THE VIVIENNE WESTWOOD GROUP MODERN SLAVERY ACT 2015 STATEMENT FOR THE FINANCIAL YEAR ENDED 31 DECEMBER 2022
This is our seventh statement published pursuant to section 54 of the Modern Slavery Act 2015. The Modern Slavery Act 2015 (“Act”) is a piece of legislation enacted in the United Kingdom to combat slavery, servitude, forced or compulsory labour, and human trafficking. The term “modern slavery” is a broad term used to encompass slavery, servitude and forced or compulsory labour and human trafficking, which are offences under the Act.
This statement provides an overview of our business and supply chain. It also sets out the steps taken by the Vivienne Westwood Group during the financial year ended 31 December 2022 to prevent modern slavery and human trafficking potentially taking place in our business and supply chain. This statement is prepared and published by Vivienne Westwood Limited on behalf of the Vivienne Westwood group, which is made up of a parent company (Latimo S.A.) and its subsidiaries in the United Kingdom (Vivienne Westwood Limited), Italy (Vivienne Westwood S.r.l.), France (Vivienne Westwood S.a.r.l.), the United States (Rio Bravo Inc.) and China (Vivienne Westwood Asia Ltd), as well as a representative office of Vivienne Westwood Limited in Thailand (“Vivienne Westwood Group”).
You can find our previous statements by clicking here:
2. OUR BUSINESS
The Vivienne Westwood Group is an independent global fashion house that designs, develops, manufactures, and sells a range of luxury goods, including womenswear, menswear, footwear, accessories, jewellery and homeware, under the Vivienne Westwood brand. Our supply chain plays an important role in the process of bringing our finished products to our customers.
3. OUR SUPPLY CHAIN
Our supply chain is split into two main streams:
(A) Operations (product design, development, manufacturing, packaging, delivery and sales); and
(B) Administration (procurement of complementary or ancillary services and products that support and facilitate our day-to-day operations).
Supply chain streams (A) and (B) above are multi-tiered, extend across borders, and involve thousands of workers located across the United Kingdom, Europe, Kenya, Tunisia, South Korea, Turkey, Japan, Thailand, Hong Kong, China, and United States.
The product design process is centralised in our head office in London. Our design teams work independently and in collaboration with our trademark licensees to design and develop the range of products we sell each season. Our design teams also collaborate with other brands to bring to market-limited collections of products.
Raw materials used in the manufacturing of our finished products are selected on a per category and per season basis by the Vivienne Westwood Group, our trademark licensees and external manufacturers. We retain final approval on the selection of raw materials unless, by exception, we are collaborating with another brand in which case approval is a joint decision or we have granted an exclusive trademark licence. Our selection process is driven by environmental sustainability goals that support our modern slavery mission. The same goals drive the selection of the raw materials that are used in our retail packaging (the packaging we offer to our customers) and our transit packaging (the packaging that we use to wrap our goods in transit).
As at 31st December 2022, data reveals that a large proportion of our finished products are manufactured by Tier 1 suppliers located in the following territories:
• Italy: 31 (thirty-one)
• Thailand: 4 (four)
• Turkey: 2 (two)
• United Kingdom: 5 (five)
• Portugal: 1 (one)
• Kenya: 1 (one)
• Tunisia: 1 (one)
• Hong Kong: 1 (one)
• Portugal: 1 (one)
The remaining proportion of our finished products, consisting mainly of made-to-measure couture pieces, are manufactured directly by our studio in London with the assistance of select European-based ateliers. Our retail and transit packaging, on the other hand, is manufactured in Europe and China.
Once manufactured, our finished products and packaging are delivered to our warehouses in the United Kingdom and Italy for onward despatch via our global distribution channels. Our finished products are available for sale on a seasonal basis to commercial partners, including franchisees, department stores and independent retailers. Finished products manufactured by our trademark licensees and by our brand collaborators are sold directly to our commercial partners.
Our finished products are also available for sale directly to consumers. Consumers can purchase our finished products online through the e-commerce website accessible from www.viviennewestwood.com and the e-commerce websites of our commercial partners. They can also be purchased offline by visiting one of our retail stores located in Milan, Fidenza, Paris, London, Cardiff, Nottingham, Manchester, Glasgow, Leeds, Bicester, Los Angeles and New York, or the retail stores of our commercial partners. Brand collaboration products can also be found on the e-commerce website and in the retail stores of our brand collaborator (when in season).
