This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for Specsavers International Healthcare Limited (Specsavers) and all its subsidiary companies including but not limited to, the following:

  • Specsavers Optical Superstores Limited
  • Specsavers UK Holdings Limited
  • Specsavers Procurement UK Limited
  • Vision Labs Limited
  • International Glazing Services Limited
  • Lens-Online Limited
  • NLRX Services Limited

Specsavers is committed to acting responsibly and trading ethically and ensuring that the people who make our products are safe, healthy and free from human right abuses.

This Modern Slavery statement outlines the upcoming plans and commitments that Specsavers as a global business has made towards preventing and mitigating risks of modern slavery throughout the business and Specsavers supply chain. Specsavers continues to broaden its’ understanding of modern slavery risks, strengthening due diligence processes and increasing transparency of reporting, whilst also embedding knowledge and understanding of human rights across the Specsavers teams. Specsavers continues to focus and continually advances the business efforts in tackling Modern Slavery.

Our approach

Specsavers is committed to global ethical trading objectives, and to ensuring that regular, independent audits of all major suppliers who do not operate in globally recognised regulatory environments are undertaken and monitored.

Wherever possible, Specsavers has, and continues to develop strong, long-term relationships with suppliers so that Specsavers can work in partnership with the suppliers and provide best value eyecare and hearing care to everyone.operations

Amongst other things, the Specsavers audit program is designed to identify, monitor and assess that employment is freely chosen, working hours are not excessive, conditions are safe and hygienic, child labor is not used and there are no other occurrences of discriminatory or illegal practices which violate the rights of individuals working anywhere within the Specsavers business, including its supply chain.

There is no place for illegal, unethical or unprofessional conduct in Specsavers. Specsavers as a business, makes it clear that colleagues must speak up and report, if they become aware of any activity that is not consistent with the Specsavers trading vision and values. Since 2011, Specsavers has reported on activity relating to Modern Slavery avoidance, the business plans and progress in the Specsavers Annual Review. As part of this reporting and commitment, Specsavers continues to develop practices and procedures to progress and enhance the ethical trading activities and improvement of the transparency of reporting.

Our facts and figures 2023/24

Our business and supply chain

Specsavers International Healthcare Limited is the Guernsey registered parent company of the Specsavers Group. The Specsavers Group includes subsidiaries which are or support optical retail outlets, audiology stores and domiciliary partnerships throughout the UK, Republic of Ireland, Northern Europe, Spain, Canada, Australia and New Zealand as well as Specsavers group owned manufacturing and distribution sites.

Specsavers has more than 40,000 employees across Guernsey, UK, Republic of Ireland, Netherlands, Denmark, Finland, Sweden, Norway, Spain, Hungary, Canada, Australia, New Zealand, Shanghai and Hong Kong.

As a retailer, the product supply chains are extensive and global; Specsavers sources in excess of 3,500 products from more than 20 countries. The global Specsavers business, takes the obligations to combat modern slavery and to trade ethically very seriously, with a dedicated team of experts supporting risk assessment and due diligence activities.

Identifying and managing risks

Policies and controls

The Specsavers Regulatory and Compliance teams continue to focus on ensuring our operations are free of unethical practices and we continue to make our processes more robust in this area.. As some of Specsavers’ goods are manufactured in medium-risk countries, procedures are in place to monitor the treatment of employees and ensure we comply with local laws and regulations as a minimum in these regions. We require our suppliers to adhere to Specsavers Global Ethical Trading Policy or have their own equivalent standard and checks in place. Specsavers retains the right to independently audit compliance with these principles and requirements. When engaging with new suppliers in the product sourcing category, they are required to undergo a risk assessment process and a third-party audit.  Alongside this we carry out additional compliance checks, all of which must be completed and approved before production is commenced.  

Throughout the relationship with the supplier, functional leaders are supported by the Regulatory and Compliance teams to embed compliance activity into their commercial decisions and supplier performance discussions.

