As a business we take seriously our responsibility to operate ethically. Respecting human rights is a fundamental part of our business.

Outlined below is our position on slavery and human trafficking.

This is our fourth Modern Slavery Statement and sets out 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 in the last 12 months; 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.

About Superdry

We design, produce and sell clothing and accessories globally under the Superdry brand.

At Superdry we focus on high quality, contemporary products with a strong link between our brand values and our product attributes: design detail; quality obsession; end-to-end innovation; and affordability.

Our products are:

  • Designed at our head office based in the UK.
  • Manufactured through third party suppliers globally.
  • Sold globally through our stores, through e-commerce sites and through our wholesale customers.

These activities are co-ordinated by a global team of almost 5,000 employees and a network of trusted suppliers and business partners.

About our supply chain

Superdry works with apparel, footwear and accessory suppliers, the majority of which are based in India, Turkey and China. Our suppliers may choose to use subcontractors (also known as Tier 2) where specialist components are required or services needed which cannot be completed on these main production sites (Tier 1). Our suppliers’ source branded trims and labels through a network of nominated and sourced suppliers (Tier 3).

In September 2017 we announced our goal to use 100% organic cotton in all apparel by 2040. This goal is ambitious and will have significant impacts on extending visibility through our organic cotton supply chains. To achieve this we plan to establish dedicated organic supply chains, with fabric, spinning and ginning mill traceability. As a part of this we plan to establish risk assessment and monitoring in key sites to support our modern slavery strategy.

We also have a network of suppliers providing 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.

Our commitment to human rights and our Modern Slavery Policy

As an integral part of our commitment to human rights, 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.

Our Modern Slavery Policy applies to all colleagues, suppliers and business partners and requires them 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.

Our commitment to human rights is further re-enforced through all of our ethical trading policies, which are contained within our supplier manual, and all contracts from 2016 onwards contain a requirement to comply with it.

Our:-

  1. Ethical trading Code of Practice is based on international standards including the Universal Declaration of Human Rights and the International Labour Organization’s Core Conventions on Labour Standards.
  2. Migrant and Contract Worker Policy and Guidelines aim to protect vulnerable groups of workers by requiring ethical recruitment practices, appropriate conditions for accommodation, and effective communication of terms and conditions of employment.
  3. Subcontractor Policy aims to support ongoing mapping of our supply base, and to ensure our standards are actively communicated and supported within this tier. To date, this policy has been rolled out in factories producing 83% of our volume by number of units delivered.

All policies have been developed in consultation with organisations including the Ethical Trading Initiative, and local experts. Their ongoing development is managed by our ethical trading team, which is overseen by our Executive Committee and Board of Directors.

How we implement the Modern Slavery Policy

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 assist law enforcement agencies with the investigation, identification and prosecution of any party that knowingly engages in or facilitates slavery or human
trafficking.

1. Raising awareness for colleagues, suppliers and business partners

Our rolling training programme continues to support our cross business risk assessment and roll-out plan of our Modern Slavery Policy, with the view of completing this year’s training refresher sessions with all supplier facing colleagues by the end of September 2019.

2. Embedding human rights across our business

Superdry has a growing global team focused on human rights and wider sustainability.

This team manages our ethical trading programme as well as progress towards environmental targets.

We have established a number of mechanisms across our organisation to ensure human rights continue to be embedded in day-to-day business practice:

  • We have established robust ethical pre-approval processes for all main factory sites (Tier 1) and subcontracted units (Tier 2) to ensure we continue to work with the best possible partners.
  • We regularly audit 100% of main production sites (Tier 1) and their subcontracted units (Tier 2) on a semi-announced and unannounced basis. In the last 12 months we have started to enrol Tier 3 (trims and labels) into our ethical trading pre-approval processes, reaching 100% coverage in Turkey and India. We will be re-launching our China based subcontractor (Tier 2 and 3) approval processes in FY20 once recruitment of local ethical function is completed.
  • We risk assess human rights impacts within our business and supply chain and adapt our programme to ensure any issues are addressed. In the last 12 months we have reviewed how we grade factories using globally recognised risk assessment “equivalence” focusing on risk to worker wellbeing (severe, negative, neutral, positive), and scale of impact (isolated, widespread). Impact driven risk assessment will enable more effective response to issues in factory, trend monitoring and targeting of resources where they are needed.
  • We established dedicated local ethical trading experts in key source (China, India and Turkey) also covering satellite (Sri Lanka, Vietnam and Cambodia) countries to work closely with our suppliers’ factories and their subcontracted units.
  • We provide training and support for factories to remediate any issues where identified. We have extended our Women’s Change Alliance programme in India to reach 62% of women working in our supply chain. These women are trained on gender awareness, rights and empowerment in factory. The programme aims to establish functional grievance mechanisms, and we have since extended its scope to include targets for female representation at Supervisory Level.

We continue to collaborate alongside other Ethical Trading Initiative members to support
the development of best practice guidelines where industry wide risk has been identified.

3. Measuring the effectiveness of our ethical trading programme

We monitor the ongoing impacts of our ethical trading programme and report to our Executive Committee and Board of Directors regularly to provide continued oversight.

An update on targets set in the last financial year and the targets we are setting ourselves for the next financial year are set out below:-

FY Target Status
18 All supplier facing colleagues trained in head office on a rolling basis. Ongoing – all supplier facing colleagues to be trained by end Sept 2019.
18 Maintain ethical approval and monitoring processes for 100% of main production sites (Tier 1) and continue roll-out to achieve 100% for all subcontracted units (Tier 2).

Complete - India & Turkey

Relaunch planned in FY20 – China and SE Asia

19 Extend migrant worker assessment to all factories in India employing significant proportion of international migrant workers. Complete
19 Extend Tier 3 monitoring programme to 100% India based trims and labels sites, maintain coverage in Turkey. Complete
19 Complete full end line assessment for gender empowerment work in India and review possibility of extended to 40% of Indian factory base. Complete – 62% women in India Supply based included.
19 Support factory resilience and train all factories to ensure they have sufficient systems to support ethical conditions in Tier 2 and Tier 3 factories.

Complete – India and Turkey

Relaunch planned for FY20 – China and SE Asia

20 Include gender empowerment element into Farmer Engagement and Development programme for Organic Cotton. New for this year
20 Test and roll out Global Risk Assessment (equivalence)/grading processes for all ethical audits and due diligence processes using Product Lifecycle Management (PLM) system. New for this year
20 Establish due diligence processes at Spinning Mills utilised for Organic Cotton. New for this year

The above statement has been made pursuant to Section 54 of the Modern Slavery Act 2015 and California Transparency in Supply Chains Act of 2010 (SB657) and was approved and signed by Julian Dunkerton, Interim Chief Executive Officer, Superdry Plc (formerly SuperGroup Plc), on 9 August 2019.

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