Modern Slavery Act
Slavery, forced labour and human trafficking affect all regions and industries, with the International Labour Organisation estimating that 21 million people are victims of forced labour worldwide.
Hunter Boot Limited and its relevant group companies (“Hunter”) is committed to respecting and protecting the human rights of all workers in our supply chain and operations. We do not tolerate any form of modern slavery or human trafficking in our business or supply chain.
This statement has been published in accordance with the Modern Slavery Act 2015. It explains the steps we have taken to prevent modern slavery in our business and supply chain for the year ending 31st December 2016.
Founded in 1856, Hunter is a progressive British heritage brand renowned for its iconic Original Boot. We hold two Royal Warrants of Appointment to HM The Queen and HRH The Duke of Edinburgh. We design a wide range of products including footwear, outerwear, bags, and accessories.
We are a privately-owned business with two main shareholders. Private equity firm, Searchlight Capital Partners, has held a majority share since 2012. Pentland Group, the global sports and fashion brand-management company, has been a shareholder since 2007.
Hunter is headquartered in the UK with offices in London, Edinburgh, New York, Shenzhen, Tokyo, and Dusseldorf. We own and operate two stores in the UK, two in Japan, and one in the US. We have over 270 employees.
We design our products on a bi-annual basis for the spring/summer and autumn/winter seasons. Our products are developed by our teams in the UK and in China, manufactured at supplier factories globally and shipped to third-party distribution centres in the UK, US, Canada, and Japan. Our business sells products internationally via a network of carefully selected distributors and agents and directly to consumers through our own retail stores and e-commerce websites.
Our supply chain
We have two main categories of suppliers:
- Production suppliers involved in the sourcing and manufacture of our products.
- Logistics and operational suppliers who provide services such as shipping and transport services, warehouses and office cleaning.
Our products are made at 32 factories in China, Vietnam, the UK, Italy, Turkey, India and Indonesia. These are our tier-one production suppliers, companies with whom we have a direct contractual relationship. Approximately 9,000 workers are involved in the manufacture of our products at these factories.
Tier-two suppliers provide the raw materials, components and services used in the manufacture of our products. These include rubber plantations, component suppliers, fabric mills, laundry companies, printers and packaging suppliers. The majority of tier-two suppliers contract directly with tier-one suppliers or via an agent. We only have a direct contractual relationship with a small number of tier-two suppliers.
Our Code of Conduct and key policies
Our Code of Conduct sets out the principles we expect our tier-one suppliers to meet in relation to human rights and safe and fair working conditions. It is based on international standards, including the International Labour Organization conventions. It states our requirement that employment must be freely chosen. Tier-one suppliers must not use forced, bonded, or involuntary prison labour, and workers must not be required to lodge deposits, identity papers, or any other security with their employer and are free to leave their employment after reasonable notice. Our Code of Conduct is available in the local language for all countries where we have tier-one production suppliers.
We have a number of supporting policies to our Code of Conduct. These include our Subcontracting Policy that requires tier-one suppliers to seek Hunter’s approval for any subcontracting processes and to disclose tier-two supplier information on request. Our Transparency in Audit Policy requires factories to share all genuine and complete records with Hunter during ethical trading audits.
Our ethical trading policies including our Code of Conduct, our Subcontracting Policy and Transparency in Audit Policy, are integrated into our legal manufacturing agreements (our supplier contracts), supplier manuals, and our audit scheduling documents. Tier-one suppliers are required to meet our standards set out in our ethical trading policies and to maintain adequate records to demonstrate their compliance.
We also have a number of policies designed to protect and promote the human rights of our own employees. These include our Code of Ethics and policies in areas such as equal opportunities and dignity at work, anti-bullying and harassment, health and safety, parental leave, working time guidelines and whistleblowing.
Human rights, including modern slavery, are integrated into our governance procedures and our ethical trading programme. Our Board and our main shareholders regularly assess environmental, social or governance risks to the business including human rights risks and risks of modern slavery in our supply chain. The Board reviews our progress quarterly including any significant cases of non-compliance with our ethical trading policies and how these are being addressed.
Our Corporate Responsibility Manager is responsible for day-to-day management of ethical trading issues. Ethical trading considerations are integrated into our supplier review process along with issues such as price, quality, and reliability when we evaluate factory performance. Our corporate responsibility, sourcing, quality, and production teams meet monthly to review supplier performance and discuss any ethical trading issues. Any critical issues identified among our suppliers are reported to our Global Operations Director on a fortnightly basis.
