UK MODERN SLAVERY ACT 2015
This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and sets forth steps JC Broadway Collection Operating Company, LLC (together with its affiliated companies, “JC Broadway Collection” "we," or "us") has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. This statement is intended to enable consumers to make more informed choices about the products they buy and companies they support.
As discussed below, JC Broadway Collection takes our supply chain responsibilities very seriously. We are committed to conducting business in an ethical, lawful, and responsible manner. Slavery and human trafficking are complex and horrific issues and we will not tolerate slavery or human trafficking in our supply chains or in any part of our business.
Therefore, our approach begins with identifying suppliers who share our commitment and who incorporate responsible practices into their own operations. We then systematically monitor our suppliers to ensure their continued compliance and adherence to our standards. We are equally committed to investigating, addressing, and resolving any concerns that may arise.
OUR BUSINESS AND SUPPLY CHAINS
For more than 30 years, we have been one of the most recognized fashion brands. Beginning with shoes and expanding into fashion accessories and clothing, our business -- along with the complexity of our supply chains -- has grown
We have two main types of suppliers:
(i) manufacturing facilities that we directly contract with and monitor;
(ii) llicensees who are responsible for monitoring their own suppliers. These suppliers are in countries around the world. In addition, our licensees’ source and sell licensed products through their own distribution channels. These licensees are also responsible for monitoring their own suppliers.
OUR ANTI-SLAVERY AND ANTI-HUMAN TRAFFICKING POLICIES
JC Broadway Collection will only do business with companies whose workers are in all cases present voluntarily, not put at risk of physical harm, compensated, allowed the right of free association and not exploited in any way. Our suppliers must comply with all legal requirements relevant to the conduct of their businesses.
Therefore, JC Broadway Collection mandates that all our suppliers contractually agree to comply with our Business Partner Terms of Engagement (“Terms of Engagement”). Those licensees who source and sell licensed products through their own distribution channels must also comply with our Terms of Engagement. The Terms of Engagement prohibits the use of prison, indentured, bonded, or forced labor as well as prohibits the use of child labor. The Terms of Engagement also requires every supplier to certify that its employment practices are in compliance with all applicable laws and regulations including all wage and benefit laws, child labor laws and regulations, all applicable laws and regulations governing the safety and health of workers, and all applicable laws and regulations concerning discrimination in employment.
If JC Broadway Collection determines that a supplier is in violation of our Terms of Engagement, we may withdraw production or require that the supplier implement a corrective action plan within a specified time. We will work with such problem suppliers to help them meet our standards. Except in the clearest and most severe cases, we prefer not to pull out of a facility at the first sign of trouble. Rather, we believe progress can be made by constructive engagement to better the situation for the supplier and its employees. However, if a supplier fails to meet its corrective action plan commitment or repeatedly violates our Terms of Engagement, we will terminate the business relationship.
As we apply our standards throughout the world, we will continue to take into consideration all pertinent information that helps us better address issues of concern, meet new challenges and improve our guidelines.
OUR DUE DILIGENCE PROCESSES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING
All new factories manufacturing JC Broadway Collection products must complete a comprehensive Pre-Sourcing Survey Form which requests specific information pertaining to compliance with our Terms of Engagement. No supplier can begin production of our products until JC Broadway Collection has given written approval authorizing such facility. To obtain such approval, the supplier must submit the required information to the JC Broadway Collection factory compliance staff for review. A facility may be added to our approved list of factories only after we have evaluated and approved the new factory proposal.
All new factories are inspected at the inception of our relationship and JC Broadway Collection reserves the right to audit the facilities to verify continued compliance with the Terms of Engagement and all applicable laws and regulations. Each factory is inspected every 12 to 18 months by trained auditors for compliance with our Terms of Engagement. We work on-site with our suppliers to develop strong alliances dedicated to responsible business practices and continuous improvement.
All inspection reports are reviewed by our Senior Vice-President, Supply Chain, and our Legal Compliance Team. The Senior Vice-President, Supply Chain and the Legal Compliance Team hold quarterly meetings to discuss all relevant supply chain compliance matters, including any factory issues.
To ensure strict adherence to our standards, we must know who is manufacturing our products. Therefore, JC Broadway Collection strictly prohibits unauthorized subcontracting. If we discover unauthorized subcontracting, JC Broadway Collection may cancel existing purchase orders and future purchase orders, as well as remove the contracting supplier entirely from our list of approved factories.
JC Broadway Collection knows that even regular inspections cannot identify every workplace problem. Therefore, we have established an employee hotline that allows our workers to report concerns to JC Broadway Collection directly and with complete confidentiality -- calls may be made anonymously if so desired. JC Broadway Collection makes certain that these calls are satisfactorily responded to and, if appropriate, investigated and addressed to ensure proper resolution.
Our licensees are responsible for monitoring their own supply chains. We survey our licensees on a yearly basis and are committed to working with them to achieve social and environmental welfare throughout our global supply chains. The information provided by our licensees in response to the annual survey includes audits, codes of conduct and factory lists.
OUR SLAVERY AND HUMAN TRAFFICKING RISK ASSESSMENT AND MANAGEMENT
JC Broadway Collection knows the challenge of managing global supply chains in the apparel industry. There are well-known reports of slavery and human trafficking in specific countries and in apparel factories.
We recognize that certain areas of our supply chains may pose higher risks due to their geographic locations and our industry. Therefore, we assess the countries where potential suppliers operate to determine if the legal and economic environment creates unreasonable risk to our ability to effectively implement our standards. Our Country Assessment Guidelines help us address the risk of doing business in any country.
Regardless of the countries where factories are located, JC Broadway Collection carefully selects the factories with which we will engage. As discussed in the Polices and Due Diligence sections above, we schedule an initial audit by an external, third-party monitor for all new factories, even those not deemed to be high-risk. These third- party auditors inspect the factories, review with the factory any areas needing improvement and make suggestions as to compliance with JC Broadway Collection policies and applicable law. A factory may begin production for us only after the factory demonstrates compliance with our standards.
In Asia, we contract with a third-party audit firm who is the exclusive certified consultant for Worldwide Responsible Accredited Production (WRAP). In addition, JC Broadway Collection has recently become a member of Business for Social Responsibility (BSR) and is working with BSR to develop a set of actions to further refine our supply chain processes.
EFFECTIVENESS OF OUR ANTI-SLAVERY AND ANTI-HUMAN TRAFFICKING APPROACH
Years before the UK Modern Slavery Act was enacted, JC Broadway Collection was working to ensure that slavery and human trafficking was not in our supply chains or in any part of our business. In addition to requiring training for our people, we have been utilizing our own trained professionals as well as retaining third-party auditors to further our efforts to prevent slavery and human trafficking in our supply chains and in any part of our business. During fiscal year 2016, our audits found instances where suppliers were not in complete compliance with all of our Terms of Engagement but found no instances of slavery or human trafficking.
OUR REQUIRED TRAINING AND CAPACITY BUILDING CONCERNING SLAVERY AND HUMAN TRAFFICKING AVAILABLE TO OUR STAFF
We require all our employee responsible for our supply chains -- including those responsible for conducting on-site visits -- to take online training provided by an American university and taught by leading authorities on corporate responsibility in supply chains.
IIn addition, our third-party auditors undergo training and are sent to reputable organizations to obtain professional accreditations such as SA 8000 certified auditors, ISO certified auditors, Occupational Health and Safety Assessment Series (OHSAS), IRCA, and WRAP consultants.
This training helps equip our people to identify and confront slavery and human trafficking issues.
This statement covers the 2020 calendar year and has been approved by the member of JC Broadway Collection Operating Company, LLC.