Modern Slavery Agreement
In compliance with the regulations of both the UK Modern Slavery Act and the Californian Transparency in Supply Chains Act (SB 657), this statement sets out Thomas Pink’s policies and actions relating to the prevention of slavery and human trafficking in our business and supply chain.
We are committed to preventing slavery and human trafficking within our business activities and to ensure that our supply chains are free from modern slavery and human trafficking in any form.
This statement relates to actions and activities during the last financial year 1st January 2016 to 31st December 2016.
Countries of operation:
Part of the Louis Vuitton Moet Hennessy group (“LVMH”) Thomas Pink is a modern British shirtmaker with flagship stores in London’s Jermyn Street, Madison Avenue, New York and Rue Francois Premier, Paris. Thomas Pink has stores in the UK, Ireland, USA (including California) and France and has a global franchise network including Mexico, Australia, China and South Africa. In addition to its shirt ranges, Thomas Pink carries a range of silk ties, tailoring, knitwear and accessories.
Countries of supply:
Thomas Pink sources its products from approximately 80 suppliers. During the year the majority of products are sourced from supplier sites in Malaysia, Vietnam, China, UK and Italy. The majority of fabrics are purchased from reputable mills in the UK, Italy and China which meet Thomas Pink’s high-quality standards. Thomas Pink exercises caution when approving suppliers to ensure that products are only sourced in countries that respect human rights.
Thomas Pink is aware that some of its operations are considered to be at a higher risk of slavery or human trafficking and is working with its supply chain to mitigate these risks. For example Thomas Pink is a member of the Better Cotton Initiative “BCI”. The BCI exists to make global cotton production better for the people who produce it, promoting decent work practices in the cotton fields, specifically banning child and forced labour. Thomas Pink is working to increase the amount of cotton bought from better cotton sources.
Responsibility for Thomas Pink’s anti-slavery initiatives lies with the Production and Human Resources Teams. Risk assessments, due diligence and training are carried out by these teams who then review policies as required and submit any necessary revisions to the responsible board member for approval.
Thomas Pink has developed the following policies to address human trafficking and slavery in its’ supply chain and business. All policies are available to employees through a central online database.
Employee Code of Conduct:
Thomas Pink’s Employee Code of Conduct sets out the ethical and practical framework within which employees are invited to act. A fundamental part of this is to respect and defend the principles of the UN Global Compact in the workplace, one of these being the elimination of any form of forced or bonded labour.
Ethical Sourcing Policy:
Thomas Pink’s Ethical Sourcing Policy contains direct references to human trafficking and modern slavery. This states that employment should be freely chosen and that no forced, bonded or involuntary prison labour will be tolerated. Suppliers whom engage in or support slavery or human trafficking in any way will not be used.
During 2016, Thomas Pink developed a Whistleblowing Policy which sets out to ensure that protections are in place for those who raise legitimate concerns over wrongdoing within its own operations.
Thomas Pink undertakes due diligence when considering new suppliers and regularly reviews existing suppliers, using a variety of tools to assess potential and existing supply chain partners in all tiers.
Code of Conduct:
All suppliers receive a copy of the Thomas Pink Supplier Manual and must sign a declaration to confirm acceptance of the terms and conditions. Incorporated within this is Thomas Pink’s Supplier Code of Conduct and Ethical Sourcing Policy.
Supplier Management and Supplier Ethical Data Exchange “SEDEX”:
Thomas Pink requests and commissions independent 3rd party ethical audits from tier 1, 2 and 3 suppliers. Thomas Pink visits suppliers on a regular basis and conducts 2nd Party SMETA (SEDEX Members Ethical Trading Audits) ethical audits on factories in the UK. Thomas Pink is also a member of SEDEX. SEDEX is a not for profit membership organisation dedicated to driving improvements in ethical and responsible business practices in global supply chains. Thomas Pink uses SEDEX to store and review audits from suppliers.
Non-compliances found during ethical audits, whistleblowing or other methods form the basis for Corrective Action Plans (“CAPs”). All suppliers are encouraged to work through their CAPs in a timely fashion and Thomas Pink supports suppliers with their CAPs as required. If critical issues such as evidence of human trafficking are found, business would be suspended until corrected and terminated permanently if the issues are not resolved. Whilst Thomas Pink aims to support suppliers in the resolution of incidences of human trafficking and slavery within the supply chain and recognises that it is not possible to effectively solve the issue without the full cooperation of the supplier.
Supply Chain Mapping:
Thomas Pink began mapping its supply chains, starting with 15 top suppliers in late 2014 to assess where risks may lie within its supply chain. Suppliers are now requested to disclose information on their trim and component suppliers as standard practice when beginning work with Thomas Pink.
All retail managers and head office staff joining the business attend a company induction where Thomas Pink’s ethical and environmental sourcing policies, including those on Modern Slavery and Human Trafficking, are explained.
Thomas Pink continues to develop training for those who are involved directly with supply chain management, to improve knowledge and awareness of the issues and concerns surrounding Modern Slavery. Thomas Pink also encourages employees within the Production and Human Resources teams to participate in external training programs and seminars on social compliance issues, human trafficking and modern slavery.
This statement has been signed by Christopher Zanardi-Landi, CEO on 22 June 2017.