Modern Slavery Policy

Policy Statement

 

This policy statement sets out LeMieux’s actions 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.

 

As a company, we recognise that we have a responsibility to adopt a robust approach to modern slavery. Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

 

Definition

 

Modern slavery is the severe exploitation of other people for personal or commercial gain and is a crime resulting in an abuse of the human rights of vulnerable people from both the UK and overseas.

 

Modern slavery can take various forms, including:
  • Human Trafficking: The process of trapping people through the use of violence, deception or coercion and exploiting them for financial or personal gain
  • Forced Labour: Any work or service which people are forced to do against their will, under threat of punishment. Almost all slavery practices contain some element of forced labour

  • Bonded Labour: Also known as debt bondage or debt slavery, it occurs when a person is forced to work to pay off a debt. They are tricked into working for little or no pay, with no control over their debt

  • Child Slavery: The enforced exploitation of a child for someone else’s gain, meaning the child will have no way to leave the situation or person exploiting them

  • Child Marriage: This can be referred to as slavery if the child has not genuinely given their free and informed consent to enter the marriage, if they are subject to control in the marriage (particularly through abuse and exploitation), or if they cannot realistically leave or end the marriage

  • Descent-based Slavery: Where people are born into slavery because their ancestors were captured into slavery and their families have ‘belonged’ to slave-owning families ever since

  • Domestic Slavery: Domestic workers in private homes where the circumstances and conditions of their work amounts to slavery e.g. their employer stops them from leaving the house, doesn’t pay their wages, uses violence or threats, withholds their identity documents, limits their contact with family and forces them to work

     

    Slavery in Supply Chains

     

    Long and complex supply chains make it challenging to oversee who is working where and under what conditions, from the extraction of raw materials, the manufacturing of goods or the shipping and delivery of those goods to customers. However, these are steps we shall take to challenge the potential of Modern Slavery in our supply chain.

     

    Slavery in the UK

     

    Modern slavery is present in every area of the UK and can take many forms. The most common form of slavery in the UK is forced labour, more often found on farms and in construction, shops, bars, nail salons, car washes or manufacturing.

     

    Our Commitment

     

    LeMieux has a zero-tolerance policy towards modern slavery and is dedicated to ethical, transparent business practices. It ensures compliance with the Modern Slavery Act 2015 through effective systems and controls to prevent modern slavery and human trafficking within its operations and supply chains. LeMieux is committed to fostering an inclusive society where people are treated with dignity and respect, and inequalities are addressed. LeMieux also expects the same high standards from its suppliers, contractors and other business partners.

     

    Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the company accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

     

    Responsibilities

     

    This policy applies to all individuals working for the company or on the company’s behalf in any capacity, including employees, directors, officers, agency workers, agents, contractors, consultants and business partners.

     

    Senior Management:
  • Ensure the implementation of this policy
  • Oversee due diligence processes
  • Review and update the policy as necessary
  • Ensuring those reporting to them understand and comply with this policy

     

    Employees:
  • Report any concerns regarding modern slavery either in person or by email to [email protected]. If neither option is viable then an online report can be made to the UK Government at Report modern slavery – GOV.UK
  • Adhere to the principles outlined in this policy

     

    Suppliers and Business Partners:
  • Comply with this policy and our Supplier Code of Conduct
  • Ensure their own supply chains are free from modern slavery
  • Comply with local and international laws and regulations
  • Adhere to their own Modern Slavery Statement

     

    Risk assessments:
  • Any potential risks would be highlighted by the annual audits undertaken by SEDEX/SMETA

     

    Investigations/due diligence:

  • Design, Buying, Technical & Compliance Departments

    In relation to tier one vendors, the Design, Buying, Technical & Compliance Departments undertake risk assessments prior to onboarding new suppliers and will monitor supplier sign up to SEDEX

     

    Will monitor SMETA audits and identify areas of non-compliance and take appropriate action to implement resolutions and monitor through to resolve

     

    Will visit or provide resource to visit factories in person and identify potential or suspected breaches of this policy

