Modern Slavery Act
KAREN MILLEN MODERN SLAVERY STATEMENT 2016/17
This statement has been published in accordance with Section 54, Part 6 of the Modern Slavery Act 2015 (Act). It provides an overview of our policies and sets out the steps taken by Karen Millen Fashions Limited (Karen Millen) to prevent modern slavery and human trafficking in its business and supply chains during the financial year ending 25 February 2017.
Karen Millen conducts its business with open transparency and integrity at all times, treating all people with dignity and respect and complying with applicable laws and regulations. Karen Millen is committed to protecting and promoting human rights globally, including, but not limited to zero tolerance of child labour, forced labour or other forms of coercion, fraud, deception, abuse of power or other means to achieve control over another person for the purpose of exploitation.
We recognise our responsibility to take a robust approach to slavery and human trafficking and acknowledge that our business must be aware of the risks and have appropriate procedures and processes in place to address concerns through the appropriate channels across the business.
Our business and supply chains
Karen Millen is a global retailer of own brand womenswear and has built a reputation for its quality, design and craftsmanship. The business operates online and in stores over 65 countries across six continents. We operate through solus stores, franchise partners, and in concessions in department stores.
Our supply chain involves a diverse number of product types and processes. We source from approximately 50 product suppliers and 200 raw material suppliers around the world. The average length of relationship with our product suppliers is nine years, some have been working with Karen Millen for over 20 years.
We have the following policies (together the Policies) in place to ensure that we are conducting business in an ethical and transparent manner:
- Supplier Code of Conduct. This outlines the values and standards we expect of our suppliers, representatives and the other people we deal with to uphold. This policy is based on the Ethical Trade Initiative Base Code and confirms that we will not tolerate or condone abuse of human rights within any part of our business or supply chains and will take seriously any allegations that human rights are not properly respected.
- Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can report concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. All reports will be fully investigated and appropriate remedial action taken.
- Cotton Sourcing Declaration. This confirms our ban on cotton sourced from Uzbekistan owing to ongoing concerns about forced labour, including forced child labour.
- REACH policy. This reflects our compliance with EU regulations which aim to protect human health and the environment from dangerous substances.
- Animal Testing and Animal Welfare Policy. This confirms our ban on the use of real fur and animal testing on cosmetic or hygiene products.
Suppliers are required to sign up to the Policies before we commit to working with them and they are required to abide by the terms of each for the duration of our working relationship.
We periodically update the Policies to ensure their relevance and have done so recently with the Supplier Code of Conduct to ensure it specifically refers to our intolerance of forced labour and our requirement for suppliers to implement appropriate controls to prevent modern slavery and notify Karen Millen immediately if they become aware of any modern slavery within their supply chains.
Suppliers who breach these obligations will face appropriate actions which could include termination of their relationships.
Due diligence and audits of suppliers and supply chains
We audit our suppliers to ensure that they are complying with the Policies. The audits include, but are not limited to working conditions, health and safety, hours worked, whether wages are above the legal minimum, ability to leave the premises after work shifts and whether any ID documents are held by the employers.
In cases where our suppliers have not met the expectations and standards laid out in our Policies, we have worked with them, offering support to help them improve. We would terminate commercial relationships with these suppliers if no improvements are made over an agreed timeframe or if there was no commitment to make them.
We make employees aware of our Policies on their induction into Karen Millen and the Policies are available as a reference for all online. We are committed to regularly reviewing the Policies and alerting all employees to changes when there are any.
We will be conducting training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
Chief Executive Officer, Karen Millen