Modern Slavery Act 2015

Modern Slavery Act 2015
2016-17 Slavery and Human Trafficking Statement

Our Position

We are committed to trading ethically and carrying out our business with integrity in an open, honest and accountable way. Protecting our environment and ensuring that people who make our products are safe and free of human rights abuses has been a key feature in our business plans.  Suppliers have been required to adhere to our Global Ethical Trading Policy since 2008.

Focusing on specific action that can make a difference remains a priority in our 2017-2020 Supply Chain strategic plan. Wherever possible we work with our suppliers to develop meaningful, long-term relationships.  We conduct regular independent audits of suppliers trading outside globally recognised regulatory environments to ensure they meet our global ethical trading standards.

Our audit program is designed to identify, monitor and assess that employment is freely chosen, working hours are not excessive, work conditions are safe and hygienic, child labour is not used and there are no other occurrences of discriminatory or illegal practices which violate the rights of individuals in our supply chain

Transparency is an important part of what we do and the way we work and all of our stakeholders play a part in helping us to achieve our aim. There is no place for illegal, unethical or unprofessional conduct in our business. We encourage all team members to speak up if they become aware of activity that is not consistent with our vision and values. 

Since 2011, we have reported on our plans and progress in our Annual Review.  As part of our commitment, we will continue to develop our practices and procedures to evolve our supply chain to ensure that suppliers making Specsavers products and sourcing materials meet our requirements and we will communicate our progress and achievements.

Our Business

Specsavers International Healthcare Limited is the Guernsey registered parent company of the Specsavers group. This includes subsidiaries which support our 1,598 optical retail outlets, 247 retail hearing centres (hearing care services are also available in 691 optical stores in the UK, 49 optical stores in the Republic of Ireland and 120 optical stores in the Netherlands) and 49 domiciliary partnerships throughout the UK, Republic of Ireland, Northern Europe and Australasia and our 8 group owned manufacturing and distribution sites.

We have 31,000+ employees across support offices in Guernsey, UK, Netherlands, Denmark, Finland, Sweden, Norway, Australia, New Zealand, Shanghai and Hong Kong who work in partnership with our retail businesses in 10 countries.

As a retailer, our product supply chains are extensive and global; we source in excess of 400 products from more than 20 countries.  We take our obligations to combat modern slavery and ethical trading very seriously; with a dedicated team of experts supporting the risk assessment and due diligence activities, policies are approved and reviews conducted by senior leaders and we have an absolute commitment to continuously improve and adjust to changing demands.

Identifying and Managing Risks

Our Regulatory and Compliance team are focused on combatting unethical practices within our product sourcing; which includes frames, ophthalmic lenses, contact lenses and solutions, eye drops, uniforms, unitary and equipment.  As some of Specsavers suppliers are located in countries that appear high on the Global Slavery Index, we have procedures that actively monitor their treatment of employees and adherence to associated regulations within those regions.

These suppliers are required to adhere to Specsavers Global Ethical Trading Policy. New suppliers are subject to an approval process, being required to comply with our procurement terms and undergoing an audit carried out by an independent auditor.

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 our suppliers outsource major components to a second tier supplier, we will audit that supplier as well.

After an initial audit, new suppliers will join our monitoring programme and will be independently audited every 2 years. We require suppliers with certain accreditation (such as FAMA) to undergo annual auditing.

Where there is a concern as a result of an audit, the supplier is given a corrective action plan and a timetable within which to take remedial action. If the supplier fails to take the required remedial action, our policy is to withhold approval of a new supplier and to take steps with an existing supplier to address their non-compliance.

Our Progress

During 2016 we invested heavily in our team to ensure we have the appropriate skills and resource to deliver our Strategic Plans in relation to regulation and compliance

  • We have completed 39 supplier audits, to ensure compliance with our standards
  • We report regularly to our board regarding audit compliance and supplier performance
  • We have reviewed existing policies and procedures in our supply chain to ensure that the risks of modern slavery can be identified and we can take appropriate action

Our 2017-18 Plans

  • We plan to complete a minimum of 55 supplier audits to monitor and assess compliance with our standards
  • We will work with our suppliers to raise awareness and educate them of the risks in relation to modern slavery and the sourcing of raw materials to enable them to take appropriate action
  • We plan to extend our review of suppliers to those operating in globally recognised regulatory environments to ensure they also meet our global ethical trading standards
  • We will re-issue our frame purchasing manual and global ethical trade policy to reflect changing demands of legislation and standards impacting our supply chain
  • We will support our functional leaders to embed compliance activities into their commercial decision making through development of regular monitoring, reporting, education, training and risk assessment processes

Measuring Our Progress

We will use the following key performance indicators to measure the effectiveness of our steps taken to tackle modern slavery and human trafficking in our business and its supply chain:

  • A revised Global Ethical Trading Policy and Frame Purchasing Manual (where appropriate) issued and acknowledged by all our product suppliers located in high risk regions
  • All scheduled audits completed
  • 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 statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for Specsavers and its subsidiary companies for its 2017 financial year end. The board of directors of Specsavers International Healthcare Limited have approved this statement.

Signed

Director signature

 

Director
SPECSAVERS INTERNATIONAL HEALTHCARE LIMITED