Modern Slavery Statement

Modern Slavery Act Statement

This statement has been published in accordance with the Modern Slavery Act 2015.  It sets out the steps taken by Northumberland Holdings Limited, administrators of Northumberland store (“we” or “our”) to prevent modern slavery and human trafficking in its business and supply chains during the year ending 31 December 2019.

Our Business

We have a zero-tolerance approach to modern slavery and human trafficking within our business and supply chains. We published our first statement last year and since then we have continued to increase our work in this area.

We are a retail company and and are part of the Northumberland Holdings (“Northumberland Holdings Limited”).

As a retailer, a key challenge is obtaining visibility across supply chains that we do not directly control but which are critical to us. We want more information about who, where and how the products which we sell are made, and we are committed to working with our partners and suppliers to make the sharing of this detail common practice. Like many organisations, another challenge we experience is the scale, diversity and decentralised management of our supply chain. In addition to product supply chains, we have goods and services not for resale supply chains, which are all managed by different teams across the business

Commitment to Human and Labour Rights

The Northumberland Holdings Group is committed to promoting human rights. The Northumberland Holdings Group acknowledges and recognises the:

• International Labour Organisation (“ILO”) Declaration on Fundamental Principles and Rights at work;
• ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy; and
• OECD Guidelines for Multinational Companies.

Further, our  Corporate Social Responsibility strategy has been defined in alignment with The an overall strategy which includes human and labour rights.

The steps taken so far are part of  our mission to meet our human and labour rights standards, with a specific focus on forced labour and human trafficking.

Policies

Our Anti-slavery and Human Trafficking Policy (“the Anti-slavery Policy”) reflects our commitment to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business and supply chains.  The Anti-slavery Policy sets out our zero-tolerance approach to modern slavery and human trafficking.  Every member of staff is expected to comply with the policy, which includes raising any concerns and using the appropriate reporting channels at the earliest possible stage.

We also operate a Whistleblowing Policy that encourages all staff to report any wrongdoing (including any breaches of the Anti-slavery Policy).  In particular the Whistleblowing Policy refers to a number of reporting tools designed to foster an environment of open, honest communication. All reports are fully investigated and remedial action and escalation to our board of directors follow if appropriate.

Supplier Code of Conduct

We have a long-standing approach to supply chain responsibility and so expect our suppliers to agree and adhere to our ethical standards for doing business. These standards require (without limitation) suppliers to:

• refrain from holding a person in slavery or servitude or requiring a person to perform any form of forced or compulsory labour;
• not arrange or facilitate the trafficking of any persons;
• not purchase materials or services from companies who use involuntary labour or participate in human trafficking;
• operate in accordance with the United Nations Universal Declaration of Human Rights (“UN UDHR”), and the fundamental human rights and labour rights as articulated by the International Labour Organisation (“ILO”);
• treat and reward employees equally on the basis of the characteristics of their work and the intensity of their effort;
• provide, while taking into account the specific dangers of the relevant sector, for safe, hygienic, and healthy working environments for their employees;
• provide, as a minimum, rates of pay at the national legal standards; and
• act in accordance with applicable national and regional laws and regulations at all times.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff where relevant.

Due Diligence Processes

We have in place systems to:

• identify and assess potential risk areas in our supply chains (where appropriate);
• audit prospective suppliers (where appropriate);
• mitigate the risk of slavery and human trafficking occurring in our supply chains; and
• protect whistle blowers. 

Our Effectiveness in Combating Slavery and Human Trafficking

We review our policies and procedures on a regular basis to ensure on going compliance.  The Business Assurance team regularly audits and assesses the business to ensure and assess compliance.  The results from these audits assist us in measuring how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.

Further Steps

As an organisation, we are committed to building on what we do each year to prevent modern slavery and human trafficking.  Following a review of the effectiveness of the actions we have implemented to date, we intend to take the following further steps to combat modern slavery and human trafficking:

1. Expand the audit requirements of prospective suppliers (where appropriate).
2. Refine the regular audits undertaken by the Business Assurance team.
3. Increase internal awareness on identifying and responding to incidents of modern slavery and human trafficking.

This statement was approved by the board of directors on 6 February 2019 and is made pursuant to section 54(1) of the Modern Slavery Act 2015.