Slavery and Human Trafficking Statement 2018

Department Human Resources Author Rupert Hay
Version 3.0 Release Date: March 2018
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Crew Clothing Company Ltd and related companies has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Crew Clothing Company and related companies has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

1. Our business

Crew Clothing Company is a UK based multi-channel retailer operating 80 retail stores within the UK and a web based retail business supplying internationally. We have a considerable whole sale and events business operating in the United Kingdom.

2. Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
 • Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
 • Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
 • Code of conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

3. Our suppliers

Crew Clothing Company operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on site audits which include a review of working conditions. We are committed to complying with the act and we will ensure our anti-slavery policy forms part of our contract in the future with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract update with suppliers, we require that they confirm to us that:
 • They have taken steps to eradicate modern slavery within their business
 • They hold their own suppliers to account over modern slavery
 • They pay their employees at least the national minimum wage / national living wage (UK based only)
 • They pay their employees any prevailing minimum wage applicable within their country of operations. (International only)
 • We may terminate the contract at any time should any instances of modern slavery come to light.

4. Next Steps

In accordance with the act we for our 2018 statement will commit to the following:
 • Make all relevant staff aware of the act, its requirements including the definition of slavery and human trafficking
 • Reviewing and updating the supplier policy and manual to ensure compliance
 • Include monitoring of the act in our supplier visits
 • We will conduct training for our buying and sourcing teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking

5. Approval for this statement

This statement was approved by the Board of Directors on March 2018
Signed for and on behalf of Crew Clothing Company and related companies