Assessment of modern slavery risk
We have undertaken an internal risk assessment in relation to our own operations and in relation to our tier-one suppliers. Based on this assessment, we believe the risk of modern slavery occurring in our own workforce is very low. There is a greater risk of modern slavery occurring in our supply chain. We have assessed this risk looking at factors such as the type of product or service provided and the supplier’s geographical location.
We have identified a number of potential risk factors for modern slavery, including:
- The use of migrant workers, particularly foreign migrant workers who may be more vulnerable to unequal employment terms, deceptive or coercive recruitment practices including trafficking, debt bondage, and restrictions on movement.
- Factories with incomplete or inaccurate record keeping which could be an indication that they are withholding wages or requiring employees to work excessive hours; and
- Poor human resources management practices such as an absence of clear policies and procedures
Due diligence and supplier audits
We seek to select tier-one suppliers who demonstrate a genuine commitment to our ethical standards and we work with tier-one suppliers to improve practices in our supply chain.
Due diligence checks for modern slavery are integrated into our Ethical Trading programme, including contractual requirements and regular audits. Our ethical trading programme is currently focussed on our tier-one production suppliers who represent the majority of our spend and are most closely associated with our brand. We aim to expand this focus to ensure that slavery and human trafficking is not present in our supply chain regardless of potential impact on our brand.
All tier-one production suppliers must meet the base standards in our Code of Conduct before we will work with them. We don’t contract with suppliers who demonstrate critical non-compliances with our Code of Conduct such as use of child labour or modern slavery. We meet with potential new suppliers to explain our ethical trading requirements and we commission an independent third-party audit to confirm compliance with our Code of Conduct before contracts are signed.
All tier-one production suppliers undergo third-party audits at least once a year to confirm the continued compliance with our standards. We work together with suppliers to improve standards where necessary through training and remediation.
Recognising that human rights risks may be higher further down the supply chain, we have mapped our tier-two production supply chain and identified our key tier-two suppliers. These include rubber plantations, factories making components used in our Original Boot, suppliers making components used by multiple factories in manufacturing our products, fabric suppliers and tier-two suppliers who we have a direct business relationship with.
We communicate our requirements directly to these key tier-two suppliers including through visits and third-party ethical trading audits. We communicate audit findings to the tier-two supplier and the relevant tier-one supplier or agent and require them to address any critical and major non-compliances.
We have further strengthened our procedures in light of the Modern Slavery Act introducing a new subcontracting audit methodology for tier-two suppliers focussing on high risk and critical issues, such as the use of migrant workers. The methodology is based on guidance from Verité (a global NGO that works to eliminate labour and human rights abuses in supply chains) and Stronger Together (a multi-stakeholder initiative that focuses on modern slavery and other exploitation of workers) and is designed to help engage the supplier in improving workplace standards.
When we identify non-compliances with our policies, we aim to work with suppliers to improve standards. This includes, for example, providing expert third-party support to help suppliers improve their policies and procedures. We provided support to seven of our tier-one suppliers and two tier-two suppliers during 2016. We use our regular audits to confirm that suppliers have addressed any issues identified. Any serious or persistent non-compliances would lead to a requirement to terminate the supply relationship.
Training our people
We train our employees on our commitment to ethical trading and human rights, including the risk of modern slavery in supply chains. We endeavour to maintain a culture which does not accept incidents of slavery and exploitation. New starters in our offices and stores in London, Edinburgh and New York complete an hour-long induction session on ethical trading and modern slavery risks.
We have introduced a more detailed training session on modern slavery which includes case studies, tools and resources. This incorporates key aspects of a pilot modern slavery training session that we attended, which was developed by a collection of apparel, footwear and retail companies with the support of the Verité. Our UK design, sourcing, product development, and production team members (who visit our factories regularly) were trained in 2016 with update sessions held in 2017. Our new Asia sourcing team was hired in 2017 and completed modern slavery training during their induction.
Effectiveness of our approach
We have not identified any cases of modern slavery in our supply chain. We have identified three cases among our tier-one suppliers relating to withholding a portion of wages or late payment of wages. We immediately followed up these cases with the factories concerned and the breaches of our policies have been fully resolved.
We will continue to review the effectiveness of our approach and report our progress in future statements.
Chief Executive Officer
Hunter Boot Limited