It’s been a year of significant activity at Liberty on the Modern Slavery front. We outlined in 2019 the many actions we intended to initiate for the next 12 months and we are reporting on the progress since – transparently sharing successful moves, as well as areas where we still have much work to do.
In the past year we began the capillary exercise of mapping and auditing our own brand direct apparel and accessories Tier 1 supply chain. We have appreciated being given access to others’ audits as we improve our understanding of working conditions in our supply base, and we look to encourage this practice of exchanging the information we have on good suppliers with like-minded makers and retailers who are also engaged with mapping their supply chain. In the coming year, we will begin to look vertically through our Fabrics supply chain, educating ourselves on the challenges at each tier, building our understanding of the most salient risks within fabric sourcing, and creating a programme with this knowledge in mind.
We were delighted that our application to join the Ethical Trading Initiative (ETI) was approved mid-year by their Board – the first multi-brand luxury retailer to do so. Through our membership, we look forward to sharing key information and engaging collaboratively with other ethically-minded organisations.
We have continued with education - many of our staff have benefitted from specific training sessions for those who work closely with suppliers. Modern Slavery training will still be a priority, and we will continue to focus on staff who liaise with suppliers. We are beginning to deploy our governance more widely to our Fabrics suppliers, but we are yet to cover our suppliers of services, our third-party brands and licensees – we have some catching up to do here.
In March, Covid 19 forced us to close our retail doors. For several months retailers were unable to operate, unable to earn any cash, unable to buy products and brands and unable to sell them. This critical situation has led to many retailers becoming insolvent, and many suppliers likewise. We would have preferred not to cancel some orders or delay payments – we know this has a knock on effect on our suppliers. As Liberty is 50% a retailer and 50% a supplier, we witnessed first-hand the adverse effect of receiving order cancellations. We have now reopened our retail doors and are working to close any pending dues with suppliers. As outlined in our report, we are also conducting an internal investigation on the impact of the pandemic on our direct and indirect suppliers, and looking at the actions we took in response.
While legislation is focused on pursuing perpetrators, there is still insufficient support for victims. We discussed this with the Home Office and had the privilege of time with Caroline Haughey QC who led the prosecution following the investigations of the UK’s largest ever trafficking case. Slavery and trafficking are on our doorstep – which painfully emerged on several high-profile cases in the past year.
We also joined forces with the Sophie Hayes Foundation’s 1000 Women campaign which aims to help female victims of trafficking to achieve independent and sustainable freedom, details of which can be found in our statement. I would like to thank our many customers that proved generous and engaged in our awareness and fund raising drives for both 1000 Women and Anti-Slavery International. Our customer contributions made a real impact in giving survivors of slavery a chance of a better future.
I am inspired by a new generation of customers that are keen to understand product provenance and are unforgiving towards brands and retailers that are not active and diligent in the fight against slavery. If and when we find issues, we will call them out, and our first response will be to try and solve the issue in the interest of the workers. While it is easier to disengage from problem supply chains, this is not always in the best interest of the workers, so we will always attempt to fix the issue first if we can.
In the fight against slavery, we believe education, sharing and collaboration are fundamental to turn small businesses like ourselves into a force. We celebrate even our small battle victories without being naïve about the war being long, complex and uphill. If there is one learning from the past year is that whatever the size of your business, you can actually make a difference.
Liberty Zeta Limited,
on behalf of the Liberty Group
Date: 25 August 2020
This is our third Modern Slavery statement published in accordance with the Modern Slavery Act 2015. This statement reviews the progress made in the 12 months since our second statement in August 2019. Our first statement was published in November 2018
ORGANISATION STRUCTURE AND SUPPLY CHAINS
Liberty is a leading luxury retailer and fabric and product design house. Our business is based in the UK with a head office in London, and is organised around three key divisions:
- Liberty Fabrics, which is the home of our in-house fabric design studio and archive, and operates Liberty’s global wholesale fabric business, including a wholly-owned fabric printing mill in Italy;
- Liberty brand, which designs and wholesales Liberty’s own-brand ‘Liberty’ product lines; and
- Liberty Retail, which operates our flagship store in London and our online store at www.libertylondon.com - these offer for sale over a thousand third party brands alongside our own Liberty products.
Our business operations are delivered by approximately 600 employees globally.
Liberty Fabrics sources raw materials from Italy, India, China and Romania, and prepares and prints fabric both in Liberty’s own printing mill in Italy, and in other locations in Italy and China
Liberty brand product is exclusively designed in-house in the UK, with apparel and accessories production outsourced directly to factories in the UK, Italy, Portugal, India, China, Lithuania, Turkey and Romania. Ambient foods, homeware and beauty accessories are produced by manufacturers in the UK and Europe, indirectly through licensing, distributors or agents.
Liberty Retail offers a curated edit of third-party brands across multiple product categories, including beauty, accessories, home, and ready to wear. These supply chains are managed by the brands themselves.
