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Policy and due diligence

Our suppliers are required to meet our Ethical Trading Code of Conduct, which includes the provision that workers are free to choose their place of employment. Our Code is aligned with the Ethical Trading Initiatives base code, founded on the conventions of the International Labour Organisation (ILO), and is an internationally recognised code of labour practice.

Our Own Brand suppliers are required to register on Sedex (The Supplier Ethical Data Exchange) and complete the Self-Assessment Questionnaire (SAQ). Here they must declare details of their labour practices before they are permitted to supply to us. Any sites assessed to have high risk are required to pass an independent ethical audit.

Third party suppliers and Indirect suppliers must also sign up to our Code of Conduct. This forms part of the trading agreement and is renewed annually. These suppliers may be required to register on Sedex as a condition of trading with us, particularly when they source product from at-risk locations.

Risk assessment

We understand that Modern Slavery is a criminal activity and the signs and indicators can be difficult to identify. Audits may only reveal a limited amount of information. We are constantly learning and improving our understanding of the risks involved in our supply chain. We have integrated the way we manage issues raised from Social and Environmental audits into our well-established Corrective Action Reporting procedure to ensure that they are resolved as quickly and effectively as possible. We monitor suppliers through Sedex and ensure their SAQ has been completed and up to date.

We use risk assessment tools to monitor the risk score (a function of location, manufacturing type and site profile) and rating for each supplier and use this information, along with any social audits that may have been carried out, to further drill down to see where any issues may lie. If required, we highlight any issues to our Sourcing Team who will then arrange on-site visits and/or audits as required.

We use independent auditors to assess the potential of forced labour indicators. To do this, auditors conduct onsite inspections and confidential worker interviews. Our audits look for several indicators, including those associated with forced labour. When an employer does not communicate the full terms of employment, or give clear documentation defining those terms to a worker in the worker’s own language, these may be signs of forced labour that leave workers vulnerable.

We recognize that conflict minerals are often correlated with instances of forced labour. Whilst we do not engage in direct sourcing from mines and smelters, we are committed to avoiding the use of minerals that have fuelled conflict and other rare earth minerals. We expect suppliers to adhere to our requirements as laid out in our Supplier Quality Manual.

We have made our suppliers of textiles and clothing specifically aware of human rights violations against Uyghur Muslims in Xinjiang, China. We have implemented a strict requirement that no cotton sourced from Xinjiang province should be used in any products supplied to or on behalf of Nisbets.

Awareness and collaboration

Our policies on Ethical Trading, including this statement, are available on our company portal “The Kitchen” and can be accessed to all colleagues.

We recently launched a new training hub called “POTS” which houses our training programs. This has the benefit of being able to track who has completed a course so that we can ensure that all colleagues in a procurement role have attended training and have an awareness of compliance issues both in our international supply chains and closer to home in our temporary labour suppliers.

Our training portal hosts a variety of compliance training courses including Anti-Competition, AntiBribery, Anti-Money Laundering and Mental Health Awareness. It is mandatory for our supply chain colleagues to complete compliance training courses relevant to their role.

Collaboration

In 2021 we aim to re-focus our commitment to Ethical Trade with the formation of a new committee empowered to focus on all areas of Environmental Social Governance.

Modern Slavery is a global issue, but it is also happening in our local communities. Key to combatting this crime will be our commitment to managing our complex supply chains effectively through close collaboration with NGOs, business, suppliers and worker groups to improve traceability and transparency.