After undergoing an initial third-party audit, these suppliers join the Specsavers monitoring programme and are each independently audited every two years (as a minimum).
The audits focus on risks associated with modern slavery and human trafficking, including the occurrence of passport retention, illegal documentation, the right to work, illegal deduction of wages, child labour, forced labour, excessive hours of work and illegal subcontracting. Where any of the Specsavers suppliers outsource major components to a second-tier supplier, it is paramount that the suppliers pass the Specsavers policy to them, and that monitoring is ensued.

Where there is a concern as a result of any audit, the supplier is immediately given a corrective action plan (CAP) and a timetable within which to take remedial action. If the supplier fails to take the required remedial action, Specsavers maintains the right to reduce, withdraw or (if a new supplier) withhold business, although our preference is to work with suppliers to assist in rectifying the issues in order to protect their employees. 

Increasing transparency

Specsavers is focused on increasing transparency across its supply chain and overall business. Specsavers works with over 70 suppliers and 200 factories in 20 countries and is committed to delivering the highest standard of products to every single Specsavers customer. Therefore, understanding where products are sourced and made, and the risks inherent across the supply chain operations, is an essential part of due diligence undertaken.

The product origins for Specsavers are represented on the sourcing map below. Primarily the products come from globally recognised regulatory environments or factories situated in low and medium-risk countries. The activity in the countries which Specsavers sources product from is continually monitored to ensure that slavery and human trafficking does not exist in the Specsavers supply chain.

Governance

As part of the Specsavers approach to global supply chain governance, Specsavers now has a team dedicated to onboarding our suppliers to the SEDEX platform and monitoring ethics performance. In addition to formal audits, key members of the Specsavers supply chain team regularly undertake onsite factory visits. During 2024 Specsavers has over 250 planned visits into China and Asia collectively, and any action required by the suppliers visited, is or shall be reported into our ethics governance process.

We have formalised our ethics governance process, with issues and non-compliances forming a standing agenda item at quarterly, operating board level meetings.  Where non-compliances are not able to be resolved by our Regulatory and Compliance teams, our supply chain board are responsible for ensuring that these form part of a discussion with suppliers.  Our preference is always to work with suppliers to resolve issues that support them in ensuring that their employees' rights are protected.  A key part of our governance process is to ensure that the product directors of our business consider the ethical status of our suppliers and have responsibility for communicating our requirements where issues are identified.  This process allows us to use commercial leverage if it is required, whilst avoiding a cut and run approach to supplier relationships.

Sustainability: Sourcing Responsibly

Sourcing responsibly is integral to the way we operate. We work to ensure that the people who make our products have safe and healthy workplaces, where human and civil rights are respected. We also require our suppliers to take the necessary steps to protect the environment.

We have been committed to our Global Ethical Trading Policy to ensure regular, independent audits of all our major suppliers who do not operate in globally recognised regulatory environments. However, we recognise a need to continuously evolve and enhance how we manage ethical and sustainability risks in our supply chain. As such, we have begun the transition of our supply base onto the SEDEX platform.  77 supplier sites have been onboarded as at the date of this statement, giving us increased visibility of ethics within our supply chain.

Alongside this ongoing piece of work, we are developing a comprehensive risk assessment process to allow us to evaluate risks to human rights across our extended value chain.  We expect to complete this work in the second half of 24/25 allowing us to risk assess our full value chain next year. 

Our Supplier Code of Conduct lays out our expectations of our suppliers which are aligned with, amongst other topics, The International Labour Organisation’s Declaration on Fundamental Principles and Rights to Work. To date, our Supplier Code of Conduct has been issued to and accepted by our top 75 suppliers, representing 65% of our spend on products and services.

Training and awareness raising

Specsavers recognises the importance of training, raising awareness and embedding knowledge and understanding of human rights, ethical standards and risks across all the Specsavers business functions. In each of its retail outlets, whether optical or audiology, reinforcement of the risks of modern slavery is given to all employees and partners. Through forming strong relationships and partnerships with suppliers, Specsavers continues to raise awareness and undertake discussions as to the continued implementation of preventative measures including audit processes, improved policies and agreeing on the standards expected.

