STARLET MODERN SLAVERY ACT STATEMENT 2016-2017
This statement is published in accordance with section 54 of the Modern Slavery Act 2015 for the period 1st September 2016 to 30th August 2017 and provides information on the steps STARLET has taken during the year to ensure that slavery and human trafficking is not taking place in its business.
What is Modern Slavery?
Modern slavery has many different forms: slavery, servitude, forced and compulsory labour and human trafficking. Ultimately it involves one person controlling another person thereby depriving them of their liberty with the aim of exploiting them for personal or commercial gain.
At STARLET, we aim to run our business responsibly. With this in mind, in producing this statement we have looked at all areas of our business and identified that our product supply chain represents the greatest risk of slavery and this is where we have focused our resources.
Our Supply Chain
The majority of our stock suppliers are located in China and India where we have ethical trade employees to manage relationships with our suppliers and work with them to drive improvements.
We are in the pursuit of decent working conditions for workers. Our suppliers are required to agree legal provisions ensuring their compliance with the Modern Slavery Act and to sign up to our Code of Conduct as a condition of working with us. The Code of Conduct is based on the ETI’s Code which includes: no forced labour, living wages, no discrimination, no harsh or inhumane treatment and no child labour. We also have a separate Homeworking Policy and Child Labour Remediation Policy on our website.
We conduct risk assessment checks to assess labour conditions for each stock supplier before a partnership is confirmed. Through third party and direct audits, as well as visits to suppliers and production sites, we ensure compliance with our Code on an ongoing basis. We recognise, however, that ensuring decent, non-exploitative work requires a commitment from us and a partnership with suppliers. For example, where the potential for improvement is identified, we recommend training to suppliers and have facilitated engagement with third party organisations including NGOs and social impact consultants to encourage change. We have directly supported suppliers in efforts to progress worker/management dialogues through worker representatives and committees.
As part of our commitment to ensuring transparency at all levels of our supply chains, field teams work with key suppliers in India and China to map production down through all tiers to homeworking and commodity levels. This is in addition to the mapping of production to homeworker level conducted for all items produced. Ourranges reflects our commitment to supporting handicrafts and homework in production. Suppliers producing for us are supported in incorporating and acknowledging artisanal techniques in production. Relationships with these suppliers are well established as a result of long term development of the range.
Service providers, Non-Stock Suppliers and Partners
STARLET has a substantial number of service and non-stock suppliers as well as a range of partnerships with, for example, online marketplaces and international franchisees. All such suppliers and partners are contractually required to comply with the Modern Slavery Act and all other applicable legislation. Additionally, our franchise partners are also required to sign up to our Policy Manual, which includes our Code of Conduct.
The Modern Slavery Act requires all company employees to consider the relationship that they have with other companies and to be alert to the possibility of slave labour and/or human trafficking. We are implementing a training programme to teach employees about the risks of Modern Slavery to begin on our staff Induction day and continue through role specific training provided to those that require it. We operate a Confidential Helpline for employees who wish to raise concerns about treatment or practices within our business or supply chain without fear of reprisal.