US Modern Slavery Act

ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR YEAR ENDING 30 SEPTEMBER 2021

Our policies

We love creating natural, organic beauty and health products that are efficacious, in a way that cares for people and our planet. We opened our first shop in Covent Garden, London, in 1981. From the start, we’ve been committed to providing a satisfying, safe and supportive workplace for all and to ensuring fair and respectful relations with suppliers.

'Slavery, servitude and forced or compulsory labour’, as government guidelines say, is ‘a crime resulting in an abhorrent abuse of human rights'.

We’re committed to preventing acts of modern slavery and human trafficking within our business and supply chain and impose the same high standards on our suppliers.

Our policies

As part of our commitment to combating modern slavery, we have in place the following policies:

  • Anti-Slavery Policy
  • Anti-Bribery and Corruption Policy
  • Ethical Company Policy
  • Sustainable Purchasing Policy
  • Whistleblowing Policy
  • Supplier Code of Conduct (Do Good Ethical Supplier and Supply Chain Guiding Principles)

Combating slavery in our supply chain

We are privileged to buy a wide range of materials from many countries around the world and because our supply chain is global, we take our responsibility seriously towards those involved, both directly and indirectly. Our supply chain procedures are designed to:

  • Establish and assess areas of potential risk in our business and supply chains
  • Monitor potential risk areas in our business and supply chains
  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains
  • Provide protection for whistle blowers

Our Procurement Manager has undertaken training with the Chartered Institute of Procurement and Supply (CIPS) and the Ethical Trading Initiative (ETI) to best manage our processes regarding slavery risk. Over the past twelve months, we have built into our process supply chain assessments to evaluate our suppliers and mitigate risks. This is an ongoing activity.

We include obligations regarding the ethical treatment of employees in our standard terms of business. During the last year we have been in discussions with our key suppliers- based on value and risk - to ensure all have contract terms in place, concentrating on the approximate 20% of our suppliers that account for 80% of our direct expenditure. Our standard supply agreement for the provision of indirect goods and services, and our agreements with our franchisees and distributers both in the UK and abroad, all contain anti-bribery and corruption and modern day slavery terms. We seek to buy all goods (from both packaging to raw materials and appliances) from suppliers with a proactive approach to protecting the environment and fair trade practices, and this is committed to in our Sustainable Purchasing Policy.

Human rights

'We agree with the government’s definition that ‘Human rights are rights and freedoms that belong to all individuals regardless of their nationality and citizenship'.

As an ethical and organic health and beauty company, respecting human rights throughout our business is at the heart of our company ethos. We aim to build strong, respectful, long term relationships with our suppliers, resulting in a robust and resilient supply chain.

We support the Universal Declaration of Human Rights and support the Ten Principles of the Global Compact in the areas of Human Rights, Labour, Environment and Anti Corruption.

To help identify and reduce human rights risks in the rest of our supply chain, we became members of the Ethical Trading Initiative (ETI) and Supplier Ethical Data Exchange (Sedex). ETI and Sedex aim to improve ethical and responsible practices in global supply chains. Their core principle is avoiding unfair or unsafe labour practices, including slavery and human trafficking.

Our direct suppliers are required to sign up to Sedex and our ‘Do Good Ethical Supplier and Supply Chain Guiding Principles' depending on the perceived risk. By having suppliers who are signed up to Sedex, it allows us to review the risks and take appropriate mitigating action where necessary.

Certifications

We use certifications that ensure our supply chain complies with the UN Convention for Human Rights and the core standards of the International Labour Organisation. It is included in certain organic standards (such as the Soil Association Organic standard) that there is no forced or involuntary labour, and there is either no child labour or labour does not interfere with their education and can be rescinded if failing to meet the United Nations Convention for Human Rights. As stated in our Sustainable Purchasing Policy we will always prioritise certified organic ingredients and materials where they are available in reliable volumes at the right quality. With fair trade certifications the previous points remain true, and it also certifies:

  • Employees have the right to associate, organise and negotiate terms
  • Employees are paid a fair wage

Fair trade is about better prices, decent working conditions and fair terms of trade for farmers and workers that include reliable and long-term commitments to purchasing.

In accordance with our Sustainable Purchasing Policy we will use quality fair trade certified materials that have reliable long-term availability unless the ingredient material is not organic, and an alternative organic material is available.

Looking forward

Following a review of our actions to prevent slavery and human trafficking in our business and supply chains, we’ll continue to work on the following steps to tackle slavery and human trafficking during 2021/2022:

  • Review our policies, processes, and planning based on a risk mitigation approach.
  • Continue the roll out of supplier contracts and service level agreements.
  • Review our indirect supply chain for goods and services, including the roll out of the ‘Do Good Ethical Supplier and Supply Chain Guiding Principles’.
  • Assess the potential use of Sedex for larger indirect suppliers as well as wholesale customers.
  • Confirm targets on the percentage of physically processed agricultural ingredients certified organic, and the percentage of formulations or relevant product value certified organic.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Neal’s Yard (Natural Remedies) Limited and its group companies’ slavery and human trafficking statement for the financial year ending 30th September 2021.

Stephen Tobitt

CEO

Neal’s Yard Remedies