  • HR

    Implement and review this policy

     

    Provide training to employees on the risks of modern slavery, how to identify it and how to report concerns

     

    Provide a confidential medium for individuals to report or raise concerns without fear of retaliation, and investigate reports promptly and take appropriate action which may include providing support to the victim and reporting to the police and relevant authorities

  • Finance

    Will ensure the diligence of financial and payroll transactions and identify any irregularities in payments, costs structures or terms that may indicate breaches to this policy

     

    Countries of Operation and Supply:

     

    LeMieux commits to ensuring the rights and dignity of workers within our supply chain. We will actively monitor and enforce standards to prevent forced labour, exploitation, and unsafe working conditions, collaborating with suppliers to uphold these principles and promote a fair and humane work environment for all. We are employers in the following territories:
  • United Kingdom
  • USA
  • India

     

    The following is the process by which the company assesses whether particular activities or countries are high risk in relation to slavery or human trafficking:

     

    All Tier one vendors in the supply chain of our LeMieux own-brand products must be members of SEDEX and submit to third-party SMETA audits. These audits will assess that:
  • Workers freely choose employment
  • Workers have freedom of association and right to collective bargaining
  • Workers have working conditions that are safe and hygienic
  • Child labour shall not be used
  • Living wages are paid
  • Working hours are not excessive
  • No discrimination is practiced
  • Have regular employment provided
  • No harsh or inhumane treatment is allowed

     

    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. These policies can be found within the Employee Handbook.
  • Whistleblowing policy: we encourage all our employees 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
  • Bullying and harassment
  • Diversity, equity and inclusion
  • Anti-corruption and Bribery
  • Supplier Code of Conduct

     

    Compliance

     

    Preventing, detecting, and reporting modern slavery in LeMieux's business or supply chains is everyone's responsibility. Employees must avoid any activities that could breach this policy. Suspected breaches should be reported to a line manager or via the Company’s Whistleblowers Policy. All employees are encouraged to promptly raise concerns about potential modern slavery issues to [email protected]

     

    If anyone is unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, again it should be immediately raised. Matters can also be raised by contacting the government’s Modern Slavery Helpline on 0800 0121 700, who are able to provide further information and guidance on modern slavery.

     

    The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

     

    The Company’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.

     

    Supplier Compliance

     

    LeMieux is committed to ensuring that its suppliers adhere to the highest standards of ethics and adhere to LeMieux’s Supplier Code of Conduct. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.

     

    We work with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. Where areas of non-compliance are identified, we will support our suppliers to implement improvement plans and monitor through to resolution. Serious violations of our supplier code of conduct may lead to the termination of the business relationship.

     

    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
  • Evaluating the modern slavery and human trafficking risks of each new supplier
  • Conducting supplier audits or assessments through SEDEX & SMETA, which have a greater degree of focus on slavery and human trafficking where general risks are identified
  • Taking steps to improve substandard suppliers' practices, including providing advice to suppliers through SEDEX/SMETA/BSCI/QIMA and requiring them to implement action plans
  • Using SEDEX & SMETA where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular

     

    Training

     

    Heads of Department and Managers will undertake training on Modern Slavery to understand and respond to the identified slavery and human trafficking risks. This policy is available to all employees and will be covered during the onboarding and induction process for new employees. Training in the following topics in undertaken via online learning providers:
  • Understand the extent of Modern Slavery
  • Explain the 2015 Modern Slavery Act
  • Identify everyone’s responsibilities under the act
  • Defining Modern Slavery
  • How to report Modern Slavery
  • How to spot Modern Slavery

     

    Breach of the Policy

     

    Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

     

    The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to be involved in modern slavery.

     

    This policy is non-contractual, and the business reserves the right to make relevant changes to this policy to ensure compliance with legislative updates. Any changes will be communicated to our employees appropriately.

     

    The policy will be reviewed annually by the Senior Management Team to ensure ongoing relevance and compliance with emerging legislation and best practices.