Production of our rugs, watches, eyewear categories are manufactured by our trademark licensees based in the UK from premises located in China, Hong Kong and in Nepal. We also work with licensees in Japan and South Korea, who produce special collections of bags, small leather goods, eyewear, lighters, soft accessories and RTW which are distributed in those respective countries only. Our team works with our UK licensees to ensure they apply consistent standards which align with those adhered to across the rest of VW’s supply chain.
To support our day-to-day operations, the Vivienne Westwood Group procures a diverse range of services and products. We procure marketing, IT, legal, logistics and auditing services to support sales and operations. We rely on external logistic hubs and external courier suppliers for the transportation of our finished goods. We outsource trademark protection. We also procure stationery, and other administrative equipment and products, including insurance coverage, payment machines, and retail, office and warehouse fixtures and fittings. These services and products form an integral part of our procurement supply chain, which is managed and overseen by our employees in our head offices in London, Milan, Paris, New York, Los Angeles, China and Thailand.
We believe in protecting the dignity and rights of all workers and recognise that modern slavery is a serious crime resulting in abhorrent abuses of human rights throughout the world. We recognise that global fashion supply chains such as ours involve thousands of workers. Accordingly, our mission is to take steps within our business and supply chains that will prevent any of our operations becoming fertile ground for modern slavery. We aim to support local industry while ensuring that applicable human rights and employment laws are always respected.
We are committed to being a responsible business and if we find that one of our suppliers is involved in any modern slavery offences, or is not adhering to our brand’s Labour Code of Practice or modern slavery standards, our primary concern will be to protect the safety of affected workers. We will then act to identify the origin of the offence or failure. This will involve making preliminary enquiries and deciding whether further investigation is warranted. Once we have determined the cause (or causes) of the offence or failure, we will engage with our supplier to agree a corrective action plan. Repeated failures and egregious abuses of human rights within our supply chain, and within those of our suppliers, will not be tolerated. We expect all our suppliers to embed respect for human rights within their own operations and supply chains.
5. OUR OBJECTIVES
To this end, our objectives are to:
1. Identify and monitor modern slavery risk areas in our business and supply chain and make year-on-year progress to address any risks identified and take action to improve outcomes for workers;
2. Highlight the risks and impact of modern slavery on our business and supply chain to our employees and suppliers;
3. Support local industries while ensuring that employment laws are respected;
4. Identify an independent organisation with whom we can partner to support us in our modern slavery mission;
5. Continue to provide training to our employees, and guidance to our suppliers, on how to identify, manage and mitigate the risks of modern slavery in our business and supply chain; and
6. Continue to promote a whistleblowing mechanism for anonymous reporting of suspected and actual modern slavery offences in our business and supply chain for the benefit of our employees and supply chain workers.
6. OUR TOOLS, POLICIES AND PROCEDURES
We have a set of tools that we deploy to help us achieve our objectives and succeed in our mission to combat modern slavery in our business and supply chains. These tools have been produced to help us ensure a consistent approach to identifying, managing and mitigating the risk of modern slavery in our business and supply chains.
We have produced a Due Diligence Questionnaire and Modern Slavery Pack which we send to all our suppliers and business partners to complete and return to us. The pack consists of a suite of documents, including a Code of Labour practice, a Modern Slavery Policy, a Whistleblowing policy and Modern Slavery Reporting Guidelines which all suppliers and business partners are expected to follow.
This pack is destined for all our existing and future high-risk suppliers and has been designed to:
• Help identify any modern slavery risk;
• Communicate our position on modern slavery;
• Clarify what we expect from individuals in our business and supply chain partners regarding fair employment practices and safe working environments.
• Provide workers in our supply chain with a whistleblowing mechanism; and
• Provide guidance on what information to include in annual modern slavery reports.
Further information on the above documents can be found below.
We also have a set of contractual modern slavery compliance provisions, which we include in contracts with partners and suppliers using a risk-based approach.
A. OUR DUE DILIGIENCE QUESTIONNAIRE
Our Due Diligence Questionnaire is a tool we have created to collect information from new and existing suppliers and partners on their awareness of modern slavery legislation, their employment, and health and safety practices, and the tools they use to mitigate the risk of modern slavery in their own supply chains. All suppliers and partners are required to submit this information to us on an annual basis. The information we collect through this questionnaire helps us build initial profiles of suppliers and partners. It also helps us assess whether further action or investigation is warranted.
