Modern Slavery and Human Trafficking Statement 2022
This statement is published in accordance with section 54 of the Modern Slavery Act 2015 and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. It sets out the steps taken during 2021/22 by Boux Avenue Limited (“Boux Avenue”), having its registered office at 1 St Georges Road, Wimbledon, London, United Kingdom, SW19 4DR, and Company number 07191520.
Introduction from the Board
Modern slavery includes slavery, servitude, human trafficking and forced labour. It’s recognised that this is a global and growing issue, which can exist in all economies and business sectors. The Modern Slavery Act is an important piece of legislation which seeks to provide protection to vulnerable workers, respect their human rights, drive transparency throughout the supply chain, and ensure the supply chain is both slavery and trafficking free. As responsible retailers, Boux Avenue is fully committed to acting ethically, with integrity. We are also committed to putting effective systems and controls in place within our organisation, and continually improving our processes, to ensure we prevent any form of modern slavery and human trafficking taking place within our business and supply chains. This statement sets out the actions we take, and have taken, during the financial year ending 26 March 2022.
We are a trusted multi-channel brand, focused on delivering outstanding customer service and first-class product knowledge. We strive to trade with the best quality suppliers, who have the highest social and ethical standards, and who make available the highest quality products and services for our business and our valued customers. Our products and services are sourced globally via the 37 suppliers we are engaged with, across 109 factories, spanning 13 countries across UK, Europe and further afield, such as the Indian sub-continent and Asia.
Our Policy on Slavery and Human Trafficking
As a responsible retailer, we are committed to the continual improvement of our systems and processes, and we strive to ensure modern slavery does not exist within our businesses or supply chains. Our Code of Conduct aims to uphold internationally agreed standards of labour, in particular those set by the Ethical Trade Initiative (ETI). It sets out our commitment: to freedom to choose employment; freedom of association and collective bargaining; safe and hygienic working conditions; no child labour; payment of a living wage; no excessive hours; no discrimination; regular employment; and no harsh or inhumane treatment. We expect those in our supply chain to respect the rights and wellbeing of their workforce and promote high standards of welfare. The implementation of our Code, is sought through regular checks of supplier services and factories by our agents and third parties.
Our Supply Chain
We pride ourselves on having long-standing relationships with a large number of carefully selected suppliers, who produce some of the most prominent brands within the sector, and who provide services (including the provision of contract and temporary labour) to our business. We are committed to making sure all colleagues around the world, who are involved in the sourcing and production of our products and services, are safe and treated fairly at all times. It is also our aim to source from factories and suppliers who share this commitment. Our suppliers are expected to adhere to our supplier Code of Conduct, which reflects our commitment to striving to ensure that slavery and human trafficking is not taking place within our supply chains. We request copies of our preferred and new suppliers' anti-slavery policies, to ensure they adhere to our principles and Code of Conduct, and continue to monitor suppliers, including carrying out factory audits both through our agents and approved third parties. We work with our suppliers to identify issues and develop a plan for them to make improvements, where required.
High-level risk areas
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted various due diligence procedures, as laid out in the following section. Our procedures are designed to:
Establish and assess areas of potential risk in our business and supply chains;
Monitor potential risk areas in our business and supply chains; and
Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
Due Diligence Processes
We are proud to put our name and branding on our range of uniquely designed, and high-quality products. Our due diligence processes are designed to demonstrate our commitment to striving to ensure that there is no slavery or human trafficking in our supply chain. We track all factories producing and packing our branded product, in terms of audit status and factory grading. We expect, and obtain confirmation, that suppliers of each of our products, and the suppliers of services to our business, adhere to our supplier Code of Conduct.
We adhere to a strict supplier on-boarding process. As soon as a potential new supplier has been identified by one of our buyers, our technical team is informed. They then request an independent audit from the factory the supplier intends to use, to ensure the rights of workers are upheld.
Factory audits are extensive and are reviewed by our technical team on receipt, to ensure adequate practices are in place. Our technical team has the authority to confirm whether an audit meets expected standards. We recognise audits which meet standards relating to, but not limited to:
SMETA (Sedex Members Ethical Trade Audit based on the ETI Base Code)
AMFORI (Formerly BSCI (Business Social Compliance Initiative) based on SA800
WRAP (Worldwide Responsible Accredited Production) Certification
BUREAU VERITAS (PAS)
SMETA and AMFORI audits with minor or no non-conformances are valid for 2 years. When audits are due for renewal, we ask our suppliers to submit a renewed audit for our review.
Before our technical team is able to approve a new supplier, the factory audit provided by them must have no “critical issues” outstanding, and they must also provide us with notice of past compliance issues. Furthermore, no purchase orders can be raised by our buyers until an approved, up to date, and satisfactory audit has been provided to our technical team. Once an audit is deemed satisfactory, and approved by our technical team, they will proceed with completing remaining technical processes, which include quality and fit assessments, before the on-boarding process is complete. Our suppliers are expected to keep a portfolio evidencing their manufacturers’ compliance, which must be available for scrutiny within 24 hours’ notice.
We have developed an in-house eLearning course to ensure all colleagues are aware of, and have a better understanding of the risks of modern slavery and human trafficking. All of our store colleagues are required to complete our basic awareness eLearning course every two years, whilst our retail support centre colleagues must complete this annually. Our trading and buying colleagues are required to complete our specialist version of the course on an annual basis. Modern Slavery awareness is also included as part of colleague inductions and the relevant eLearning course is assigned to all new starters. Additionally, our BUREAU VERITAS supplier website hosts regular webinars that can be accessed by our colleagues and suppliers.
We understand that the approach to modern slavery requires an ongoing assessment of our business and supply chain, in order to continue to minimise the risk of its occurrence. We will continue to work towards reducing risks within our business in the coming year. To do this, we plan to review the following key areas, and will report progress in our next statement:
Governance: Develop our Corporate and Social Responsibility governance framework and review Modern Slavery governance, to build focus and clear action planning for the future.
Learning and Development: Maintain awareness within all our businesses by training colleagues in all levels of the business.
Policy review: Review, improve and develop systems and processes to ensure that our supply chain adheres to our principles and values, including an ongoing review of our Code of Conduct, to ensure it is fit for purpose and effective.
Risk Mitigation and Audit compliance: Review and improve our due diligence and selection process for new suppliers to seek to ensure they, and their supply chains, adhere to our Code of Conduct.
This statement was approved by the board of Boux Avenue Limited.
Group Company Secretary
30th September 2022