MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR 2018
Alsico Laucuba Ltd designs and supplies uniform clothing and workwear to a range of organisation types in the UK. Much of the clothing provides protection for the wearer and these buying organisations include laundries who rent out clothing, distributors and industrial companies. In the last year, a growing number of brands whose teams wear a range of clothing that span wider garment types have begun to purchase from us and we expect that this will be a growing market for Alsico.
This year brought a change in Board structure in order to recognise and give dedicated responsibility in the areas of ethical trading, modern slavery and sustainability. A director was appointed to the Alsico board with this specific responsibility; this will strengthen our policy, due diligence and implementation around modern slavery.
Alsico Laucuba Ltd is located in Preston UK and is part of the global Alsico group which is headquartered in Belgium. Alsico own a number of manufacturing locations and sales offices spread across Europe, North Africa, Asia and North America. We are committed to creating and maintaining long-term relationships with suppliers where understanding can be grown and business relied upon in both directions. We have developed new supplier partners in 2018 but this has been to facilitate different and new product groups or extra production space and all pre-existing locations remain a valued part of our supply chain. During 2018 we supplied product manufactured in group-owned manufacturing locations in Laos, Morocco and Madagascar. More than 65% of our product quantity was produced in these locations but our manufacturing totalled less than 40% of the combined output of these factories. Other product groups such as knitwear and outerwear were manufactured in Bangladesh where our requirements represented a small % of the total production output of these manufacturing units. Raw materials and accessories continue to be specified by Alsico and we monitor that these are purchased from our specified mill or manufacturer. Our workforce in the UK is made up of permanent employees employed directly by Alsico in either full or part-time roles with contracted hours. Employees in manufacturing locations used by us are also permanent employees, again employed directly by the manufacturing company. In 2018 one of our locations used migrant workers and provided accommodation for those workers. These workers are all employed directly by the manufacturing unit with full employment contracts and the same terms and conditions as local workers. We have worked with this location in 2018 to promote understanding of how the use of recruitment agencies in the provision of migrant labour can increase the risk of modern slavery in our supply chain. This year brought a change in Board structure in order to recognise and give dedicated responsibility in the areas of ethical trading, modern slavery and sustainability. A director was appointed to the Alsico board with this specific responsibility; this will strengthen our policy, due diligence and implementation around modern slavery.
Policies in areas of procurement, purchasing and HR have been rewritten to ensure that the risk of modern slavery is a key consideration for these areas of activity. We are planning to undertake awareness building shortly with our UK staff in understanding and recognising the risks of modern slavery in our own organisation and supply chain. In 2019 we will also be providing staff and suppliers with a written guide which defines and gives tips for recognising risk in their own organisations and others in their supply chains. Our policies relating to ethical trading continue to be closely aligned to the principles of the ETI Base Code and we actively use these principles to drive our practical work in terms of ethical trading. Every garment and raw material supplier to Alsico has signed up to our policy and agreed to ensure that the Base Code principles are upheld within their own organisation. Alsico is committed to becoming a full member of the ETI 2019 and looks forward to playing a positive part in the members’ discussions and contributing to working groups in the areas of modern slavery. In 2018 we have worked to maintain and develop partnerships with our suppliers to ensure transparency and compliance around modern slavery issues. Each supplier is required to have a clear understanding of the first principle of the ETI Base Code - Employment is freely chosen and this has formed a key part of our practical activities to monitor and continually assess compliance in our supply partners. Policy review and development is embedded in the KPI’s for our Sourcing and Compliance Manager in Alsico. The ownership and signoff for all our policies is placed with this manager and the Director with responsibility for CSR, Ethical Trading and Sustainability. Assessment of supplier and contractor policies in the areas of ethical trading and modern slavery is the responsibility of our Sourcing and Compliance Manager. These are reviewed regularly and we look for evidence of enforcement mechanisms as part of our practical monitoring of suppliers.
We continue to recognise the inherent risks of modern slavery associated with garment production and the geographical and cultural areas in which we manufacture. Much of our manufacturing takes place in group-owned units and here we can be confident that the risks of modern slavery are fewer but independent manufacturers create a greater challenge and it is to these sites in Bangladesh that we will be giving our priority focus in 2019. Our buying, technical and quality staff will be part of on-going training in 2019 to ensure that they up to date with the latest practice in identifying the risks of modern slavery in our supply chain and also able to recognise the salient risk in manufacturing in Bangladesh where we do not own the production units.
We have a strong plan to ensure that we work beyond audit and contractual compliance with our suppliers and will be engaging with them through supply chain-wide projects in 2019. Our objective is to work with a limited number of suppliers in order to gain real information around the potential for modern slavery risk linked to recruitment practices and to discuss with suppliers how these might be remedied where they exist. This will be followed by roll out to the remainder of the supply chain in late 2019, evaluating best practice and sharing the learning across the whole of our supply chain. During 2018, we have started development of our policies around grievance mechanisms and remedy in order to ensure that there is easy access for direct employees and we expect to follow this with a second phase to ensure supply chain employees benefit in the same way. In 2019, we will implement an incident response plan that provides clear guidance on actions that must be taken in the event that an incident of modern slavery is discovered. This defines actions and who is responsible for implementation. In development of policies, due diligence and assessment of risk, we have worked with our group company peers to share and embed good practice throughout the UK business and this has been of benefit to both suppliers and UK staff.
EFFECTIVENESS AND KPIs
The Board of Alsico Laucuba Ltd is committed to the work of the company in this area and has continued to ensure that the resource and capacity required for all our work on ethical trading compliance and development is made available. We have not identified evidence of modern slavery or human trafficking within our immediate supply chain but we recognise that the risks are inherent in the locations and in the industry in which we work. We know that in order to reduce those risks, we must have a robust process in place that continually monitors and assesses the changing landscape that is our supply chain. Our ongoing review of supplier practices achieved through desk top research along with factory visits and independent audits is instrumental in feeding our learning into our business practices.
Alsico Laucuba Ltd