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 2019 financial year end. The board of directors of Specsavers International Healthcare Limited have approved this statement.
Slavery remains a reality in the modern world and takes place across the globe hidden from view. It can affect anyone, of any age, gender or nationality and is not restricted by borders. Specsavers is committed to acting responsibly and trading ethically, protecting the environment and ensuring that the people who make our products are safe, healthy and free from human right abuses. During 2018/19 we have continued with our plans in this respect, broadening our understanding of modern slavery risks, strengthening our due diligence processes and increasing transparency of reporting, while also embedding knowledge and understanding of human rights across our teams.
This is Specsavers’ third Modern Slavery statement, which has been published in accordance with section 54(1) of the Modern Slavery Act (2015). It follows on from our 2017/18 Modern Slavery statement and outlines our upcoming plans and commitments towards preventing and mitigating risks of modern slavery throughout our supply chain.
Focusing on specific action that makes a difference remains a priority of our 2017-2020 Supply Chain strategic plan. We are committed to our global ethical trading objectives and to ensuring that we undertake regular, independent audits of all our major suppliers who do not operate in globally recognised regulatory environments. Wherever possible, we develop strong, long-term relationships with our suppliers so that we can work together towards our vision of providing best value eyecare and hearing care to everyone. We also require our suppliers to take the necessary steps to protect the environment.
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 colleagues 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 and supply chain
Specsavers International Healthcare Limited is the Guernsey registered parent company of the Specsavers Group. The Specsavers Group includes subsidiaries which support our 1,726 optical retail outlets, 385 audiology stores (hearing care services are also available in 813 optical stores in the UK, 57 optical stores in the Republic of Ireland, 86 optical stores in Australia and 142 optical stores in the Netherlands) and 49 domiciliary partnerships throughout the UK, Republic of Ireland, Northern Europe, Australia and New Zealand and our 10 group owned manufacturing and distribution sites.
We have 37,000+ 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 19 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. 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, audiology, contact lenses and solutions, eye drops, uniforms, unitary and equipment. As some of Specsavers suppliers are located in higher risk countries, we have procedures that actively monitor the treatment of employees and adherence to associated regulations within those regions.
All suppliers are required to adhere to Specsavers Global Ethical Trading Policy and sign a declaration of conformity. New suppliers are subject to an approval process, being required to comply with our procurement terms and sign a declaration of conformity to acknowledge and confirm their compliance with our principles and requirements. Functional leaders are further supported in embedding compliance activity into their commercial decision making to ensure a successful audit result is a prerequisite of the vendor-selection processes.
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 also ensure those suppliers adhere to Specsavers policy.
After an initial audit, new suppliers join our monitoring programme and are independently audited every two years.
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. This compliance is evaluated as part of our vendor scorecard review process.
We are focused on increasing transparency across our supply chain. We work with over 70 suppliers and 200 factories in 19 countries to deliver the highest standard of products to our customers. Therefore, understanding where our products are sourced and made, and the risks inherent across our operations, is an essential part of our due diligence.
Our product origins are represented on the sourcing map below. We continue to monitor activity in these countries to ensure that slavery and human trafficking does not exist in our supply chain.
As part of our approach to global supply chain governance, we have developed monthly reporting tools, which enables our directors to review results and identify risks in relation to modern slavery and ethical compliance and to support continuous improvement activity. The Director of Supply Chain Commercial Operations is responsible for reporting to the Specsavers Supply Chain Board and Specsavers Executive Committee on implementation progress, supplier compliance and remediation activities, in addition to working with our Corporate Risk teams to map areas of risk across our supply and manufacturing regions.
Regular onsite factory visits are conducted by key members of the Specsavers Supply Chain Leadership team. In addition to this, modern slavery is part of the Supply Chain business review meeting agenda, attended bi-monthly by the leadership team. This is an opportunity to reinforce our due diligence, review progress against our commitments, escalate risks within and between categories and drive our vision to ensure we remain committed to protecting and preserving the rights of all workers across our supply chain.
Training and awareness raising
We recognise the importance of training in raising awareness and embedding knowledge and understanding of human rights, ethical standards and risks across our supply chain functions. Through forming strong relationships and partnerships with our suppliers we raise awareness and discuss the implementation of preventative measures including audit processes, policies and expectations from us to them.
During 2018 and 2019 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 completed 59 supplier audits, including 32 supplier renewal audits and an additional 27 initial audits for new 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 progressed activity initiated in early 2018 in obtaining declarations of conformity from our suppliers operating within globally-recognised regulatory environments.
We reviewed our Global Ethical Trading Policy and Frame Purchasing Manual and issued an updated version to all suppliers. In these we outlined our expectations concerning sourcing materials, specifically conflict minerals. All suppliers are required to source materials from socially responsible suppliers and conflict free mines. Where conflict minerals are essential for production, we will require verification from the supplier that the materials have been sourced from legitimate conflict free mines.
To support our corporate customers Modern Slavery Act compliance activity, we have shared our Global Ethical Trading Policy to provide further clarity on our ethical trading position and increase transparency in this area.
We developed a set of Modern Slavery e-learning modules, which will be made available through our global learning platform to provide our teams with both general guidance and awareness of associated risks. This training is being rolled out to our Supply Chain leadership teams and key staff who have responsibility and involvement in the sourcing, procurement and manufacturing of goods for resale across our product range.
Our 2019/20 plans
In 2019/20, the Specsavers partnership will:
- Complete at least 70 compliance renewal audits to ensure existing suppliers meet our ethical standards, in addition to initial audits for any new suppliers.
- Identify opportunities to share best practice and collaborate with our key supply partnerships to drive improvements.
- Develop our conflict minerals approach in accordance with the Organisation for Economic Co-operation and Development’s five-step framework and adapt our compliance processes accordingly.
- Review and update our policies and practices concerning anti-bribery.
- Continue the development of educational resources for both our suppliers and colleagues to further increase knowledge of modern slavery issues.
- Investigate ways to collaborate with non-governmental organisations (NGOs) and improve stakeholder engagement with our suppliers.
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 supply chain:
All scheduled audits completed.
Declarations of conformity held for all core suppliers of goods for resale based in recognised regulatory environments
A revised Anti-Bribery policy issued and acknowledged by our suppliers and internal supply chain members.
Regular 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 2019 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.