Our Committment

OFFICE HOLDINGS LIMITED - MODERN SLAVERY STATEMENT

Introduction

This, our fifth Modern Slavery Statement, is published in accordance with the Modern Slavery Act (2015). The Act, in particular section 54, brings UK businesses to the heart of the UK’s modern slavery agenda. Along with our parent company, we welcome the increasing momentum towards mandatory human-rights due diligence in the countries that we work and trade within.

Our statement for this financial year outlines the steps taken by Office Holdings Ltd (“OFFICE”) during the financial year ending 28 June 2021 to prevent modern slavery and human trafficking in its business and supply chains. It also outlines our commitments towards mitigating the risk of modern slavery in our supply chain to 2022.

Our commitment to our customers and stakeholders is very clear; we will always provide goods that have been produced:

  • • Lawfully, through fair and honest dealing
  • • In decent working conditions
  • • Without exploiting the people who made them

This commitment is upheld through OFFICE company policies and practices and means we will continually review and improve our policies, practices, and procedures so that we may fulfil this commitment.

Jon Richens, Managing Director

On behalf of the board of Office Holdings Ltd

06th December 2021

About OFFICE and Our Supply Chains

OFFICE is a London (UK) based footwear and accessories retailer with both our own label products and third-party brands. We are both an online and in-store shopping destination across the UK, Ireland, and Germany.

All OFFICE own label products are designed in-house and manufactured by our established supply base of third-party factories. The Corporate Social Responsibility (CSR) team manage this supply chain in collaboration with our own label buying teams. Product supply chains can be complex and involve several different material processes, however the team have mapped all our tier 1 & 2 production sites.

For our own label product OFFICE currently sources from:

  • • 10 Countries
  • • 30 Suppliers
  • • 72 Factories (Tiers 1&2)

(Data correct as of October 2021)


Our Policies and Contractual Controls

Over the past 5 years, to support our compliance programme, OFFICE have continued to improve our policies. Below are our OFFICE companywide policies currently in place, relevant to modern slavery, all of which are signed off at Director level.

OFFICE Code of Ethics and Good Business PracticesThis document, signed by every supplier and factory working with OFFICE own brand products, sets out our minimum global supplier ethical and environmental standards. These are drawn from international standards and internationally collaborative codes like the Ethical Trading Initiative (ETI) Base Code
Confidential Reporting ProceduresAimed principally at our colleagues, confidential reporting channels are managed by a 3rd party company and concerns may be raised by phone or online. This forms part of our work to strengthen our worker voice feedback mechanisms.

Our contracts with our suppliers link to our supplier manual agreement including compliance with modern slavery legislation. These standard supplier contractual terms include obligations on performing Modern Slavery Act risk assessments, instigating controls, and notifying any modern slavery findings. As part of our on-going improvements to our approach we annually review these terms and policies in line with applicable laws. To stay abreast of best practice and technological developments, we also reviewed publicly available information about initiatives taken by other partner brands and companies to combat modern slavery and human rights infringements. The outcomes of this review have been utilised in our approach for the 2021/2022 year and, in particular, the way we focus our resources.

The effect of COVID-19

This year has been an exceptional one. The COVID-19 pandemic has brought unprecedented challenges for the fight against modern slavery. As we discussed in our previous modern slavery statement, OFFICE has used this time to re-evaluate our approach to modern slavery and the procedures we have in place. With lockdowns across the globe, travel to visit and review factories has not been possible and certain external third-party audits that our team ordinarily conducts, had to be postponed. Therefore, the CSR team have been working closely with our in-country suppliers to mitigate the risk to workers caused by the pandemic.

Due diligence and Auditing programme

OFFICE’s approach to risk assessment is a combination of desk-based research, auditing, supply chain mapping and stakeholder engagement. Through our latest mapping and reviews, we established that our greatest risk for modern slavery lies within our supply chains. Therefore, we have conducted due diligence within our supply chains and operations to understand whether there is evidence of modern slavery issues and whether there are adequate controls in place. As acknowledged, the impact of COVID-19 has been significant, and we have had to learn to adapt quickly to respond effectively to the constantly changing situation. Our new ways of working, established during the UK lockdowns, have allowed OFFICE to be highly adaptable in our approach.

Our auditing programme covers 100% of our tier 1 suppliers and in 2021 we have increased this to cover 100% of our tier 2 suppliers. Although we had been able to reintroduce face-to-face third-party auditing in 2021, one of the outcomes of lockdowns and temporary factory closures had meant that traditional audits were suspended in several countries which has clouded certain visibility in this reporting period, 2020-2021. Therefore, we will be working with suppliers in the coming year to identify areas where non-compliance may occur and, where possible, we will limit the number of new factories and suppliers that have been on-boarded to further mitigate this risk.

Training and stakeholder engagement

We have used our training platform to raise awareness and train our wider teams. Initially this program was for all new head office staff and those who are in direct communication with our suppliers, however this year we have also rolled this out to our teams at our warehouses and in stores. When evaluating the risk of modern slavery in the UK at OFFICE we highlighted that these teams are the most likely to encounter third party services in their roles. This year we have trained/retrained 809 team members on the risks of modern slavery through our online portal.

To work in partnership with this additional training, we have established our Modern Slavery Champion with resources from ‘Stronger Together’; an organisation which is working to eradicate modern slavery in supply chains. Year ending June 2021 is the first year that we have had a Modern Slavery Champion and they have been working with our CSR team to raise awareness focusing on the team at OFFICE’s head office and among on-site contractors working for OFFICE as contracted service providers. It is important that people in different roles within OFFICE help to raise awareness of modern slavery and inform others about how to get help and support if they need it. After seeing an uplift in engagement due to the Modern Slavery Champion program, the CSR team plan to increase the number of Modern Slavery Champions at OFFICE in the coming year, allowing our teams to collaborate on a new level in the fight against modern slavery.

On-going commitments and our next steps

In the current climate there are many new challenges in the battle against modern slavery. Despite these, we have made progress this year through the adaptability of our approach. As a result of our on-going work to tackle modern slavery within our business we have identified areas to strengthen and develop in 2021/2022. We will continue to enhance our policies and processes throughout the next financial year through the below activities.

Our Commitments Activities planned for 2021/2022
Auditing and Supply Chain Mapping
  • •Continue to develop our supplier mapping process, to build transparency beyond tier 1 & 2 suppliers.
  • •Review of compliance processes with our third-party partners
  • •Travel restriction dependant: prioritise visits to factories based in higher risk areas and those most affected by the pandemic.
Training and Stakeholder Engagement
  • •Updating training on human rights and modern slavery for our teams.
  • •Expanding the Modern Slavery Champion scheme to cover key departments including Property and Logistics.

As a business, OFFICE is committed to addressing and minimising the risk of modern slavery and human trafficking within our business and supply chain. As we gain more visibility of our supply chain and further risks of modern slavery are identified, we recognise that we will need to continually renew our efforts to minimise negative human rights impacts on vulnerable people in our supply chain. We are mindful that there are limitations in each approach to the prevention of modern slavery and there are many opportunities for on-going development, therefore, we welcome your feedback. All comments, suggestions and queries should be addressed to the team at csr@office.co.uk.