MODERN SLAVERY ACT 2015
HOBBS TRANSPARENCY STATEMENT
2019 (FY 2018-2019)
This statement is made in accordance with section 54 of the Modern Slavery Act 2015. It sets out the steps Hobbs has taken during the 2018/19 financial year (the 'Year') to prevent slavery and human trafficking from taking place in our supply chains or any part of our business. As well as the additional steps we plan to take in 2019.
About 150 years have passed since most countries banned slavery, yet millions of men, women and children are still enslaved. Contemporary slavery, as defined in the 1956 UN supplementary convention, takes many forms, including debt bondage, servitude, child slavery, forced labour and human trafficking. Anti-Slavery International defines modern slavery as exploitative labour that places one person in the control of another.
Slavery thrives on every continent and in almost every country, and is still prevalent in the fashion industry and other labour intensive industries.
Modern slavery is a violation of human rights where victims are denied their basic rights to dignity, freedom and security. Victims are trapped in a situation where they are often powerless and vulnerable, and therefore unable to leave because they are subject to deception, mental and/or physical abuse, threats and punishment.
Headquartered in London, TFG London is owned by The Foschini Group Limited ('TFG'), a leading publicly listed South African retail group. TFG first entered the UK market (forming TFG London) through the acquisition of premium womenswear brand, Phase Eight, in January 2015. Since then the premium womenswear brands: Whistles, Hobbs, Damsel in a Dress and Studio 8, have been added to the Group.
Each brand focuses on a different customer and their tastes, from contemporary designs at Whistles to timeless British style at Hobbs to elegant occasionwear at Phase Eight. Together, there are 200 UK standalone stores, 450 UK concessions, and 250 international stores, concessions and online partners.
TFG London employs 141 people who work across all brands, both in Head Office and retail concessions.
|LOCATION||NO. OF EMPLOYEES|
Due to supply chain complexities, each brand publishes their own Modern Slavery Statement, outlining the nature of their operations and supply chains. Providing an overview of the steps they have taken to combat modern slavery.
Founded in 1981, Hobbs is a premium British womenswear brand offering clothing, footwear and accessories. Acquired by TFG London in 2017, Hobbs joined a portfolio of premium clothing brands including Phase Eight and Whistles.
Based in the UK, Hobbs is headquartered in London along with its Distribution Centre and has a strong retail presence. Hobbs operates in 10 territories with 51 UK & ROI and two international standalone stores, plus 117 UK and 48 international concessions.
Hobbs employs 1,166 people as detailed below:
|LOCATION||NO. OF EMPLOYEES|
|Retail Sites (UK & ROI)||841|
|Intl. Retail Sites||58|
|Hobbs Italian Shoe Factory||33|
Hobbs manufactures its own brand product through a global network of 79 external suppliers in 106 production sites. Hobbs sources its raw materials through the same network and in-house.
In addition to its external network, Hobbs operates its own Italian shoe factory, employing 33 people.
Hobbs top five sourcing countries are: China, Turkey, Romania, Italy and Macedonia. Representing 80% of purchasing volumes delivered in 2018.
Hobbs is committed to ensuring its supply chains promote safe, fair and legal working conditions. We expect our business, suppliers and third party brands to abide by local laws, international labour and human rights standards in all countries that we and they operate.
Our supply chain is divided into two channels:
Hobbs’ non-stock products and services are managed by its procurement team and supported by the CSR & Sustainability team, as well as the Legal team. Services include logistics, facilities maintenance, catering and cleaning.
Hobbs own-brand products are designed and developed at its headquarters in London, and manufactured through an established global network of external suppliers.
Hobbs sourcing landscape is collaboratively managed by the Buying, Technical, Merchandising and Design departments with the support of the Corporate Social Responsibility (CSR) and Sustainability team, collectively referred to as the sourcing team.
In October 2018, TFG London introduced a CSR & Sustainability team to establish an ethical trade and sustainability strategy. With an independent viewpoint, the team support the wider sourcing team to ensure all own-brand product, raw material suppliers and third party brand partnerships, are selected on ethical and sustainable merit in addition to commercial requirements.
Hobbs supply chain is defined as follows:
|1||Main Production Sites||A factory that cuts, maks and trims Hobbs products, shipping directly to Hobbs.||Mapped|
|2||Primary Production Subcontractor||A provider of one or more processes such as stitching, cutting, packing and QC, shipping directly to Hobbs.||Mapped|
|3||Secondary Process Contractor||A provider of one or more processes such as stitching, cutting, embroidery, dyeing, packing and QC, shipping directly to Hobbs.||Not Mapped|
|4||Fabric & Components||Fabric mills, tanneries and providers of hardware and trims.||Not Mapped|
|5||Raw Materials||Textiles, fibres, natural and synthetic materials.||Not Mapped|
As part of Hobbs evolving ethical trade efforts, this year the business has adopted operational policies at group level, with the view of respecting, protecting and remedying the human and labour rights of all that work on our behalf. The group policy strategy is based on the UN Guiding Principles on Business and Human Rights (UNGPs) and the ETI Human Rights Due Diligence Framework.
