STONEMANOR LIMITED MODERN SLAVERY STATEMENT 2023/24

INTRODUCTION

Modern Slavery and human trafficking are gross violations of fundamental human rights. Stonemanor Ltd is committed to protecting human rights and the dignity of all persons within our global supply chain and implement and enforce systems and controls to ensure no forms of modern slavery occur.

The following statement has been published in accordance with the Modern Slavery Act (2015) and outlines the steps Stonemanor Ltd has taken during the financial year ending February 2024 to identify and prevent modern slavery and human trafficking from taking place within our business and supply chains.

(A) ABOUT US

From a single store in 2007 we’ve grown to 1200 retail outlets world-wide. We now have 17 Apricot standalone stores and 400 concessions across the UK and Ireland. Our host partners include New Look, Shaws, Browns and many other independent department stores. We also work with a number of wholesale and marketplace partners, including Next,Very, QVC and Zalando.

With over 800 outlets across Europe, the United States and Canada, we also have an expanding international portfolio.

Our creative heart is our head office in London, which houses our design, buying, retail, finance, HR and ecommerce teams. We have two distribution centres, with the UK hub in Bedfordshire supplying all UK outlets and the European hub in Greding, Germany serves our European concessions.

(B) SUPPLY CHAIN

We have well established, long-standing, business relationships with most of our suppliers. Our product is entirely “own label”.

We have invested in our own in-house production and development team. This enables us to trace the product back to raw material, as well as offering greater visibility to our supply chain.

We have about 30 core suppliers, that produce in over 70 factories across the globe. Biggest contributors, representing 95% of our range are suppliers, based in China, Vietnam, Romania, India and Morocco.

Our brand is also sourcing various GNFR (goods not for resale), such as logistics, security, IT, maintenance, marketing, ecommerce, cleaning, catering, advisory etc, mainly based in the UK and reaching over 160 vendors.

(C) POLICIES

Stonemanor has a collection of policies and documents that set our ethical and legal standards. These include the following:

1. Code of conduct
2. Whistleblowing
3. Anti-Bribery & Corruption
4. Ethical Sourcing Declaration
5. Supplier manual, including signed compliance with our declarations on ethical sourcing, as part of our shared commitment with our suppliers, factories and mills, to prevent modern slavery and human trafficking within our supply chain. This ensures that ethical labour standards are upheld, in line with the ILO and ETI, alongside regular third-party ethical auditing.
6. GNFR contracts. All GNFR goods & services are required to be fully compliant with the Modern Slavery Act. These policies define and guide workplace & employment standards as well as business conduct and apply to both our own operations and those of our business partners. The framework and policies are regularly reviewed to ensure that they are effective and capable of addressing new and emerging risks.

(D) DUE DILIGENCE

Due diligence is critical to the overall effectiveness of addressing risk and evolving our approach. In the last year we have followed through on the following steps:

1. Mapping all first-tier suppliers and business partners: Ensuring the terms of our supplier manual is being honored and all suppliers are registered with Sedex Global or BSCI.
2. Mapping 2nd and 3rd tier suppliers for in-house product, ensuring they are 3rd party audited. This includes dyeing houses, printing mills, weaving factories. Due diligence is critical to the overall effectiveness of addressing risk and evolving our approach.
3. Third-party audits: Our suppliers and factories are regularly audited. These audits include, but are not limited to, working conditions, health and safety, hours worked, wages and ability to leave work after working shifts.
4. We have introduced procedures to ensure our buying and quality control team review audit results regularly, follow up with suppliers and ensure there is full compliance with our supplier Manual.

(E) OUR COMMITMENT/ NEXT YEAR

Over the coming year we will continue to focus on our working practices and monitoring processes:

1. Training
   Induction process for new starters include information and initial training on modern slavery.
2. Furthermore, key personnel within the business will be trained on the risks of modern slavery annually, including the various forms modern slavery takes (e.g., forced, bonded and child labour) and country specific risks. Training and communication are another area we continue to work on to strengthen our efforts both internally and with business partners.
3. Mapping GNFR
   Continued mapping of our GNFR supply chain and risk assessment exercises.
4. Monitoring
   We continue to explore initiatives within each department to further reduce the risk of modern slavery. Developing new systems, and looking at integrated processes to ensure further compliance, where identified, as necessary. We will also continue to look at the ways we measure the performance of actions we take to combat modern slavery and human trafficking, to help us monitor how effective our practices have been.

Download PDF version of our statement

This statement was approved by the Directors of Stonemanor Limited.