This statement is published in accordance with the Modern Slavery Act 2015 and outlines the steps taken by Office Holdings Ltd (“OFFICE”) during the financial year ended on 2nd July 2017 to prevent modern slavery and human trafficking in its business and supply chains.
OFFICE is committed to providing customers with goods that have been produced:
This commitment is upheld through OFFICE’s company policies.
Following on from our statement for the financial year ended on 26th June 2016, we have continued to review our policies and processes, and improving our work on creating awareness of and preventing modern slavery. We have strived to deepen our understanding of risk particularly with our primary suppliers, through further developing our working relationship and involvement within our supply base. We have continued to prioritise visits to factories based in higher risk areas and are committed to increasing the transparency within our supply chain year upon year. Our key areas of focus in the year under review include:
As part of our periodic review of our policies, OFFICE’s Code of Ethics and Good Business Practice has been updated. The Code of Ethics and Good Business Practice is a progression from our previous Code of Conduct. This has taken into consideration new legislative developments such as the Modern Slavery Act and core labour conventions of the International Labour Organization (ILO). This Code applies to all OFFICE employees and associates, including the supplier, manufacturer and any other individual involved in supplying goods to our company. Our Code is designed to be fair, achievable, and easy to check so as to promote the ongoing development of our suppliers. It is the responsibility of our primary suppliers to inform their sub-contractors and agents of our Code and its content, and to ensure compliance throughout the lower tiers of the supply chain.
OFFICE’s Code of Ethics and Good Business Practice is available here and has been communicated both internally and to our primary supply chain contacts.
We work with an established footwear supply base and build close relationships with our suppliers and agents. We understand that our biggest exposure to modern slavery is in our MTO product supply chains, where we have undertaken due diligence investigations to minimise this risk. Our MTO shoes are predominantly sourced from Spain, Italy, Portugal, China, Brazil and India, from specialist footwear manufacturers. We have continued to map our factory supply base and risk assessed each production site geographically against the latest version of the Global Slavery Index to identify areas that are at greater risk to modern slavery and human trafficking.
The OFFICE teams have a long standing relationship with the large majority of our MTO supply base. Any new supplier or factory proposed to OFFICE must complete the supplier and factory set up process before any orders are agreed. This process has been developed to ensure that we have appropriate visibility of the factories being used and commitment from the agent and factory representatives to the OFFICE Code of Ethics and Good Business Practices and to the ethical policies outlined in our Supplier Manual.
We have continued to ensure that for all of our primary factories used for shoe production, approved third party social audits are received annually and graded, along with any corrective action progress reports (CAPR’s) for any non-compliances found. These third party factory audits are undertaken in consultation with the OFFICE Technical team against internationally recognised ethical codes and standards and consist of site tours, document reviews and worker interviews. The OFFICE Technical team works with the suppliers and factories to ensure any non-compliance is resolved in a timely manner relative to the associated risk of the matters of concern.
The OFFICE Design, Buying and Technical teams will continue to visit our primary suppliers and factories to further our working relationship and involvement within our supply base. We will continue to prioritise visits to factories based in higher risk areas and are committed to increasing the transparency within our supply chain year upon year.
As a business OFFICE is committed to addressing and minimising the risk of modern slavery and human trafficking within our business and supply chain. We will continue to review our policies and processes throughout the 2018 financial year as we are aware there are always opportunities for us to improve. Therefore we welcome your feedback. All comments, suggestions and queries should be addressed to the team at firstname.lastname@example.org.
This statement was approved by the Board of the company on 10th December 2017 and signed by Brian McCluskey, CEO, on its behalf.