Modern Slavery Act 2015
2017-18 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 the 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.
Amongst other things, our 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 labour is not used and there are no other occurrences of discriminatory or illegal practices which violate the rights of individuals working within our supply chain.
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 this commitment, we will continue to develop practices and procedures to progress our ethical trading activities and improve transparency of reporting.
Our Business
Specsavers International Healthcare Limited is the Guernsey registered parent company of the Specsavers group. This includes subsidiaries which support our 1,658 optical retail outlets, 300 audiology stores (audiology services are also available in 734 optical stores in the UK, 51 optical stores in the Republic of Ireland and 132 optical stores in the Netherlands) and 49 domiciliary partnerships throughout the UK, Republic of Ireland, Northern Europe, Australia, and New Zealand 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 3,500 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 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 teams 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 are ranked 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 focuses 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 join our monitoring programme and are 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 2017, we continued to invest in and develop our team to ensure we have the appropriate skills and resource to deliver our Strategic Plans in relation to regulation and compliance. In particular:
- We have completed 75 supplier audits, to ensure compliance with our required social and environmental standards
- We developed quarterly Board reporting which enables our Directors to review audit results, identify risks in relation to modern slavery and ethical compliance and supports continuous improvement activity
- An extended review of suppliers is underway, and we will obtain declarations of conformity from those suppliers operating within globally recognised regulatory environments
- We have mapped out our areas of Supply Chain risk across all territories and all categories
- We have worked with our functional leaders to embed compliance activity into their commercial decision making and ensure a successful audit result is a prerequisite of the vendor selection process
Our 2017-18 Plans
- We plan to complete 31 supplier renewal audits to monitor and assess compliance to our standards in addition to initial audits for any proposed new suppliers
- We will introduce modern slavery training delivered via e-learning modules which will provide guidance and insight into modern slavery together with an understanding of how to identify areas of risk
- We will develop our compliance activity to include assessment of risk in relation to origin of products and conflict minerals
- In response to increasingly frequent requests from our corporate customers, we will develop new documentation to clearly state our position on ethical trading to support their Modern Slavery Act compliance activity.
- We will complete activity initiated in early 2018 in relation to obtaining declarations of conformity from those suppliers operating within globally recognised regulatory environments
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 all of its subsidiary companies for its 2018 financial year end, 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
The board of directors of Specsavers International Healthcare Limited have approved this statement.
Signed
Director
SPECSAVERS INTERNATIONAL HEALTHCARE LIMITED