Modern Slavery Act Transparency Statement

HACKETT is committed to ensuring that all workers involved in the production of any labelled products by its brands, wherever they may be located, are treated with humanity and dignity and all are entitled to their basic rights. This constitutes a non-negotiable commitment from HACKETT and shall be followed by all supplier partners and any other business partner that take part in the purchasing, manufacturing and finishing processes (henceforward, collectively referred to as “Partners”).

This Statement, made pursuant Section 54 of the UK Modern Slavery Act 2015, constitutes HACKETT’s Modern Slavery, Human Trafficking and Transparency in Supply Chain Statement for the Financial year 2020 (ended on 30 April 2021), and refers Hackett Limited and its respective subsidiaries (“HACKETT”).

HACKETT Policies in relation to slavery and human trafficking

HACKETT is committed to positive change, taking serious responsibility for the impact made on the environment and on human lives and seeks business partners that consider the broader impact of its activities on human rights and environmental issues within the community in which they operate.

HACKETT recognises that one of the main challenges faced by operating in a global market is the tight control of the supply chain. For that reason, HACKETT requires all Partners to involve themselves in the fight against human trafficking and slavery by subscribing to the AWWG’s Supplier Code of Conduct that outlines the objectives sought by the group to achieve together in the implementation of quality and quality standards, ethical business practices and operating procedures in our business. This Supplier Code of Conduct applies to any entity manufacturing merchandise under the HACKETT brand label.

Compliance with the terms of AWWG’s Supplier Code of Conduct is a requirement to be able to manufacture Hackett’ merchandise. Such compliance to be evidenced by agreeing to be bound by executing the Supplier Code of Conduct in the form provided by HACKETT. With it, partners agree that they have in place policies to monitor the facilities which manufacture HACKETT’ merchandise and that these are sufficient to ensure their compliance with the Supplier Code of Conduct and all applicable state, local and foreign laws and regulations pertaining to wages, overtime compensation, benefits, hours, hiring and employment, workplace conditions and safety, the environment, collective bargaining, freedom of association and that their products or and the components thereof are made without the use of child, prison, indentured, exploited bonded, forced or slave labour.

HACKETT’s partners shall take all necessary measures to implement and have the policies implemented and will ensure that all staff members comply with them. Consequently, partners acknowledge HACKETT’s right to carry out inspections and audits of its premises.

HACKETT fosters and its activities are based upon the following general principles that define HACKETT’s ethical behaviour.

1. No child labour: Partners recognize the rights of every child to be protected from economic exploitation and shall eliminate as a priority the worst forms of child labour according to the International Labour Organization (ILO) Convention nº 182. There shall be no recruitment of child labour.
2. Freedom of choice: Workers cannot be forced to work. Forced, bonded or involuntary prison labour will not be accepted.
3. No discrimination: There must be no form of discrimination in the hiring of workers, remuneration, access to training, promotion, and termination of the employment relationship or the retirement of the worker based on race, caste, national or social origin, ethnic origin, religion, age, disability, gender, marital status, sexual orientation, union membership, philosophical views or political affiliation, or any other condition that could give rise to discrimination.
4. No inhumane treatment: Body punishments, mental or physic constraints or verbal abuses won´t be applied or supported.
5. Freedom of association: No worker should be discriminated against or prevented from joining a trade union or to bargain collectively. Disciplinary actions against workers who choose to peacefully and lawfully organise or join an association are forbidden. Personnel must be informed about their right to join an organization of their choice and that their doing so will not result in any negative consequences to them.
6. Working hours: Working hours, whether ordinary working hours or overtime, must comply with all applicable laws and benchmark industry standards, whichever affords greater protection.
7. Working conditions: Partners must follow and comply all international, national and local laws and regulations relating to working conditions, including but not limited with laws relating to health and safety, sanitation, fire safety, risk protection, electrical fittings and appliances and the structure of premises, such as the Social Accountability Standard 8000.
8. Wages: All workers shall be paid no less than the minimum national (or local) legal wage or industry benchmark standards. Wages should be paid either on a weekly or monthly basis, without unlawful and unreasonable deductions. Hackett believes and endorses the living wage ideal. Wage should meet basic needs and provide some discretionary income.
9. Housing conditions: Accommodation for workers must meet all international, national and local legal requirements relating to health and safety and shall, in any event, be fit for dignified human habitation. The sleeping quarters must be clean, secure and must cover the basic necessities of the workers. Workers living in this accommodation must be free to enter and exit the premises, as can be reasonably permitted.

Steps Taken to Assess and Manage Risk

HACKETT monitors the compliance of the Supplier Code of Conduct and maintains and enforces internal accountability procedures for employees and contractors regarding company including the prohibition against forced or involuntary labour, and addresses any identified risks or violations. In the case of non-compliance, HACKETT reserves the right to examine the specific situation and develop a best possible strategy for resolution.

HACKETT conducts pre-sourcing compliance assessments before a supplier is allowed to produce for any of its brands, conducts regular communications audits once production begins and works closely with factories to remediate any identified deficiencies.

As mentioned above, and as part of our monitoring responsibilities, HACKETT conducts assessments of its suppliers based on standards found in the Social Compliance Program. With them, HACKETT encourages its business partners to assume in their responsibility for their labour practices and general compliance. Each assessment identifies areas for improvement and HACKETT works with factories to remediate the issues. HACKETT engages factory management in corrective action plans with actions and timelines for remedies implementations.

When a business partner or supplier fails to meet HACKETT’s standards, they are given a time period to correct the problem. If, on the next assessments, certain cases of non-compliance have not been resolved within a timely manner, HACKETT will apply a Three Advertisement policy. If a supplier receives three advertisement within a 12 month period, Pepe Jeans will reassess its business relationship with the supplier.