TFG BRANDS (LONDON) LIMITED modern slavery statement summary (2022)

Organisation address
41 Lothbury,
London,
United Kingdom,
EC2R 7HF

We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.

This statement provides information for all 6 recommended topics

What is a modern slavery statement?
UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains. Read more in the government guidance on publishing modern slavery statements.
Link to full statement
Go to full modern slavery statement on organisation’s website

PDF version of the statement (optional)

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About this statement summary

All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.

Contents

Organisations covered by the statement

TFG BRANDS (LONDON) LIMITED modern slavery statement for 2022 is a group statement covering 4 organisations. See the full list of organisations covered by this statement

Statement period and sign-off details

The statement covers the following period:
1 April 2021 to 31 March 2022

The statement was signed off by:
Justin Hampshire (Chief Executive )

It was approved by the board (or equivalent management body) on:
30 September 2022

Recommended topics covered by the statement

Government guidance encourages organisations to cover a range of topics in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended topics in the statutory guidance.

We asked the organisation to tell us which topics its statement covers.

Topics recommended by government guidance Organisation’s response
The organisation’s structure, business and supply chains Covered
Policies Covered
Risk assessment Covered
Due diligence (steps to address risk) Covered
Training about modern slavery Covered
Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time Covered

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

  • Fashion, textiles, apparel and luxury goods

Turnover

Its turnover in the financial accounting year of this statement was:

£100 million to £500 million

If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.
What does 'turnover' refer to in group statements?
If this is a group statement, this includes the total turnover for all the organisations covered by the statement.

Number of years producing statements

The organisation has been producing modern slavery statements for the following number of years:
1 to 5 years
How does this work for group statements?
If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.

Policies (optional)

We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.
Policy provisions we asked about Organisation’s response
Freedom of workers to terminate employment Included
Freedom of movement Included
Freedom of association Included
Prohibits any threat of violence, harassment and intimidation Included
Prohibits the use of worker-paid recruitment fees Included
Prohibits compulsory overtime Included
Prohibits child labour Included
Prohibits discrimination Included
Prohibits confiscation of workers' original identification documents Included
Provides access to remedy, compensation and justice for victims of modern slavery Included
Other
Not included

Training (optional)

We asked the organisation whether it provided training on modern slavery, and who it was for.
What counts as training?
We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks. This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.
We asked who the training was for Organisation’s response
Your whole organisation No
Your front line staff No
Human resources Yes
Executive-level staff Yes
Procurement staff Yes
Your suppliers Yes
The wider community No
Other
3rd-party distribution center

Monitoring working conditions (optional)

Engaging with others

We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.
We asked who the organisation engaged with Organisation’s response
Your suppliers Yes
Trade unions or worker representative groups Yes
Civil society organisations Yes
Professional auditors Yes
Workers within your organisation Yes
Workers within your supply chain No
Central or local government Yes
Law enforcement, such as police, GLAA and other local labour market inspectorates No
Businesses in your industry or sector Yes

Social audits

We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.
What are social audits?
A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains. By their nature, audits of supplier workplaces represent a snapshot in time.
Social audits we asked about Organisation’s response
Audit conducted by your staff No
Third party audit arranged by your organisation No
Audit conducted by your supplier’s staff No
Third party audit arranged by your supplier Yes
Announced audit No
Unannounced audit Yes

Grievance mechanisms

We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.
We asked if workers could raise concerns this way Organisation’s response
Using anonymous whistleblowing services, such as a helpline or mobile phone app Yes
Through trade unions or other worker representative groups Yes

Other ways of monitoring working conditions

We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:
Organisation’s response
The organisation did not answer this question.

Modern slavery risks (optional)

Warning Identifying modern slavery risks is a vital step towards eradicating it. The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.
We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.

Priority risks for this organisation (1 of 3)

Migrant workers paying recruitment fees who might be trapped in bonded labour and be subjected to substandard employment terms.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 1 suppliers
    Provide their products and services directly to your organisation.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
  • Refugees
In which country Organisation’s response: Mauritius
Actions or plans to address this risk Organisation’s response: TFG Brands has conducted an extensive impact assessment of our Mauritian factory, established a migrant workers policy, supported suppliers in implementing the ‘employer pays principle’, Lobbied Mauritian and Bangladeshi governments to address worker protection, collaborated with peers and MSIs, as well as supporting the establishment of a Migrant Resource Centre in Mauritius.

Priority risks for this organisation (2 of 3)

Refugees & displaced workers from Ukraine entering supply chains, venerable to exploitation.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 1 suppliers
    Provide their products and services directly to your organisation.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
  • Refugees
  • Children
In which country Organisation’s response:
  • Bulgaria
  • Lithuania
  • North Macedonia
  • Romania
Actions or plans to address this risk Organisation’s response: As events unfold, we have enhanced our due diligence measures to monitor our existing supply chains in Ukraine’s neighbouring countries, to prevent and mitigate human rights risks and impacts in these regions as a result of the huge influx of refugees and displaced people. We will continue to evaluate the situation and are in communication with relevant stakeholders and strategic partners on the actions we are taking.

Priority risks for this organisation (3 of 3)

Uyghur forced labour in the Xinjiang Uyghurs Autonomous Region.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 1 suppliers
    Provide their products and services directly to your organisation.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
  • Refugees
  • Children
In which country Organisation’s response: China
Actions or plans to address this risk Organisation’s response: TFG Brands are active member signatories of the Coalition to End Forced Labour in the Uyghur Region. As such, TFG Brands has implemented a policy banning Xinjiang cotton and if the supplier was sourcing from Xinjiang, they planned a gradual exit. TFG Brands continues to accelerate its enhanced HRDD due diligence in this country, alongside key peers and expert partners.

Indicators of forced labour (optional)

We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.
What are ILO indicators of forced labour?
The International Labour Organization (ILO) has produced a list of the most common signs of forced labour. They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’ More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour
ILO indicators we asked about Organisation’s response
Abuse of vulnerability Yes
Deception Yes
Restriction of movement Yes
Isolation Yes
Physical and sexual violence Yes
Intimidation and threats Yes
Retention of identity documents Yes
Withholding of wages Yes
Debt bondage Yes
Abusive working and living conditions Yes
Excessive overtime Yes
Other
-

Actions taken in response to finding ILO indicators

We asked the organisation to tell us whether its statement refers to any actions it took after finding indicators of forced labour
Actions we asked about Organisation’s response
Financial remediation, including repayment of recruitment fees Yes
Change in policy Yes
Change in training Yes
Referring potential victims to government services Yes
Supporting victims via NGO Yes
Supporting investigations by relevant authorities Yes
Other
-

Demonstrating progress (optional)

We asked the organisation how its statement demonstrates progress over time in addressing modern slavery risks. They provided the following answer:
Our statement outlines each modern slavery risk, the steps we have taken, our commitment and a progress update for the reporting year vs the previous year