Card Factory plc - Modern Slavery Act 2015
Annual Compliance Statement
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. It focuses on the value and mid-market segments of the UK’s greeting cards market, and also offers a wide range of other quality products, including small gifts and gift dressings.
Card Factory principally operates through its nationwide chain of over 850 Card Factory stores, as well as through its online offerings: 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 are in the process of formalising 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.
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, requesting copies of any audits and workforce confirmations including working conditions, employee ages and legal pay rates;
- a factory audit programme for key suppliers using reputable third-party audit firms;
- separate technical and ethical audits where appropriate with ethical audits specifically addressing the age 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 factory visits by our own sourcing teams.
We also source some products through established trading companies and buying agents in the Far-East and we have sought assurances from our key partners that the 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 our own supply chains.
Our commitment and further steps
We are committed to developing long-term relationships with 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:
- formally adopt our Anti-Slavery policy which will supplement the steps we already take and seek assurance from all of our key suppliers that they will adhere to this;
- provide our sourcing teams with training to ensure they understand our obligations; and
- ensure that all suppliers outside the EU with whom our purchase exceed £50,000 pa have received separate ethical and technical audits commissioned by Card Factory.
Approved and adopted by the Board of Card Factory plc on 18 July 2017
Karen Hubbard – Chief Executive Officer