Introduction

This statement sets out Threads' actions and commitment to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. We are referring and aligning to the Ethical Trading Initiative definition of Modern Slavery: 

“Modern slavery is an umbrella term that includes forced labour, debt bondage, servitude and trafficking for the purposes of labour exploitation. The prohibition of forced labour forms Clause 1 of the ETI Base Code, Employment is freely chosen, as it is the most egregious labour rights violation. Forced labour describes a situation in which a worker performs work or services involuntarily and under a threat of some form of penalty. ” 

This statement relates to actions and activities during the financial year 1st Jan 2022 to 31st Dec 2022.

As part of the luxury fashion industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking, and we continue to take our responsibility very seriously as we navigate post pandemic.

Organisational structure and supply chains

 This statement covers the activities of the Threads Styling Group.
Threads Styling is a global concierge business that sources and delivers bespoke luxury fashion and other products for women, men and children.
The countries assessed by the company of being high risk are: Belarus, Central African Republic, China, Eritrea, Iran, North Korea, Russia, Sudan, Syria, Venezuela, Crimea and Cuba

  
High-risk activities

 
The following activities are considered to be at high risk of slavery or human trafficking:

• Manufacturing supply chains
• Gem stone and fine jewellery products
• Cotton, denim & sneakers
• Exotics
• Fur
• Delivery partners

Responsibility

Responsibility for our anti-slavery initiatives is as follows:
Risk assessments and due diligence: We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking. We are constituting a Modern Slavery Committee responsible for the creation and review of any policies in relation to modern slavery or human trafficking. The committee is responsible for overseeing any risk assessment required for high risk activities.

• Tier 1 suppliers will be required to agree to contractual terms relating to modern slavery. Any tier 1 partner who receives financial payment from Threads is  required to specify their approach to the modern slavery act as part of their onboarding. The Executive VP of brands is responsible for the completion and monitoring of the supplier agreements relating to brands, and the Head of Logistics is responsible for the completion of due diligence on delivery partners. 
• Any investigations will be carried out by the Chief People Officer, and the VP of Operations / Chief Operating Officer. Any suppliers unable to agree to the terms must provide evidence of their own modern slavery statement and commitments.
• The modern slavery committee will be monitoring external channels for any references relating to brand partners not complying with the modern slavery act, as well as the internal whistleblowing process.

Looking over the next 12 months our vetting process will be further developed for all tier 1 suppliers and partners to continue: 

• Evaluating the modern slavery and human trafficking risks of each new supplier
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• Conducting supplier audits or assessments through the organisation's own staff/third party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• Creating an annual risk profile for each carrier and packaging provider;
• Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans
• Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular using details of ethical supplier database, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship 

Relevant Policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our confidential helpline/complete our confidential disclosure form.
• Employee code of conduct Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier/Procurement code of conduct We are committed to ensuring that our tier 1 suppliers adhere to the highest standards of ethics. Suppliers will be  required to demonstrate that they are providing safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We will work with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. Any violations will be investigated and the committee will agree on whether to pause, separate, investigate further or review terms, depending on the incident.
• Recruitment/Agency workers policy We use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. We pay a minimum of the living wage to all employees in the UK, and minimum wage in the US. 

Training

We will be requiring staff/staff working in roles that have procurement, recruitment and supply chain responsibilities to have completed training on Modern Slavery as part of their induction. 
 
Our modern slavery training will cover:

• Our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation;
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.

Awareness-raising programme

As well as training staff, we have been raising awareness of modern slavery issues by circulating information via email to staff members who work with our external partners and we will provide in depth training for hiring managers.
 
The emails or presentations explain to staff:

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and
• what external help is available, for example through the Modern Slavery Helpline.

Board approval

This statement was approved on 16 November 2022 by our Board of Directors, and will be reviewed and updated annually.