Hobbs core policies relating to our commitment to adopting the UNGPs, to benefit all those who work on behalf of Hobbs are: Supplier Code Of Conduct, Migrant Workers Employment Policy & Implementation Guidelines , and the Young Worker & Child Labour Policy.
Hobbs Supplier Code Of Conduct is aligned with the Ethical Trading Initiative base code, with elements of the SA1000 Standard:2014. It outlines the minimum social and environmental standards we expect each factory to meet and our expectations regarding the conditions in which our products should be manufactured.
Our Migrant Worker Employment Policy and Implementation Guidelines set out the supplier requirements to protect, respect and remedy the rights and welfare of migrant and contract workers, some of the most vulnerable to exploitation and modern slavery. Within this policy, Hobbs endorses the Employer Pays Principle, which reflects the Dhaka Principles For Migration With Dignity.
Our Young Worker & Child Labour Policy prohibits the recruitment of child workers in our supply chains and outlines remediation guidelines.
Finally, other policies that are also related to the prevention of modern slavery are our Anti-Bribery Policy, Whistleblowing Policy, Equal Opportunity Policy and our Compliance Handbook.
Hobbs is currently issuing its core policies to suppliers and this is due for completion in June 2019.
The Managing Director and the Hobbs Board of Directors are responsible for ensuring Hobbs meets its human rights responsibilities. They are supported by the CSR & Sustainability team and sourcing team.
Hobbs faces human rights risks in its supply chain and as such, we have identified key elements that pose risks of modern slavery. These include migrant labour, high presence of refugees, young workers and a risk of the use of child labour, contract and temporary workers, women workers and outsourced recruitment agencies.
We recognise our own operations may have one or more of these modern slavery risks and to gain greater visibility, we have mapped our non-stock suppliers. Areas such as logistics, facilities maintenance, catering and temporary workers are a priority area for Hobbs to expand its mapping efforts.
Hobbs endorses a holistic approach to its risk assessment and acknowledges that each area is part of a wider due diligence process that works to harmonise our approach. Our current risk prioritisation is focused on the manufacturing of our own brand products, and we've outlined below some of the steps we have taken to mitigate and manage human rights risks in our supply chain.
Mapping our supply chain is an essential piece of work in managing and mitigating risk. This year, with the support of the CSR & Sustainability team, Hobbs is revisiting and enhancing its mapping efforts. By detailing the labour landscape of our supply chain and obtaining key data about the workforce such as age, gender, migration, temporary and flexible working, and worker representation. Although we acknowledge that the nature of supply chains is to constantly evolve, we continue to work towards long-lasting and meaningful partnerships with our suppliers, enabling us to foster a culture of transparency and continue to map beyond tier one.
As an integrated business practice, all new suppliers are assessed based on their ethical credentials, in addition to commercial requirements. Suppliers are required to submit a Self-Assessment Questionnaire (SAQ) and sign up to our core policies (as detailed above). Together, these documents outline our expectations and requirements, and in return, allow us to review key labour practices. We also require a third party factory audit, verifying the information disclosed in the SAQ. Should an issue be present, this is highlighted to the sourcing team, lending to the overall sourcing decision and supplier strategy going forward.
In 2018 Hobbs became members of Sedex, utilising the platform to share and exchange audit data.
Since its acquisition in 2017 and as part of our ongoing risk assessment and sourcing strategy, Hobbs has benefited from its position within TFG London. Being able to exercise leverage and engage with other stakeholders, collaborating together to find common solutions to salient issues. This includes reviewing shared intelligence on modern slavery risks, how to manage and mitigate risks, and how to provide remedy in instances of abuse.
Hobbs has been a member of the Ethical Trading Initiative (ETI) since 2015, benefiting from a multi-stakeholder approach to collaborate, and actively participate in country specific working groups and initiatives to manage its assessment of risk.
In an effort to increase presence on the ground at factory level, this year Hobbs will adopt material used to engage with suppliers regarding their working environment and labour practices. The material is designed to raise awareness of the key elements that pose modern slavery risks, such as recruitment practices, employment types and skillsets, while capturing current practices and outlining recommendations where needed. Attended by the Technical team and supported by the CSR team, the material will be completed during a meeting and factory tour, allowing for a well-rounded collaborative approach, considering product type, production processes and general site management.
The Modern Slavery Act is an opportunity to embed a greater understanding of human rights within our supply chain and extend awareness internally. We are committed to improve our approach and this year Hobbs will launch an e-learning module covering modern slavery risks. This will be distributed across the wider business and sourcing team.
Hobbs is committed to advancing its approach to ethical trade and mitigating modern slavery risks.
This year we will continue to focus on transparency. Mapping third tier ‘secondary process’ suppliers and continuing to expand our mapping efforts for non-stock suppliers.
To advance our efforts on the ground, a representative from the CSR & Sustainability team will accompany the members of the sourcing team during factory visits. Directly engaging with suppliers on key elements that pose risks of modern slavery, while reviewing current working environments and labour practices.
Finally, Hobbs will develop KPIs, detailing the modern slavery risks we have identified, the steps we have taken to mitigate those risks and our future commitment. Publishing our findings in subsequent modern slavery statements.
This statement was approved by the Hobbs Board of Directors.
JUSTIN HAMPSHIRE, MANAGING DIRECTOR