Card Factory plc - Modern Slavery Act 2015
Annual Compliance Statement 2018
Card Factory recognises the importance of conducting its business and managing its supply chain responsibly to mitigate the risk of slavery and human trafficking being present. We take this responsibility seriously and our policy is not to do business with any party that may directly or indirectly finance or benefit from slavery or human trafficking.
Our structure and business
Card Factory is the UK’s leading specialist retailer of greeting cards, dressings and gifts.
Card Factory focuses on the value and mid-market segments of the UK’s large and resilient greeting cards market, in addition to offering customers a range of complementary products associated with card giving occasions.
Card Factory principally operates through its nationwide chain of over 900 Card Factory stores, as well as through its transactional web sites: www.gettingpersonal.co.uk and www.cardfactory.co.uk.
Our retail business is predominantly UK based with a small presence in the Republic of Ireland. We have more than 7000 permanent employees and, during our peak trading period, employ an additional c6000 temporary employees to ensure we are able to meet the needs of our customers.
Our supply chain
Our supply chain includes buying agents, third-party manufacturers and distributors, logistics partners, our own, UK based, manufacturing facility and our distribution centre.
The majority of the greeting cards we sell in our stores are designed and manufactured within the Group in the UK. This vertically integrated model provides us with more direct control of this part of our supply chain.
The vast majority of the other products we sell in our retail stores and online are sourced directly from overseas suppliers based outside the EU.
We take reasonable steps to mitigate against the risk of slavery or human trafficking occurring in our supply chain or in any part of our business. We have implemented an Ethical Trading and Anti-Slavery policy which underpins our commitment to operating ethically and supplements the steps we already take in this regard.
In spite of the steps we take, there remains a risk that third-parties and supply chain partners may outsource manufacturing or the provision of services to us without our knowledge or consent, impacting our ability to mitigate against the risk of slavery or human trafficking. Where this comes to our attention we will promptly take appropriate steps to ensure this does not expose our business to additional risks.
Our procedures and due diligence
Our retail business and UK manufacturing facility
Our retail business is predominantly UK based with a small presence in the Republic of Ireland. Additionally we have a UK manufacturing facility which prints the majority of our greeting cards.
- Our policies and procedures ensure we comply with all laws covering the employment of our colleagues, their working conditions and environment.
- Our recruitment and ongoing employment processes mitigate the risk of slavery and human trafficking in the UK. We adopt fair employment practices within our workforce and our policies and procedures support these.
EU Based Suppliers of stock and services
Products from our UK and EU based suppliers represent a small proportion of the products we sell and, in mitigating risks relating to these, we seek to deal with reputable suppliers who have their own assurance procedures in place and do not currently conduct our own audits.
Overseas Suppliers of stock
The vast majority of the other products we sell are sourced directly from overseas suppliers based outside the EU.
For these products our assurance programme comprises:
- pre-engagement desktop due diligence for new suppliers which typically includes identity verification, confirmation of manufacturing facilities being used, obtaining Modern Slavery Declarations and requesting copies of any applicable accreditations and audits;
- a factory audit programme for all key suppliers using reputable third party audit firms (irrespective of any existing audits);
- technical audits (ISO9001 standard) and ethical audits (SA8000 standard) with ethical audits specifically addressing the ages of staff, remuneration, working conditions, working hours and health and safety;
- a managed programme for dealing with audit failures and any material issues raised in audits; and
- periodic visits by our own sourcing teams.
We also source some products through established trading companies and buying agents in the Far East and have adopted a formalised Trading Partner Statement which provides assurances from our partners that suppliers they engage are complying with applicable laws and regulations governing the employment of their staff and that they are taking all reasonable steps to mitigate the risk of slavery and human trafficking in their own supply chains.
What we’ve achieved during the last year
Last year we set ourselves objectives that would supplement the steps we already take to mitigate the risk of slavery and human trafficking being present in our supply chain. We’ve managed to achieve all of those objectives and during the last year have:
- formally adopted our Ethical Trading and Anti-Slavery policy and sought assurance from all of our key product suppliers that they will adhere to this;
- provided training to our sourcing and property teams to ensure they understand our obligations and to provide practical guidance on what they should be looking out for on a dayto-basis; and
- de-listed from our active supplier list, any suppliers outside the EU, with whom our purchases had previously exceeded £50,000 pa, who failed audits and did not take appropriate remedial action.
Our continuing commitment and objectives for the next year
We remain committed to developing long-term relationships with product suppliers who share our commitment to eradicating slavery and human trafficking and whose business practices are responsible and ethical. In support of this we will continue to take all reasonable steps to develop our supply chain management procedures and our supplier audit programme to give assurance to our stakeholders that we take our commitment seriously.
During the course of the next year we intend to:
- introduce a short-form audit for suppliers with whom our purchases are less than £50,000 pa (small and one-off usage suppliers) that covers key technical and ethical aspects including a social evaluation;
- rationalise the number of trading companies and buying agents we use to source products and, where we continue to use trading companies, introduce appropriate technical and ethical audits for the suppliers and manufacturers they engage with;
- adopt a “no audit, no order policy” for all product suppliers outside the EU; and
- review and supplement the training we provide our teams across the wider supply chain in the areas of modern slavery, ethical trading, supplier audit policies and anti-bribery and corruption.
Approved and adopted by the Board of Card Factory plc on 18 July 2018
Karen Hubbard – Chief Executive Officer