A revised version of the Due Diligence questionnaire was produced in 2020 and added to our Modern Slavery Pack that has been deployed to suppliers in 2021. Our revised Due Diligence Questionnaire includes a mixture of targeted open and closed questions, together with an introductory paragraph explaining the purpose of the questionnaire, and this has successfully enabled us to gather more information than in previous years.
B. OUR MODERN SLAVERY PACK
OUR MODERN SLAVERY POLICY
Our Modern Slavery Policy has been produced to bring the requirements of the Modern Slavery Act 2015, and the rights and principles enshrined in the United Nation’s Universal Declaration of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work to the attention of our suppliers. This policy describes how we expect our suppliers to assist us in combatting modern slavery risks throughout our supply chain by providing guidance on how to identify, assess, manage and monitor modern slavery risks.
OUR CODE OF LABOUR PRACTICE
Our Code of Labour Practice outlines the behaviours we expect our suppliers to adopt and uphold in relation to their own employees and their own supply chain by imposing obligations to adopt fair employment practices, and guarantee safe working environments free from child labour, discrimination, harassment and abuse. Our Code of Labour Practice also requires suppliers and partners to establish and maintain appropriate procedures to evaluate and select their own suppliers based on their ability to meet the requirements of our Code of Labour Practice.
During 2022, our Italian operating company introduced a Code of Labour Conduct and Business Practice for all onboarded suppliers which sets out our brand’s standards regarding safe and regular labour conditions in the factories and has been updated with additions of clauses pertaining to ethics and integrity, employment of third party country nationals, anti-corruption, conflict of interest, industrial and intellectual property, protection of competition, anti-money laundering, industry and trade.
OUR WHISTLEBLOWING POLICY
Our Whistleblowing Policy provides a mechanism that enables individuals employed by our partners and/or suppliers can use to contact us directly to report any potential concerns or suspicion of wrongdoing, unethical practice or criminal acts within the workplace in our supply chain.
Our Whistleblowing Policy lists examples of concerns or suspicion of wrongdoing, unethical practice or criminal acts that can be reported to us. It also provides a whistleblowing report form that individuals forming part of our supply chain can complete; and, explains how we will respond to any concern or incident reported to us.
In 2022, our Italian operating company has substituted the offline physical paper document with a new advanced online Whistleblowing tool for Modern Slavery to modernise the process, in which our Italian suppliers have now access through a QR code that leads to the main page of the software to proceed with any reporting.
OUR LETTER OF UNDERTAKING
Furthermore, we ask all of our suppliers to read and undersign a letter of undertaking to acknowledge both our Code of Labour standards and Modern Slavery Policy and most importantly, to undertake that they agree to implement our policies step-by-step within their company. In fact, these are all requirements of working with us to ensure that our policies are observed in all the workplaces where our products are manufactured.
Within the letter, we also ask our suppliers to commit to prepare and submit to us no later than 31 March each year an annual report on Modern Slavery and Human Trafficking outlining the steps they have taken, and continue to take, to ensure that there are no cases of human trafficking and slavery in any of their supply chains and in any part of their activities.
OUR MODERN SLAVERY ANNUAL REPORTING GUIDELINES
As anticipated in our modern slavery statement issued last year, data collected from manufacturers with which we have a direct commercial relationship, revealed potential benefits of sharing guidance with our suppliers on the information to be provided in their annual modern slavery reports.
Our Modern Slavery Annual Reporting Guidelines are issued to partners and suppliers that have agreed to annually report to us on the steps they have taken to ensure modern slavery and human trafficking are not taking place in any of their supply chains or in any part of their business.
C. OUR RAW MATERIALS SUPPLIER FORM
Our Raw Materials Supplier From is a tool that has been created for assessing raw materials suppliers in a standardised way. It has been introduced to our internal sourcing teams in 2021 and deployed to raw materials suppliers starting from the first half of this year. An improved traceability and transparency matrix has been included in the form, in order to fit textile and leather supply chains and collect data from an early stage of the sourcing process.
