Modern Slavery Act Statement 2023
Introduction
This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It details the steps that clearhalo.com has taken - and is continuing to take - to ensure that modern slavery and human trafficking is not taking place within our business or supply chain. This statement details clearhalo's actions to combat modern slavery in our supply chain from 1 January 2021 to 31 December 2022.
Modern Slavery Definition
The Ethical Trading Initiative (see www.ethicaltrade.org), an umbrella organisation which assists businesses in working and trading ethically, defines modern slavery as a term used to describe a number of specific issues, including human trafficking, forced and compulsory labour, debt bondage, slavery, servitude, and the worst forms of child labour and slavery.
clearhalo has a zero-tolerance approach to any form of modern slavery. We are committed to acting in an ethical manner with integrity and transparency in all of our business dealings. We are also committed to establishing effective systems and controls in order to safeguard against any form of modern slavery taking place within our business or our supply chains.
Our Organisation
clearhalo is a design brand with a vision to make great design accessible to everyone. We collaborate with talented designers and work closely with suppliers across the world to offer consumers unique furniture, homeware and lifestyle products at affordable prices.
Our Supply Chain
It takes a global team of artisans and furniture-makers to create our products. We don’t own any factories but only collaborate with those who share our values. We are committed to building long-term relationships with our key partners and the factories where our main production and product assembly takes place (known as Tier 1 units). We have local teams in our main sourcing regions of Vietnam and China. These teams visit our factories regularly.
Our onboarding processes for suppliers include the requirement that all our suppliers make a number of contractual commitments to us as part of the supplier terms and conditions that they sign. Under these terms and conditions, suppliers must adhere to all applicable laws regulating child working and bonded labour; must not under any circumstances or on any basis, engage any person under the age of 15; and must maintain appropriate workplace health, safety and welfare conditions. Our suppliers also agree to assist and cooperate with us on any due diligence checks, audits, and inspections that we may undertake to verify their compliance with these commitments.
Our Policies
We operate a number of internal policies to ensure that we minimise the risk of harm associated with modern slavery and human trafficking in our direct business operations, as well as with related matters such as unsatisfactory working conditions and discrimination. These policies are also designed, more generally, to ensure that we are conducting business in an ethical and transparent manner. These policies include:
- Recruitment policy. We conduct eligibility-to-work checks for all employees globally to safeguard against human trafficking or individuals being forced to work against their will.
- Employee policies. We have employee policies on health and safety, grievance procedures, and anti-corruption.
Updates from previous year and commitments for the year ahead
2023 Actions
We took some significant steps in 2022 to continue the global fight against modern slavery.
Internal Capacity and Strategy Building
We built a sustainability team comprising three full time team members, two of which are focussed on supply chain sustainability. The team operates both proactively and reactively. The team developed processes to centralise our data and ensure a greater level of visibility and management of the supply chain - these processes included updates on all supply chain forms for new and existing suppliers, ensuring a deeper level of information gathering on our partner suppliers. The creation of the team also allowed clearhalo to focus business responses on relevant global modern slavery risks that occurred throughout 2022.
The clearhalo sustainability team created and internally launched the business’ first sustainability strategy in 2022.
clearhalo.com recognises that sustainability is not only about our impact on the environment but also our impact on people and therefore our plans also outline clearhalo's social responsibility. clearhalo is fully conscious of the close link between people and planet and understands that the climate crisis aggravates human rights issues, including modern slavery. That is why our approach to sustainability is strategically multi-disciplinary and ensures both elements are equally weighted.
2022 was a catalysing year for our sustainability journey at clearhalo and we know that as clearhalo continues to grow at pace, that it is fundamental that our approach to modern slavery and the associated processes develop alongside that growth.
2023 Intentions
Transparency
In 2022, the clearhalo sustainability team created and launched its first sustainability strategy. 2023 will build on this creation by making public a number of our targets, one of which is focussed around the development of more robust responsible sourcing practices. Responsible sourcing refers to the use of less environmentally impactful materials and also the welfare of our supply chain workers. Transparency is a key pillar for responsible business and so we intend to report against these targets publicly, on our website. More details about our strategy can be found on our ‘Sustainability at clearhalo’ pages on clearhalo.com
Policy Implementation
We are committed to reviewing and updating our supply chain Code of Conduct, in line with the globally recognised Ethical Trading Initiative (ETI) base code. Our Code of Conduct will include a strict prohibition on all forms of modern slavery. We intend to develop a further suite of responsibility policies. These will include a Responsible Sourcing Policy, that will indicate clearhalo’s requirements in terms of raw material procurement. Once completed, these policies will be published publicly.
Collaboration
Undertaking collaborative work with industry experts and peers is a core method of tackling supply chain abuses. As such, we commit to applying for membership to the ETI and actively participating within all relevant working groups. The ETI is a membership organisation that comprises multiple stakeholders including trade unions, brands and NGOs. The ETI and its members work together to tackle the many complex questions surrounding what steps companies should take to trade ethically, and how to make a positive difference to workers' lives - including eradicating modern slavery.
Due Diligence
Formalising tools and mechanisms to assess standards is a vital part of modern slavery eradication. Therefore, we are committed to strengthening our factory and supplier on-boarding process and according to a new business strategy we will ensure all Tier 1 sites are covered by a third-party social audit. A review process will be built to review corrective actions and follow up with the supplier and our in-region teams to remediate any issues.
Training
A core action for 2023 is increasing awareness of spotting the signs of modern slavery. We feel this is best approached directly through our in-region employees and agents including those that are on the ground and regularly visiting our manufacturing facilities. The aim is to increase business-wide skills in identifying and preventing modern slavery risks.