Bedeck Group Modern Slavery And Human Trafficking Statement 2024

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Background

Section 54 of the Modern Slavery Act 2015 (‘the Act’) encourages increased transparency within businesses and supply chains. Section 54(1) of the Act places a statutory obligation on commercial organisations, in any part of a group structure, that supplies goods or services with a turnover of £36 million or more to publish a “slavery and human trafficking statement” for each financial year. Such an organisation has an obligation to publish a statement within 6 months of their year-end, indicating the corporate position, policies and due diligence in relation to modern slavery and human trafficking.

Bedeck Limited (‘Bedeck’ / ‘the Bedeck Group’) is an organisation that fully acknowledges our responsibilities in relation to ethical business activity and is committed to addressing any instance of modern slavery and / or human trafficking within our business or our supply chain. Our policies and our interaction with colleagues, as well as suppliers and customers, continues to reflect our commitment to acting ethically in all our operational matters. We continue to review our approach annually in accordance with the Act and continue to monitor such compliance with a view to continuous, iterative improvement both within our facilities and our supply chain.

Policy Statement

This is our fourth year of producing a modern slavery statement on behalf of the Bedeck Group. This statement is published in accordance with the Act and sets out the steps taken by the Bedeck Group during the financial year ending 30 September 2024 to seek to prevent modern slavery in our business and supply chains.

Our Business and Supply Chain

The Bedeck Group’s Head Office is based in County Down Northern Ireland and accommodates our design, sales, warehouse, administration and technical staff teams. We hold and distribute stock from this facility with over 100 colleagues onsite.

The Bedeck Group also operates over 50 retail stores and concessions located across UK and Ireland which employ over 200 employees.

The Bedeck Group’s supply chain currently comprises of the UK, Ireland, Portugal, India, Pakistan and China. Our supply chain is actively managed by our offices in Northern Ireland and by retained agents located in each country. Agents regularly visit factories located within our supply chain in order to review products and working conditions. Our agents feedback to Bedeck Group as required. This amounts to regular coverage of around 40 home textile facilities.

The Bedeck Group Ethical Approach

It is a priority for The Bedeck Group to ensure that we trade ethically, source responsibly and work to prevent modern slavery throughout our organisation and in our supply chain. The Bedeck Group respects and values its colleagues and expects our partners to do so as well.

We work hard to ensure that our supply chain shares our values and we prefer suppliers who have achieved recognised international standards in this regard such as Sedex Members Ethical Trade Audit (‘SMETA’), Responsible Down Standard (‘RDS’) or British Social Compliance Initiative (‘BSCI’).

Sedex is one of the world’s leading ethical trade membership organisations, working with businesses to improve working conditions in global supply chains. They provide an online platform, tools and services to help businesses operate responsibly and sustainably, protect workers and source ethically.

Bedeck are members of Sedex and through the membership Sedex provides an audit service called SMETA (‘Sedex Members Ethical Trade Audit’) which is the most widely used social audit tool in the world. SMETA enables businesses to assess their sites and suppliers to understand working conditions in their supply chain.

Most of the Bedeck Group’s suppliers are members of globally recognised organisations such as Sedex and have been for some time.

The Bedeck Group recognises the benefit of third-party regulators, but we do not rely exclusively on such and undertake our own due diligence on suppliers and business partners on an annual basis.

Bedeck Code of Conduct is sent to all suppliers and must be signed and returned before any orders are placed. This document details the standard of conduct Bedeck Ltd. requires from all of its suppliers in relation to the conditions under which goods are manufactured and supplied, including: Freedom of employment, Safe and hygienic working conditions, Zero child labour, Living wages are paid, Working hours meet national laws, etc.

Suppliers must also ensure that all sub-contractors meet these requirements.

Due Diligence

As part of our modern slavery due diligence, and in the last financial year, we have taken the following steps:

1. Undertaken a risk assessment by issuing a due diligence questionnaire to our top 7 and 3 new international suppliers across India, Pakistan, China and Portugal (which equated to coverage of 32% of total annual purchases).
2. Undertaken a risk assessment by issuing a due diligence questionnaire to our top 10 UK and Ireland suppliers equating to 16% of total annual purchases.
3. Used the Sedex online portal in order to assess the accreditation of suppliers as well as providing audit reports that the Bedeck Group has analysed to assess risk throughout the year.
4. Taken steps to assess and manage the risk identified including:
   1. Addressing any concerns from questionnaire responses or Sedex’s SMETA audit feedback with our suppliers; and

• 100% of staff in the Bedeck Group with roles managing suppliers in the higher risk areas we have identified have confirmed that either:

1. they have not discovered, nor been made aware of, any issues affecting their suppliers which might constitute modern slavery; or
2. any potential instances of modern slavery have been reported in accordance with our policies and procedures.

Training

Our external legal provider A&L Goodbody Northern Ireland LLP have provided advice and guidance in creating and maintaining appropriate policies as well as creating bespoke training materials for the Bedeck Group.

Last financial year, bespoke training on modern slavery and human trafficking was delivered to all members of the Sourcing team, Human Resources and to key members of the Marketing, Sales and Design team. The purpose of this training was to broaden our team members knowledge on the Modern Slavery Act 2015, what risk factors to be aware of and to provide guidance on how to address any concerns.

This training session was recorded so it could be delivered to any new employees joining the Bedeck Group.

The Bedeck Group’s Operations Manager also undertook training from our external legal provider on legislative developments regarding modern slavery across the United Kingdom, Northern Ireland and Europe.

Assessing and Managing Risk

1. Due Diligence Questionnaires

The Bedeck Group Board has analysed the responses from the 20 questionnaires issued to suppliers providing 48% coverage of Bedeck Group’s annual purchases. Responses received were as follows:

• 15 completed questionnaires were returned, including all 10 questionnaires issued to our international suppliers.
• 1 supplier sent their company policies in place of the questionnaire

There were no non-compliance issues or concerns raised by the responses received, but the Bedeck Group nevertheless proposed improvements to suppliers if required and followed up with the suppliers that did not respond.

1. Site Visits

Throughout this financial year, Bedeck team members have conducted site visits and inspections of key suppliers within the UK and Ireland. For example, multiple visits took place at suppliers in ROI and GB.

Internationally, Bedeck agents also regularly visit factories located within our supply chain and feedback to the Bedeck Group as required.

This practice allows the Bedeck Group to identify whether any modern slavery and / or human trafficking concerns are taking place within our supply chain and to address any instance identified appropriately.

Key Performance Indicators (‘KPIs’) and Continuing Our Approach in 2025

In order to continue to do all that we reasonably can to ensure that no modern slavery or human trafficking occurs within our supply chain, we intend to measure our performance against the following KPIs in the forthcoming financial year:

• (i). The number of suppliers completing our modern slavery audit questionnaire;

These indicators will continue to be reviewed over subsequent reporting periods and we will continue to review and enhance these KPIs and develop further metrics to assess the effectiveness of our actions, in line with continuous improvement.

In the forthcoming financial year, we intend to undertake the following:

• (i). Undertake at least three site visits to key suppliers to assess working conditions first hand. For example, we intend to conduct a site visit to suppliers in the Far East this year.
• (ii). Provide and facilitate training on modern slavery and human trafficking (either e-learning or in person) to all new start employees and ensure management and key employees are kept updated on legislative developments in relation to modern slavery.
• (iii). Implement a new Anti-Slavery and Human Trafficking Policy and conduct a review of the Group’s existing policies which relate to modern slavery issues.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 in relation to the financial year ending September 2024.

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30 September 2024