D. OUR CONTRACTUAL MODERN SLAVERY COMPLIANCE PROVISIONS
Our contractual modern slavery compliance provisions are included in partner and supplier contracts wherever possible. At present, the contractual modern slavery compliance provisions are included in all agreements with suppliers and partners that manufacture finished products bearing the Vivienne Westwood trademark or consisting of other intellectual property rights, and in selected logistic services agreements and high-risk service providers.
E. OUR SUBSUPPLIERS LIST PROCEDURE
The Sub-supplier list procedure (‘the Procedure’) has been defined and developed in 2022 in order to make direct manufacturing suppliers that sub-contract any or part of their services more accountable of the production activities they have externalised and to provide improved visibility on sub-suppliers within our supply chain.
The Procedure has been divided in two documents: the first inherent to the actual procedures with specified execution methods, timelines and penalties, while the second, to be returned seasonally, is the collection of the list of subcontractors with related specific information useful for the risk analysis.
The Procedure will be adopted and fully implemented starting from 2023 and all manufacturing suppliers will be required to follow this Procedure.
F. OUR MODEL 231
In order to comply with the requirements of Italian Legislative Decree no. 231 of 8 June 2001 (“Decree”), our Italian operating company has validated and adopted for the Organization, Management and Control Model (“Model 231”), which describes in an organized form the rules, procedures and behavioural rules aimed at mitigating the possibility of illicit conduct occurring in the company, and in particular the crimes included in the Decree. In the broader framework of Model 231, the company has continued the application of the Code of Ethics, which summarizes the rules of conduct and general ethical principles and which, therefore, constitutes a fundamental reference that suppliers, consultants and all those who have relations with our Italian operating company are called to scrupulously respect.
7. OUR EFFECTIVENESS
Our supply chain mapping exercise is the key to identifying the extent of our supply chain and increase transparency of upstream processes. By identifying suppliers and partners in our supply chain, we can effectively engage them in our sustainability initiatives and share our Due Diligence Questionnaire, which will enable us to assess any risks associated with modern slavery and human trafficking. Therefore, a supplier and sub-supplier analysis was conducted with the aim at mapping first and second tier suppliers, which perform external production activities, and whenever applicable, certification and relevant documentation to supply chain risk assessment were collected. To date, we have mapped and continue to monitor all of Tier 1 and also, we are continuing to improve mapping and assessment of key Tier 2 and some sub-suppliers.
Our Modern Slavery Pack and our contractual modern slavery compliance provisions are the first tools we deploy to raise awareness and to hold our suppliers and partners accountable for their own supply chains over which we have no direct control or contractual connection.
Through our Due Diligence Questionnaire, we can assess suppliers and partners, identify the risk areas, recommend improvement action where appropriate and monitor progress annually. At present, the DDQ is deployed to new and existing partners and suppliers who supply us with our finished products either during the on-boarding process or whenever a commercial relationship is renewed.
As we continue to progress with our supply chain mapping exercise, we intend to deploy our Due Diligence Questionnaire or the Materials Supplier Form to other branches of our supply chain we consider warrant prioritisation and further investigation from a modern slavery perspective, such as components suppliers and contractors who provide property, facilities and logistics services.
RISK ASSESSMENT AND RISK MANAGEMENT
We have continued to progress with our Workplace Conditions Assessment (WCA) Audit programme. WCA is a form of second party audit which can be considered an effective monitoring mechanism to periodically assess our direct supplier base and to gather more visibility of the lowest tiers, as each supplier audited shares their production sub-supplier list with us.
WCA audits involve an assessment of the conditions of the workplace at the factories in which we operate and are carried out by us with the assistance of our external assurance service provider at supplier facilities. The announced audit is designed, by way of example only, to investigate and assess the presence, or indicators, of child labour, forced labour, discrimination, harassment and abuse, as well as assess the adequacy of health and safety measures, and compliance with applicable employment legislation.
Although in the previous years the COVID-19 pandemic and government-imposed lockdowns have caused delays in our WCA Auditing plan due to restricted access to the facilities, the programme fully resumed in 2022. Manufacturers we have a direct commercial relationship have been periodically visited and are seasonally monitored through scheduled quality control inspections, audits, and during contract governance meetings by sourcing, production and CSR teams. It is worth mentioning that our Audit Plan has continued to expand including facilities located in Asia and manufacturing sub-contractors.
A total of 8 (eight) direct suppliers, 4 (four) sub-suppliers were audited by our external assurance service provider during 2022.
