It continues to be a priority for Superdry plc to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain.
Our FY22 Modern Slavery Statement sets out the steps taken by Superdry plc (which includes its wholly owned subsidiaries C-Retail Limited, DKH Retail Limited and SuperGroup Internet Limited) to ensure modern slavery does not take place in any part of our business and supply chain. We have updated our statement with progress made for the full financial year, between May 2021 and April 2022; our overall modern slavery strategy remains on track.
We review our approach on a regular basis and seek to continually improve through ongoing risk assessment, raising awareness of issues and requirements, and by delivering training to our colleagues and working in partnership with our suppliers and partners.
We design, produce, and sell clothing and accessories globally under the Superdry brand with a focus on high quality, contemporary and sustainable products. Our Group annual turnover was £609.6m.
Our products are:
These activities are co-ordinated by a global team of 4,038 employees and a network of trusted suppliers and business partners.
More information about Superdry, our organisational structure, group relationships and sustainability programme is available in our FY22 Annual and Sustainability Reports at corporate.superdry.com.
ABOUT OUR SUPPLY CHAIN
Superdry works with apparel, footwear and accessory suppliers based in China, India, Turkey, Sri Lanka, Vietnam, Cambodia, and Bulgaria.
Our suppliers may choose to use subcontractors (also known as Tier 2) where specialist components are required, or services needed, which cannot be completed in Tier 1 factories. Our suppliers source branded trims and labels through a network of nominated and sourced suppliers (Tier 3).
We also have a network of suppliers throughout our supply chain who provide goods not for resale and services to support day-to-day business operations, examples of which include transportation, warehousing, and store ancillary services.
We operate sourcing offices in key source countries, which function to support our suppliers in manufacturing our apparel, footwear, and accessories in line with our standards – from quality standards, through to compliance with our ethical standards including our Modern Slavery Policy.
Achieving full traceability throughout our supply chain is a core focus for Superdry as we recognise that the visibility of our indirect suppliers reduces as we move down the supply chain.
To tackle this, we work directly with over 90% of our factories, and with farm groups and raw material suppliers globally, who supply fully traceable organic cotton, down, and recycled fibres into our factories. In FY22, 47% of our product volume was certified to industry recognised standards to guarantee supply chain traceability.
Recognising that cotton is our largest and most high-risk raw material, we are committed to ensuring that all cotton will come from fully traced organic sources by 2030. In FY22, we have onboarded 7,508 smallholder farmers in-conversion into our supply chain, extending to over 12,000 farmers in FY23 and reaching 20,000 by 2025. This increases our visibility with our suppliers whilst providing opportunities to ensure our modern slavery policies are being implemented and complied with.
OUR MODERN SLAVERY COMMITMENT AND POLICY
The term modern slavery covers forced and compulsory labour, indentured child labour, servitude, human trafficking, debt bondage, deceptive recruiting for labour or services and similar violations. These are violations of human rights such as the right to be free from slavery, servitude or forced labour and the right to freedom of movement and other human rights, which are upheld by both international and national legislation.
We actively seek to ensure that our business, business partners and all parts of the associated supply chain are free from all forms of slavery and human trafficking. If at any point we suspect or identify any cases of modern slavery, we commit to support the remediation of any victims – working with business partners, other brands, governments, and NGOs as applicable. We also commit to assisting law enforcement agencies with the investigation, identification and prosecution of any party that knowingly engages in or facilitates slavery or human trafficking.
Our Modern Slavery Policy
We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. This information can be found in our supplier manual, which is provided to each of our suppliers during the onboarding process, and in all contracts from 2016 onwards.
Our Modern Slavery Policy and related policies upholding our commitment to eradicating modern slavery are accessible on our website and are reviewed and updated annually. The policy applies to all colleagues, suppliers, and business partners, and requires all parties to implement effective due diligence processes to enable us to understand and identify the potential risks of slavery and human trafficking so that we can report actual and suspected cases to the appropriate law enforcement agencies.
We also have the following policies in place relevant to modern slavery, which we continuously review and update:
All policies have been developed in consultation with organisations including the Ethical Trading Initiative (ETI), global experts in due diligence including Bureau Veritas, The Reassurance Network (India, Sri Lanka and Turkey) and Social Compliance Service Asia (Far East). Their ongoing development is managed by our Sustainability and Ethical Trading team, which is overseen by our Executive Committee and Superdry plc Audit Committee.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
We understand the heightened risk associated with complex supply chains, recognising that the risk of forced labour can go undetected.
As part of our initiative to identify and mitigate risk, we apply the following processes:
Continued assessment of current business partners
We continue our active membership of the Ethical Trading Initiative (ETI), which enables industry collaboration and supports the continued advancement of our Ethical Trading programme. Our programme, objectives and progress received positive feedback in Superdry’s annual ETI Progression Meeting, held in March 2022.
HOW WE ENSURE OUR MODERN SLAVERY POLICY IS ADHERED TO
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a rigorous supply chain compliance programme. This is achieved through a dedicated compliance team, which consists of involvement from our sustainability, audit and compliance teams.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide regular training to our staff. We also require our business partners to provide training to their staff, suppliers and providers.
To support our cross-business plan to raise awareness of our Modern Slavery Policy, 100% of Superdry colleagues completed Modern Slavery training in FY22. Furthermore, 100% of Superdry suppliers onboarded from 2020 have completed comprehensive induction programmes which include Superdry’s policies related to Modern Slavery. All suppliers onboarded prior to 2020 have received training on Modern Slavery outside of the induction process.
In addition to this, since 2017, it has been Superdry’s policy to ensure that contracts with business partners include our commitment to human rights and our modern slavery policy.
Superdry has a well-established global team focused on human rights whilst managing our ethical trading programme.
We have employed dedicated ethical trading experts, working directly with all suppliers across our Sourcing regions, with full global coverage and visibility of factory conditions. This structure allows us to respond to risks quickly as they emerge and is critical in negotiating and facilitating transparent risk assessments with factories by building partnerships locally.
Our dedicated ethical trading experts provide training and support to factories to help remediate issues identified during the risk assessment process. Our enhanced support programme, which is designed to provide the factories who need it with additional support in maintaining compliance with our Code of Practice, has been in place for two years.
The programme involves targets and milestones agreed between the supplier and Superdry leadership teams and local experts – additional training is then delivered by third party specialists, with regular visits to monitor improvement.
In FY22, 73% of factories enrolled in the programme succeeded in meeting agreed targets (equating to 8 factories).
We report to our Audit Committee twice a year to provide continued oversight of our policies and due diligence programmes.
Our risk management process, overseen by our Head of Risk and Internal Audit includes detailed updates on human rights and modern slavery risk – with reviews completed with the Head of Ethical and Sustainability on a quarterly basis. Further detail on this process is provided in our FY22 Annual Report, as is wider information on our governance processes.
We continue to review the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains and update/set new targets. Please note that the below table includes progress made against targets for FY22,our targets for the coming financial year, FY23 our medium-term goals to FY25. Historic targets are available in our archived statements.
The above statement has been made pursuant to the Modern Slavery Act 2015, the Australian Modern Slavery Act 2018 (Cth), and California Transparency in Supply Chains Act of 2010 (SB657) and has been approved by Superdry Plc’s Board of Directors on 17 October 2022. The statement is signed by Julian Dunkerton, Chief Executive Officer, Superdry Plc (formerly SuperGroup Plc), on 20 October 2022.