Modern Slavery Statement
Modern Slavery Act 2015 Introduction
The Modern Slavery Act 2015 (‘the MSA’ or ‘the Act’) requires UK companies to promote ethical business practices and policies to protect workers from abuse and/or exploitation by their organisation and global supply chains.
The Act specifically requires all businesses with annual revenues of over £36million to publish a transparency statement setting out the steps taken to ensure there is no modern slavery in their own business and their supply chains.
In October 2017, the Home Office published further guidance ‘Transparency in Supply Chains etc., A Practical Guide’ (‘the Guidance’), under Section 54(9) of the Act, which provides further clarification of how companies are expected to comply with the Act, and also reaffirms the importance of an effective response from UK businesses to the threats and risks posed by modern slavery.
About Four Group
Four Group (Four (Holdings) Limited and subsidiary companies) is a privately owned luxury fashion retail group comprising ownership and distribution of luxury fashion brands.
This statement applies to all subsidiaries of the company with an annual turnover in excess of £36m per year, which carry on business in the UK.
Our supply chains include direct and indirect relationships with household name international brands, staff agencies, buying agents, shipping partners, third party factories and licensees in the UK and elsewhere.
Our Policies on Modern Slavery and Human Trafficking
We have a zero tolerance approach to modern slavery and human trafficking and we are committed to eradicating modern slavery and human trafficking (including child labour) occurring in our business.
We take all reasonable steps to effect necessary change in our supply chains, acknowledging that it is an on-going challenge to ensure consistent visibility and enforcement of policies which virtually all businesses dealing in consumer goods are facing.
We are committed to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls aimed at reducing the risk that modern slavery or human trafficking is taking place anywhere in our business or supply chains.
Due Diligence Processes in 2021/2022 for Modern Slavery and Human Trafficking Within the Group
As part of our overall drive to identify and mitigate the risk of modern slavery and human trafficking, we monitor our supply chain on an ongoing basis in order to:
Highlight and address potential risk areas in our business and supply chains, including through contractual provisions.
Monitor potential risk areas in our supply chains, including through audits.
Notify and work with relevant authorities when any instances are believed / suspected to have occurred.
Across our Wider Supply Chain
We have continued to engage with our suppliers to ensure that as far as is reasonably possible all those in our supply chains and contractors comply with our values.
A large proportion of our supply chain comes via major third party brand suppliers with equally mature and publicised transparency statements in relation to modern slavery and human trafficking risks. We have a long standing relationship with our two largest supply chain companies.
Where the group engages directly with 3rd party factories producing goods for owned brands, the group monitors and works closely with those suppliers to ensure that compliance with applicable standards.
In an effort to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, training on relevant topics is accessible to staff. Our organisation also encourages an ‘open door’ policy for staff to put forward any information regarding potential modern slavery incidents or concerns, and we encourage our supply chains to provide equivalent relevant processes for their staff and their suppliers.
1. To maintain the Group’s zero tolerance approach to modern slavery and human trafficking;
2. To continue to build awareness of modern slavery risk and mitigation measures through the staff training already offered;
3. To further strengthen the Group’s monitoring and assurance processes;
4. To engage with more of our suppliers to seek confirmation of adherence to our requirements
5. To further strengthen and enforce our mitigation procedures and policies for modern slavery related risks.
Our Assessment of Modern Slavery Risk
The Board of Four Group are mindful of the ongoing risks, impacts and costs of global slavery and human trafficking. We are committed to conducting our operations with honesty and integrity, and with respect for human rights and the interests of our employees and shareholders.
We fully support both the original principles of the MSA and the Guidance published in October 2017.
The Group actively maintains a zero tolerance approach to slavery and trafficking in all its forms, in any part of its business or supply chain, continuing to apply the UN Guiding Principles on Business and Human Rights and core labour standards set out by the International Labour Organisation. The Board oversees our approach to addressing modern slavery through our governance and risk frameworks.
The Board is kept informed of any material issues or developments in this area and has approved this Transparency Statement.
As outlined above, we have continued to review and assess the risk of modern slavery in our business and supply chains, taking into account the Guidance. Based on this, we are satisfied that Four Group, its operations and supply chain are materially ‘low risk’ in terms of actual instances of, and the potential for slavery or trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group's modern slavery and human trafficking statement for the financial year ending 24th April 2022. This statement has been approved by the Board on 20th April 2022. As part of the Group's commitment to transparency, this statement will also be published on TISCreport.org and modernslaveryregistry.org.