River Island has always believed in doing business the right way. This means honestly, fairly, and with a respect for others. We are a family business with a steadfast commitment to protecting the human rights and the dignity of all persons within our global supply chain. Furthermore, we have an underlying and long standing commitment to ethical trading, based upon the firm belief that business can be both profitable and responsible. Therefore, River Island firmly supports the UK Government’s pioneering approach to tackling modern slavery and the introduction of the Modern Slavery Act 2015.
Modern slavery is a wide-reaching umbrella term which describes a variety of situations where individuals are made to work on an involuntary basis. This can include human trafficking, forced labour, or debt servitude - where a debt is created through deception in order to exploit workers into working against their will. Modern slavery is reported to affect somewhere between 21m and 45.8m victims worldwide, generating an estimated $150 billion of criminal income every year.
We recognise the risk of modern slavery occurring within any area of a business and its supply chain. This risk can be heightened where the following factors are present: migrant labour - within a country or between countries, a high presence of refugees, young workers at risk of child labour, contract and agency workers, outsourced business functions, and female workers.River Island takes the abolishment of modern slavery very seriously and, as such, has incorporated this objective into our existing supply chain ethical trade programme. In order to address this considerable challenge, we are committed to working collaboratively with each of the following: the ETI and its members, government bodies, NGOs, local authorities, and any other relevant stakeholders.
The following statement has been published in accordance with the Modern Slavery Act 2015 and outlines the steps River Island has taken, during the financial year ending 31 December 2016, to identify and prevent modern slavery and human trafficking from taking place within our business and supply chains.
(A) About River Island
River Island is a leading multi-channel fashion brand based in the UK, selling womenswear, menswear, and kidswear. The brand was established in 1988 and is part of the Lewis Trust Group which is a privately owned business. The group was started in 1948, by Bernard Lewis, and he and his family are still actively involved in running River Island today.
We have over 320 stores in 16 countries, on 4 continents, and sell to over 120 countries online. River Island’s annual turnover in 2016 was £1bn.
Our head office in west London is home to the design and development, buying and merchandising, marketing, technical, ethical, sourcing, logistics, legal and finance teams. Our DC, in Milton Keynes, receives, holds, and distributes our products to stores, wholesale partners and online customers. Our IT teams are based at both our head office and also at our tech hub in east London.
Total Number of Employees:
Head Office 1192
Distribution Centre 696
Our product is almost 100% ‘own label’ and includes clothing, footwear, bags and accessories. This diverse range of products is sourced from over 30 countries but the ‘top 5’ countries (China, Turkey, Romania, India and the UK) account for 75% of our range. We work closely with our suppliers and aim to build long-term sustainable business relationships. In 2016 we worked with 285 suppliers (650 factories) but the ‘top 20’ supplied 55% of our products.
In addition, we also source a wide range of goods and services (shop fitting, packaging, cleaning, catering, logistics, security, IT, marketing, ecommerce, advisory etc; collectively referred to as ‘goods not for re-sale’ or ‘GNFR’) from a wide range of third party suppliers, the vast majority of which are UK based.
(B) River Island Policies – Relating to Slavery and Human Trafficking
Supplier Manual - River Island suppliers are contractually bound by the terms and conditions in our supplier manual, which include adherence to the following policies, for the protection and promotion of human rights:
River Island Anti-Slavery and Human Trafficking Policy - incorporated into employee contracts in 2016 download policy.
Employee Contracts – all River Island employment contracts now include a suite of policies designed to protect worker rights and promote a safe and fair supply chain. These include the River Island Ethical Policy, the River Island Anti-Slavery and Human Trafficking Policy, as well as the Anti-bribery and Corruption Policy, and the Whistleblowing Policy.
GNFR Contracts – all require compliance with the Modern Slavery Act and those relationships deemed to be operating in ‘higher risk’ areas, according to the criteria set out below, specifically require adherence to our River Island Anti-Slavery and Human Trafficking Policy.