The CEO and CFO retain ultimate responsibility for ensuring that the Liberty Group continues to monitor and mitigate its human rights risk. Sponsored by the CEO, in March 2019 we established the CSR Steering Committee, formed of individuals from the Leadership Team in CSR, Human Resources (HR), Buying, Retail and Marketing. The objectives of the CSR Steering Committee are to support the CEO, CFO, and CSR Department by:
- Embedding and promoting responsible ways of working throughout the business
- Providing programme governance
- Endorsing and sponsoring new initiatives
- Ensuring effective devolvement of actions to individual departments
Human rights and modern slavery are also key elements of an annual Environmental Social and Governance (ESG) Survey that is completed and shared with Liberty’s shareholders.
AUGUST 2019 – AUGUST 2020 UPDATE
LIBERTY, FOR LIFE
In the period since the last report, the company formed a cross-functional Charity Working Group, focused on building a framework around our charitable giving programme entitled “Liberty, For Life”. As part of this process, the Working Group concluded that our philanthropic efforts would be in support of local, community-based charities, with the group then collectively creating a shortlist of charities who fit this theme. The final charities selected for support by the Charity Working Group and the Chief Executive, were House of St Barnabas and the Sophie Hayes Foundation.
The company’s long term commitment to anti-slavery has been exemplified in its support of the Sophie Hayes Foundation, a charity which focuses on supporting female survivors of human trafficking into employment. At the time of publishing, Liberty’s customers had raised over £50,000 through instore and online sales donations for the charity’s 1000 Women initiative, which aims to mitigate the risk of re-trafficking through employability support.
In addition to the above, Liberty continued to support Anti-Slavery International over the 2019 Christmas period, holding collections in store and at till point, raising a total of £7,633.
CSR - RESOURCE UPDATE
In the period since the last report, an additional headcount was created in 2020, to further support the development and delivery of Liberty’s ethical trade programme. The CSR function now comprises two full time roles (CSR Manager and Ethical Trade Business Partner) and one part time role (Director of CSR and Central Procurement). Through the latter role, the CSR department continues to have direct representation at Senior Leadership level.
ESTABLISHING OUR ACTIVITY AND THE IMPACT OF COVID 19
In the period since the last report, we have made strong progress in building foundations of our ethical trade programme, joining the Ethical Trading Initiative (ETI) as a Company Member in October 2019. Where globally-recognised standards already exist, such as the ETI Base Code, we have sought to embed these into our supply chain operations. Our first Supplier & Partner Code of Conduct mirrors this guidance and, based on the countries we source own brand product from, established supplementary policies that address heightened thematic risks in our supply chains. We additionally created a framework for our first audit programme, partnering with a global auditing company and working collaboratively to agree an audit protocol. Whilst audits have provided a critical first insight into factory conditions, we also appreciate that auditing only provides a snapshot of factory conditions, so we have additionally also looked at the way we select and risk assess suppliers, building the capabilities and knowledge base of our Production and Sourcing Teams to ask critical questions that give our business an overview of risk. We have additionally mapped our own brand direct supply chain at Tier 1 (finished goods), and will look to build on our visibility of our indirect own brand supply chain, and our Fabrics supply chain.
Whilst we are proud of the progress we have made in a year, the challenges presented by the Covid 19 pandemic have limited what we have been able to achieve, resulting in partially completed progress in certain workstreams, further outlined in our Activity Review below. Operationally, the pandemic has had a dramatic impact on our business; with our UK retail store closing shortly prior to the UK-wide general lockdown in March 2020 and our Italian fabric operations, based in the Lombardy region, severely impacted by local restrictions from early March. As part of the measures taken to protect our business, 70% of our colleagues were furloughed under the UK Government’s Covid 19 Job Retention Scheme, which meant that most of our Retail and Head Office colleagues, including the CSR team, were unable to work for several months.
As the CSR Team returns to work, we remain acutely aware of how the pandemic has added further complexity to the evolving risk of modern slavery in global supply chains. We have been working to build our understanding of the risks within our supply chains as they relate to Covid 19, collaborating with the ETI and its brand members to understand the collective challenges that the retail sector faces. We are also conducting internal investigations on the impact of the pandemic on our direct and indirect suppliers (largely based in Europe), whilst also looking at the actions we took in response.
The activity review outlines our progress made against our objectives, established in our second statement in August 2019:View our activity review
OBJECTIVE SETTING FOR 2020 - 2021
As our work over the last year has progressed, we have identified the need to refine our focus, prioritising enhanced due diligence in our direct and indirect own brand supply chains (Liberty and Liberty Fabrics) before assessing risk in our Liberty Retail division, and with non-stock suppliers.
The objectives will be in addition to any that we establish as part of our internal review of the impact of Covid 19 on our suppliers:View our objectives