholesale, franchising and online channels, we now reach customers in all corners of the world.
2.2 L.K.Bennett is a design-driven label, and we source quality products from suppliers in Portugal, Italy, Bulgaria, Romania, Albania, Spain, India, Turkey, Vietnam and China. Our suppliers are carefully selected not only for the quality of their output, but for the standard of working practices that they provide and their own reflection of our brand values.
3. Our Modern Slavery Act Policy
3.1 L.K.Bennett has adopted a Modern Slavery Act Policy that seeks to ensure that not only our business, but business partners and our supply chain operate with a zero tolerance approach to modern slavery.
3.2 We require all to adhere our final made goods factories (hereafter "factories") to our fully-comprehensive (contractual) Supplier Manual which incorporates all of our ethical business practice requirements.
3.3 L.K.Bennett's ethical standards are based on the Ethical Trading Initiative (ETI) base code, which is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognized code of labour practice. ETI exists to improve working conditions in global supply chains and its key principles include: freely-chosen employment, prevention of child labour, payment of a living wage and prevention of harsh or inhumane treatment in the workplace. All of our factories are required to sign a declaration confirming their level of compliance with the ETI base code, and to the local laws in their country of manufacturing.
4. Due Diligence Processes
4.1 L.K.Bennett requires that all factories within our supply chain are audited for ethical standards. Not ones for simply ticking boxes, we know that any genuine and thorough assessment will inevitably reveal incidents of non-compliance, and when these are identified, we work hard to fix them. Our production team visit factories on a regular basis to build strong and trusting working partnerships, and we maintain an ongoing dialogue and process to remedy any breaches.
4.2 During the latter part of 2016, L.K.Bennett assigned dedicated resource to gather information about the compliance of our factories. We asked these factories to share with us any third party audit report that was conducted in their facility in the past two years, in which their compliance with the ETI Code of Conduct and local laws were evaluated. We are currently in the process of collating this data, and once this process is complete, we will re-evaluate the compliance status of our factories. The objective is to ensure that all of our factories are fully compliant with the ETI Code of Conduct and their own local laws, and this will always be an ongoing process of education and assessment. We are investing time and resource to support our factories through this process and see that they take all necessary steps to achieve and maintain a clean bill of health.
4.3 During our recent investigations, various non-compliance issues were identified and resolved. However, there were two recurring issues which were harder to solve. These were:
4.3.1 Breaches of Chinese working hours regulations; and
4.3.2 Non-payment of Chinese employers' social security payments to workers' accounts.
On investigation, we learned that these practices were freely chosen by the workers themselves who (a) voluntarily chose to work longer hours than prescribed by regulation; and (b) chose themselves not to pay into their own social security plans, thus vitiating the employer's need to match their installments. To alleviate the first issue, L.K.Bennett reassessed manufacturing lead time in its critical path to avoid situations where excessive overtime was employed in producing its orders. It is our aim as a business to ensure that all workers in our nominated factories are protected from pressure and duress.
4.4 Contractually, failure of our factories to comply with audit standards enables us to terminate our relationship with them, but whilst we reserve the right to report offending organisations, our preferred approach is to work with them to become responsible employers themselves. We recognize that all our factories represent a valuable source of employment for often vulnerable individuals and it is to everyone's benefit to improve the standards of under-performing facilities rather than shut them down altogether.
4.5 Within our own business, we have identified areas of potential risk as regards modern slavery and seek to relay a continuous message across our workforce to be aware of this issue in everything that we do. We have implemented modern slavery reporting procedures so that any suspected cases can be referred appropriately.
5.1 We provide internal training to key individuals on the requirements of the Modern Slavery Act and the adequacy of this programme will continue to be reviewed over the coming year.
5.2 We have created a new role of Corporate Social Responsibility and Quality Controller in order to manage our factory audit programme and monitor supplier compliance.
5.3 We see our commitment to the Modern Slavery Act as an ongoing and evolving process and will continue to assess the efficacy of our current procedures.
DARREN TOPP, CEO
For and on behalf of the board of L.K.Bennett Group Limited on 25 January 2017.