Here at Cotswold Co, we take all forms of slavery and human trafficking very seriously. This is the second Modern Slavery Statement issued by the Cotswold Company in accordance with s54 of the Modern Slavery Act 2015.
Drawing on the Ethical Trading Initiative Base Code and the International Labour Organisation’s Forced Labour Protocol for guidance, in the past year we have continued to expand our work, ensuring we take action to address and effectively mitigate risks relating to Modern Slavery.
We remain steadfast in our commitment to preventing any form of Modern Slavery within our business and throughout our supply chain.
The Cotswold Company Ltd – who we are
The Cotswold Company is a multi-channel homewares brand that proudly champions a timeless, country-inspired lifestyle. With showrooms in the UK, logistics centres in The Midlands and offices in Norwich, China, and Vietnam, our supply chain, showroom network, and logistics footprint are continually expanding.
Whilst The Cotswold Co's Board of Directors hold responsibility for compliance with this statement, it is the Operations Director who takes day-to-day responsibility for compliance within the organisation and the supply chain. Our Senior Managers working within our warehouse, retail, sourcing and people departments will also ensure that both they and their staff all comply with this statement at all times too.
Supply Chain – who they are
We work with suppliers across the world, who are in line with our brand values, to bring beautifully made furniture at surprisingly affordable prices. We understand, given the scope and nature of our supply chain, that we do risk exposure to forms of modern slavery. That’s why we work diligently to identify where these risks are in our supply chain - allowing us to focus our efforts accordingly to both mitigate and eliminate them.
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We have a number of policies in place for all Cotswold Co employees to ensure that we are conducting business in an ethical manner.
Supply Chain Policies
We don’t just ensure these requirements are made in-house though, we also take a number of steps to guarantee our supply chain meets these important requirements too.
- Supplier Code of Conduct
All suppliers that we place orders with are required to make a contractual agreement guaranteeing that they will adhere to The Cotswold Company Ltd Ethical Sourcing Policy and all relevant local legislation. Where the two differ, we will always follow the policy that offers the greatest protection. If a supplier was to breach these terms, it offers us grounds to terminate the business relationship immediately.
- Supplier Ethical Data Exchange (Sedex)
All tier 1 suppliers are required to register to Sedex and complete the self-assessment questionnaire. By doing so, it will highlight any risks relating to labour standards, health & safety, environment and business ethics – therefore allowing us to make a well-informed decision.
We ensure that members of our U.K. based team visit all of our tier 1 suppliers at least twice a year. These visits allow us to identify any issues and work with suppliers to resolve any issues as quickly as possible. We also have locally based teams who frequently visit and work at the sites of our tier 1 suppliers. These handy placements provide us considerable insight into the supplier’s processes and the day-to-day conditions of the site.
The Steps We're Taking
We’ve made progress in a number of areas in the past year to improve visibility and minimise the risks associated to Modern Slavery within any supply chain that we have exposure to.
This policy clearly outlines our position on Modern Slavery and sets the minimum standards that we require all of our suppliers to comply with. Based on the International Labour Organisation’s ETI Base Code, this policy is designed to ensure ethical standards are maintained throughout our supply chain globally.
Our Due Diligence system has been developed to make sure we are constantly reviewing and updating information on our supply chains that helps us monitor and assess risks. A key part of this due diligence system is the Supplier Ethical Data Exchange (SEDEX). This platform allows us to review audit findings and run risk assessments based on the location and industry of the supplier. All new suppliers are required to complete a questionnaire that will highlight any possible areas of risk before a full SMETA audit is carried out. SMETA audits are one of the most commonly used social audits in the world. Through work with our suppliers we aim to have all Tier 1 suppliers audited before June 2020. In the past year we have audited 60% of our Tier 1 suppliers based in China and plan to have the remaining suppliers audited before the end of this financial year. Further to this we strengthen our due diligence with frequent visits to our suppliers by our U.K. based compliance and sourcing teams. All Tier 1 suppliers are visited a minimum of twice per year, during which time reviews are carried out of employee records, timesheets and working facilities.
Employee Awareness & Training
We recognise that the effectiveness of the above policies however, do rely heavily on the awareness and ability of our teams to identify these potential issues. We therefore ensure that employees who are directly involved in the supply chain have received training on how best to identify and address any possible breaches of our sourcing policy, with a focus on how to recognise signs of modern slavery.
Assessment & Effectiveness
As we grow, we will continue to review and develop all of these processes to ensure we adapt to any challenges that may arise in identifying ethical issues within our supply chain. It’s important to note that all the information collected from our suppliers is weighted and measured against key performance indicators that cover not only ethical but also environmental, management and quality standards too.
This statement has been approved by the organisation’s board of directors who will continue to review and publish it annually. It is signed on their behalf by our Chief Executive Officer,
CEO. The Cotswold Company Ltd