Furthermore, 1 (one) supplier notified us about the completion of audits (non-WCA) in 2022 performed using BSCI (AUDIT AMFORI BUSINESS SOCIAL COMPLIANCE INITIATIVES) ethical audit methodology, which encompasses all aspects of responsible business practice and promotes human prosperity as well as free and sustainable trade.
In conclusion, any specific risks we identify from the information collected from completed Due Diligence Questionnaires, annual modern slavery reports and during scheduled audits are addressed promptly and directly with the relevant supplier either through enhanced due diligence activities, remediation action plans, additional audits and/or, if appropriate, contractually.
The Ethical Training Programme, launched in 2021 by Vivienne Westwood LTD, continues to be fully incorporated in the Learning and Development programme for new starters in the UK that have passed the probation period. The Ethical Training Programme includes 4 online courses: Anti-Bribery, Diversity and Inclusion, GDPR and Modern Slavery. Specifically, the Modern Slavery online course provides employees with a broad overview of modern slavery legislation, explanations and examples of each modern slavery offence, guidance on how to spot warning signs and high-risk situations and a test to maximise information retention.
During this financial year:
- A total of 27 new employees in the UK have completed the course successfully by 31st December 2022 reaching the pass rate of 80%;
- A total of 35 employees based in Italy have completed successfully the course provided by our Italian operating company.
Furthermore during 2022, an “Advanced Training on Forced Labour in Global Supply Chains” has been developed in collaboration with a US University and deployed to key departments in Vivienne Westwood who require a deeper understanding of modern slavery to readily identify the related risks in our supply chain. Starting from the second half of 2022, a total of 20 employees of different teams in Italy received credentials to complete the course, which will be extended to the UK team in 2023.
As we consider further strategies to raise awareness on modern slavery risks and engage suppliers in our mission, we began the roll-out of Modern Slavery online training course to direct suppliers based in Italy in 2021 and encouraged them to offer it to their employees and managers to equip them with information and skills to manage the modern slavery risk to their own business. So far 58% of direct suppliers located in Italy have completed the online training supplied by our Italian operating company.
9. LOOKING AHEAD
We remain committed to playing our part in combatting modern slavery and will continue to take steps to prevent the formation of any conditions where modern slavery or human trafficking could occur within our business and supply chain. We will continue to monitor any risks to our operating model, workforce and suppliers and regularly measure the effectiveness of our activities. Below is a list of the activities we will aim to launch, progress and, if possible, complete next year. Based on that, we will devise Key Performance Indicators (“KPIs”) that can be used, at individual company and group company level, to benchmark our effectiveness and our progress as we continue to strive to achieve our mission and objectives.
Highlight the risks and impact of modern slavery in our business and supply chain to our employees and suppliers;
Continue to deploy our Due Diligence Questionnaire to suppliers and partners.
Map and understand our supply chains beyond our direct relationships.
Continue with the mapping of our supply chain and go further to map lower tiers.
RISK ASSESSMENT AND MANAGEMENT
Identify modern slavery risk areas in our business and supply chain
Continue to progress in auditing direct suppliers and sub-suppliers worldwide.
Continue to provide training to our employees, and guidance to our suppliers, on how to identify, manage and mitigate the risks of modern slavery in our business and supply chain;
Extend the advanced training to key departments based in the UK, who require a deeper understanding on modern slavery and human trafficking to readily identify the related risks.
Identify an independent organisation with whom we can partner to support us in our modern slavery mission and support local industries while ensuring that local employment laws in that jurisdiction are respected.
Engaging external companies and industry peers in our efforts to deliver best practice at supply chain level, including switching to renewable energy providers. Continue to seek partnerships with external experts, universities and research centres to develop new awareness initiatives and trainings.
We stand firm in our belief that we must remain flexible in our approach to combatting modern slavery in our business and supply chains as this is the key to adapting to the rapidly changing global landscape in which our supply chain operates. We also believe that a collaborative approach based on trust is essential to build long lasting relationships, to improve stability and best practices, and successfully implement and execute our due diligence strategy.
Approved by the board of directors of Vivienne Westwood Limited and signed on its behalf by:
Chief Executive Officer
This statement applies to the Vivienne Westwood Group and its UK subsidiary Vivienne Westwood Limited
Last update: June 2023