(C) Due Diligence and Ongoing Assessment of Modern Slavery Risk
River Island has been a member of the ETI since 2008, having adopted the ETI base code as the minimum standards against which our suppliers and factories are consistently measured. This now includes ongoing assessment of modern slavery risk. Our ethical approach is to build trust and transparency with our suppliers and factories, and to fully understand the conditions, risks, and challenges that exist. We aim to collaborate and make improvements as required, but will discontinue business with any supplier, or factory, who persistently fails to be open and honest, take responsibility for meeting our ethical standards, or make the required improvements to rectify serious non-compliances within an agreed time frame. Our focus to date has been on ‘first Tier’ suppliers, factories and sub-contractors who directly manufacture our products.
Our due diligence has covered the following key areas:
New Supplier/Factory Set-up Process: orders cannot be placed with any supplier/factory until it has completed pre-assessment and received approval from the ethical, technical and commercial teams at River Island. This includes all first tier sub-contractors. We review independent 3rd party audits (SMETA) and corrective action plans, and may also conduct River Island validation audits, according to risk.
Visibility of Production Location: suppliers are contractually obliged to manufacture River Island products at the factory named on the purchase order (PO). Only pre-approved sites may be used and written approval is required in the event that the location needs to change. This allows us to report, measure, and risk assess our product supply base according to location and business levels. Ethical audits and resources are prioritised and managed accordingly.
Unannounced/Illegal Sub-contracting: whilst our ethical policy dictates that only audited, approved factories and sub-contractors are used, we recognise that there is an ever present risk of illegal sub-contracting to units with ethical failings, including potential for modern slavery conditions and practices. We have already increased our focus on first tier sub-contracting in 2016 and are committed to increasing visibility and compliance in 2017.
Supply Base Risk Assessment: we are aware that some production locations carry a higher potential risk of modern slavery and trafficking. Key risk factors include migrant labour within a country or between countries, a high presence of refugees, young workers at risk of child labour, contract and agency workers, outsourced HR functions and female workers. In addition, the security situation and increasing threat of terrorism in some countries makes it more difficult to travel safely in order to conduct visits.
Supplier Performance Review: compliance with River Island’s ethical policy is a contractual responsibility for suppliers. River Island buying teams review ‘end-to-end’ supplier performance twice a year. The ethical team provide an ethical score/summary for each supplier to ensure buying teams are aware of, and consider, ethical performance and risk when compiling their sourcing plan. Buyers review the plan with their divisional director, and the Head of Sourcing and Ethical, prior to each new buying season which includes the discussion of any ethical risks and actions required.
River Island Ethical Audits and Visits: our in-country ethical teams are based in our five key manufacturing countries. We arrange regular audits/visits to factories to follow-up on 3rd party audits, monitor corrective action plans, and support with issue resolution. Since 2016 these visits are often unannounced, to uncover real ethical conditions and validate that products are being manufactured in the agreed factory.
ETI Working Groups and Collaboration: in order to address significant and widespread ethical challenges, we are collaborating with other brands, industry experts, NGOs and other stakeholders in the following areas:
ETI UK Working Group: in 2015 ETI members sponsored the research and publication of the independent report into working practices in the Leicester garment industry, published by the University of Leicester. Following this River Island became a founding member of the UK Fast Forward Improvement Programme, working with other brands under the guidance of David Camp download leaflet. David was the founder of an initiative known as ‘Stronger Together’ created specifically to tackle the issue of modern slavery in the agricultural and food industry. He has since adapted the same robust audit methodology and approach to apply to all UK manufacturing factories.
Fast Forward: during 2016 River Island completed Fast Forward factory training, including initial audits and unannounced validation audits, on all River Island UK factories, including first tier sub-contractors. During this process, we uncovered and reported six instances of illegal activity, including suspected trafficking activity, to the Leicester Police. We have now consolidated our UK business into the factories which can demonstrate compliance and ongoing improvements.
ETI Turkey Working Group and the Syrian Refugee Crisis: in 2016 we conducted unannounced audits and published guidance/training to suppliers to help ensure that Syrian workers can be employed ethically, safely, and are paid not less than the legal minimum wage.
