Modern Slavery Act
This is Coast’s second statement on Modern Slavery and covers the financial year 2017/18. In accordance with Part Six, Section 54 of the Act, it outlines the measures we have taken to comply with our responsibilities. The first statement can be read here.
Coast is fully committed to ensuring employee welfare and human rights are respected throughout our business and supply chain. This is fundamental to our approach to corporate social responsibility. We recognise businesses can use their influence to positive affect and, as stated last year, we commit to use our leverage, where it may be needed, to prevent against infringements that may occur.
Founded in 1996, Coast is a UK based, multi-channel, occasionwear focused womenswear fashion brand. The brand is sold in 28 countries worldwide via our own stores, concessions, franchise/wholesale partners and websites. We directly employ 951 people across our own operations in four countries. Our supply base comprises 31 suppliers that use approximately 55 factories in seven countries.
Policy development in 2018 focused on cotton. Our cotton policy, which was put in place in 2010, prohibited cotton from the Central Asian state of Uzbekistan. This was due to widely reported and ongoing use of forced adult and child labour. The policy was recently revised to include Turkmenistan, a neighbouring country of Uzbekistan. Like its neighbour, Turkmenistan’s cotton sector is centrally planned and each year tens of thousands of people are instructed to pick cotton during the harvest and, in some cases, there have been reports of child labour. This has been deemed a form of involuntary labour and, therefore, in 2018 we extended our cotton ban to include Turkmenistan.
In relation to Uzbekistan we note the International Labour Organisation’s (ILO) recent report, Third-party monitoring of measures against child labour and forced labour during the 2017 cotton harvest in Uzbekistan. The report claims there has been significant improvement in transparency and dialogue, especially by the state and child labour has been abolished. It states:
‘The picture emerging to the ILO monitors throughout the country was one of intensified efforts to ensure voluntary recruitment [of cotton pickers]. The monitoring and assessment confirms that the majority of cotton pickers engage voluntarily in the annual harvest. They have received wages, which have been increased this year in line with recommendations by the ILO and World Bank. The monitoring confirms the positive relationship between decent wages and voluntary recruitment in cotton picking’.
We welcome these developments, especially in relation to the discontinuation of child labour. Of course, the ILO has not been able to confirm all labour was voluntary. In terms of our policy therefore, we will only allow Uzbek cotton when independent and credible reports verify that no forced labour is used in any stages of cotton production. This year, we looked at our procedures for enforcing our policy and considered we need to strengthen our due diligence at the point when orders are planned and placed with suppliers (including samples) and will therefore involve our buying teams more.
Coast’s code of conduct, adopted over 10 years ago, is based on norms defined by the International Labour Organisation and prohibits forced and bonded labour. It remains the cornerstone of our ethical trading strategy.
As we reported last year, our forced labour and human trafficking policy was adopted in 2017 to strengthen efforts to prevent against forced labour, particularly among high risk group of workers, i.e. foreign and domestic migrants.
Due diligence and risk management
Coast’s audit programme is the chief means of carrying out due diligence on our suppliers. Within the scope of the audit, contract terms and personnel files are reviewed, and the wider recruitment and termination procedure examined. In doing so, this can help determine if there are practices that could constitute or lead to forced labour. We use a range of different tools, including internal audits in China performed by our ethical trading team, third-party assessments commissioned from a limited number of labour specialists and independent audits that are shared with peers to prevent unnecessary and costly duplication of effort. Our buying teams may also visit factory facilities, which provide further observation and scrutiny of manufacturing sites.
We continue to map our first-tier supply chain, which forms part of our ongoing ethical trading efforts, and, in doing so, provides us with crucial visibility of where our products are made. All suppliers are required to inform us in advance if they wish to change their production facility.
Within the business we have a whistleblowing policy which is there to encourage the disclosure of unlawful or otherwise business critical information that might not otherwise be disclosed, including the exposure of risk of modern slavery and human trafficking.
Training and capacity building
One of our key suppliers in China is participating in a multi-brand improvement project run by ethical trading consultants, Impactt. The project involves multiple suppliers who manufacture for well-known UK brands, with the aim to improve compliance by building highly capable management teams. The training has so far covered recruitment practices and health and safety. Next modules are on wages, working hours and employee engagement.
Our buying teams work closely with our ethical trading function in supporting our policies through supplier selection, engagement and follow up.
How is modern slavery reported?
Quarterly meetings are held with the board of directors where recent activity is discussed and any necessary actions can be agreed.
I confirm that the Modern Slavery Act statement has been approved by the Board.