Our progress

During 2023/24 we continued to invest in, and develop, our people  to ensure we have the appropriate skills and resources to deliver the Strategic Plans in relation to regulation and compliance. We have grown the global team across the regions and recruited subject matter experts dedicated to each element of the long-term plan. The teams have all provided expertise and support with progress, in particular:

  • Following the launch of our new Supplier Code of Conduct, we engaged with, and received commitment from, our top 75 suppliers across goods for resale (GFR) and goods not for resale (GNFR). These suppliers account for 65% of our spend on products and services.
  • The Specsavers team completed 69 supplier audits, for suppliers across our product categories. These audits ensure compliance with our social and environmental standards and adherence to regulatory requirements, enabling long-lasting improvements to be achieved.
  • We became registered members of SEDEX, as part of our commitment to ensuring good working conditions within our supply chain. The ethical and environmental data platform will allow us to report more transparently on our suppliers’ performance, identify risks more accurately and therefore focus our efforts accordingly.
  • We onboarded 77 manufacturing sites onto SEDEX and have started the process of mapping our full value chain.We consulted with our key suppliers to better understand which ethical and sustainable standards and practices they have in place.
  • We began inserting sustainability related contractual clauses into new agreements with suppliers. These enable the implementation of measurements and reporting on our environmental targets.
  • We formalised our governance of ethics across our supply chain, ensuring that senior directors up to executive board level are informed and involved in decision making on ethics and human rights issues. 

Our plans

In 2024/25, we will remain committed to being ethical and sustainable across our business, and making a positive difference by:

  • Ensuring a robust approach to human rights and ethical risks. Working with independent auditors, as well as the introduction of our new systems, enables us to conduct risk assessments and proactively rectify any non-compliance of our policies which are aligned with the Ethical Trade Initiative and the International Labour Organisation;
  • Continuing to embed our Supplier Code of Conduct which sets out the behaviours and standards that suppliers must always demonstrate when working with us.
  • Ensuring that all of our  product suppliers are audited and onboarded onto SEDEX with and Corrective Action Plans in place where required.
  • Carrying out risk assessment of our wider value chain to identify further areas of ethics and human rights risk.
  • Running communication events with our key suppliers to ensure they understand our expectations regarding the ambitions we have towards our people, communities and planet.
  • Continuing to educate Specsavers colleagues on the areas of risk within our supply chain and how to identify and manage them.
  • Working collaboratively with our suppliers to identify opportunities to share best practice and to drive improvements.
  • Identifying areas where we need to engage third party organisations and NGO’s to build our knowledge of developing human rights risks.
  • Providing clarity within our supplier contracts, not only about how we require then to operate in accordance with internationally- recognised standards, but also the actions that will be taken in the event of non compliance. 
  • Continuing to evolve and adapt our sustainability related contractual clauses to keep up with changing targets, expectations and regulatory requirements. 
  • Engaging stakeholders within our value chain to identify areas for improvement. 

Measuring our progress

Specsavers has committed to adhering to the following key performance indicators to measure the effectiveness of steps taken to tackle modern slavery and human trafficking in the Specsavers business:

  • All scheduled audits completed with Corrective Action Plans in place and actioned within appropriate timeframes.
  • Declarations of conformity held for all core suppliers of goods for resale based in recognised regulatory environments.
  • Quarterly board reporting on identified risks of modern slavery and ethical compliance.

This Modern Slavery Statement is made in respect of the Specsavers International Healthcare Limited’s financial year ending 29 February 2024 and has been approved on behalf of the board of directors. 

John Perkins

Group Chief Executive Officer, for and on behalf of SPECSAVERS INTERNATIONAL HEALTHCARE LIMITED

Statement No. 8

Dated: August 2024