Migrant Labour Model: the risk of modern slavery is increased in all countries where migrant labour is relied upon. In 2016, we collaborated with other brands in targeted countries to visit, assess and monitor our shared key factories and recruitment practices, in order to ensure that migrant workers are employed legally and ethically.
Business Wide Operational Due Diligence: in addition to the due diligence carried out in relation to product supply, a due diligence and risk assessment programme is also applied across the rest of the business in order to identify and assess any areas where there is the potential for modern slavery and/or human trafficking to exist (also see Section D below). These assessments have been carried out taking into account the modern slavery risk factors shown above. Each department and location within the business has been reviewed and risk assessed. Every GNFR relationship has also been assessed and graded according to risk. 2017 will see our contracts amended with every GNFR supplier deemed to be ‘higher risk’ in order to procure express compliance with our anti-slavery and human trafficking policy.
(D) Modern Slavery Governance
Sourcing, Ethical and Supply Chain Steering Group: held quarterly and chaired by our CEO. Also in attendance are our COO, our FD, the buying directors and the Supply Chain Director. We review the current supply base and sourcing strategy, as well as highlight any key risks and actions which may be required to comply with River Island’s ethical policy and anti-slavery and human trafficking policy.
Modern Slavery Working Group: in 2016 we formed the Modern Slavery Working Group led by our general counsel. This cross-functional group of senior managers from all areas of the business focuses on the supply of non-branded products, as well as River Island operations and services, with input and guidance from the Ethical Sourcing Manager. This group reports into the Modern Slavery Steering Group which is chaired by our CEO.
(E) Modern Slavery Awareness and Training
Ethical Sourcing induction: all River Island buying teams and new starters are required to attend a mandatory ethical sourcing induction session which provides a detailed introduction to the ETI base code. In 2015 we held a directors’ ethical away day, hosted by an external consultant, in order to raise awareness of worldwide ethical issues and the key risks associated with our chosen manufacturing countries. This provided the foundation for our new ethical policy and strategic approach.
Modern Slavery Seminar: in August 2016 all directors attended a seminar hosted by the founder of ‘Stronger Together’. The seminar covered two modules; ‘Tackling Modern Slavery in UK Businesses’ and ‘Tackling Modern Slavery in Global Supply Chains’.
Online Modern Slavery Training Tool: in 2016 we developed an online modern slavery training tool, due to launch in the summer of 2017. Completion of this interactive module will be mandatory for all head office functions and store managers, with a view to be extended to all River Island UK sites. Completion rates and scores will be monitored, to ensure the awareness and understanding of modern slavery is prevalent in all areas of the business.
Industry training and participation: as an active member of the ETI we regularly participate in briefing meetings, working group meetings, and the Medium Sized Companies’ Roundtable, providing valuable opportunities to raise awareness, share experiences and learnings, and collaborate on the resolution of key issues including modern slavery.
(F) Next Year
We recognise that we are at the beginning of the long journey towards the eradication of modern slavery on a global scale. Nevertheless, at River Island we are committed to continue to do our bit year in, year out, to make that journey a successful one.
In 2017 we will continue work within our product supply chain. We will increase unannounced audits of factories and continue to educate our suppliers. Our suppliers are our partners and we stand a better chance of successfully tackling modern slavery if we have a shared understanding and a shared accountability for the outcome. We will also continue to add tier 1 ‘processors’ (printers and laundries) to our audit and risk assessment process. We will build reporting and visibility of our key fabric mills (prioritised according to River Island business level and leverage) as a first step to enabling tier 2 visibility and risk assessment at a future stage.
2017 will also see us continue to further map the GNFR supply chain and expand our risk assessment exercise. We will be exploring initiatives within each department to further reduce the risk of modern slavery subsisting. Following our GNFR risk assessment in 2016, we shall ensure that all contracts are enhanced to require 3rd party compliance with our anti-slavery and human trafficking policy within areas of the business deemed high risk. We will also be addressing methods of measuring the performance of actions we take to combat modern slavery and human trafficking, to help us monitor how effective our practices have been.