UK Modern Slavery Act

WellWorthUK Ltd. STATEMENT ON FORCED LABOUR, HUMAN TRAFFICKING AND MODERN SLAVERY FOR THE FISCAL YEAR 2021

 

BACKGROUND

At WELLWORTHUK LTD, we respect human rights in our operations and extended value chain and conduct business ethically and sustainably. WELLWORTHUK LTD supports human rights as defined by the Universal Declaration of Human Rights, which recognizes that “all human beings are born free and equal in dignity and rights.” We work to elevate human potential through our products, partnerships and operations, something that cannot be accomplished without fundamental respect for human rights throughout WELLWORTHUK LTD’s operations. We expect the same from our suppliers and focus on working with long-term, strategic suppliers that demonstrate a commitment to engaging their workers, providing safe working conditions and advancing environmental responsibility. This includes working to combat the risks of forced labour.

This statement is being furnished according to the UK Modern Slavery Act, UK. This statement discusses WELLWORTHUK LTD’s global business practices to address forced labour. This statement encompasses WELLWORTHUK LTD, Inc because we take a global approach to forced labour compliance.

As used in this statement, forced labour includes modern slavery, prison labour, indentured labour, bonded labour, human trafficking, or other similar conduct.

WELLWORTHUK LTD OVERVIEW and SUPPLY CHAIN STRUCTURE

We are strengthening long-term relationships with strategic suppliers and sourcing from fewer factories, focusing on those that are committed to our strict standards of sustainability, product excellence and compliance with local laws. Our sourcing strategy prioritizes and favours suppliers that show demonstrable leadership in corporate responsibility and sustainability, seeking to move beyond minimum standards. As part of our growth strategy, we seek suppliers who drive sustainable business growth by minimizing their environmental impacts, fostering a strong culture of safety and developing an engaged and valued workforce.

WELLWORTHUK LTD’S CODE OF CONDUCT & STANDARDS TO ADDRESS FORCED LABOUR

WELLWORTHUK LTD takes seriously and fully supports national and international efforts to end forced labour.

WELLWORTHUK LTD’s requirements for suppliers are contained in our Code of Conduct and Code Leadership Standards. The Code of Conduct lays out the required minimum standards we expect each supplier factory or facility to meet in producing WELLWORTHUK LTD products and includes strict requirements around forced and child labour, excessive overtime, compensation, and freedom of association amongst other requirements. The Code Leadership Standards specify how the Code of Conduct should be implemented. The document also articulates how we measure factories’ compliance efforts and progress against our Code of Conduct, including specific requirements on the management of key forced labour risks.

We have progressively raised expectations for our contact factories through evolving standards of our Code of Conduct and Code Leadership Standards. WELLWORTHUK LTD’s Code of Conduct and Code Leadership Standards include specific requirements to address key risks of forced labour including, but not limited to, prohibiting workers paying fees for employment, requiring employment terms and conditions to be provided and explained before departure from the home country with adequate time for review, providing contracts in both the worker’s language and legally enforceable language in the receiving country, and prohibiting requirements to post bonds or make deposits as a condition of employment.

RISK EVALUATION

WELLWORTHUK LTD continually evaluates and updates our systems to identify and address supply chain risks, including those related to forced labour. This process includes information from external sources such as risk assessments for key human rights risks, supplier-specific risk profiling based on location, including the employment of vulnerable worker groups, and areas of improvement identified in audits. We also review information on key and emerging risk areas identified through our engagement with external stakeholders. WELLWORTHUK LTD is working towards mapping these risks further up the supply chain and is expanding engagement with Tier 2 suppliers. In recent years, we have prioritized our work on forced labour risks to focus on suppliers employing foreign migrant workers, a key vulnerable worker population.

AUDITING

WELLWORTHUK LTD audits include detailed criteria to look at risks of forced labour, including the employment of vulnerable worker groups such as foreign migrants, interns and temporary workers and high-risk practices such as payment of recruitment fees or restrictions on freedom of movement.

REGIONAL EFFORTS

WELLWORTHUK LTD takes very seriously any reports about forced labour and we have been engaging with multi-stakeholder working groups to assess collective solutions that will help preserve the integrity of our global supply chains. We will continue to collaborate with industry experts, partners, industry associations, stakeholders and other organizations to understand, evaluate and address this critical global issue. For more information about our work, please see our statement here.

REMEDIATION & EFFECTIVENESS

Working with a wide range of organizations and experts, WELLWORTHUK LTD continuously seeks to improve our approach to evaluating working conditions in our supply chain and supporting suppliers’ efforts to enhance their capabilities.

Through our ongoing assessment process, WELLWORTHUK LTD has been in close collaboration with a supplier group to evaluate enhancements to programs designed to ensure foreign migrant workers did not pay fees related to their employment, in violation of WELLWORTHUK LTD’s Code of Conduct and Code Leadership Standards.

TRAINING AND ACCOUNTABILITY

WELLWORTHUK LTD believes suppliers that prioritize the well-being of their workers, by engaging with them to understand their needs, have better factory performance. We also believe that our ability to influence suppliers is dependent, in part, on building the right incentives and sanctions into our business relationships.

WELLWORTHUK LTD frequently convenes supplier events, or learning communities, designed to share information on WELLWORTHUK LTD expectations, developments on local policies/legislation, and other sustainability and labour best practices. Considerations related to the management of migrant workers is a key area of focus given that many of our suppliers and vendors are in countries where it is common to recruit workers cross-border.

COLLABORATIVE SOLUTIONS

WELLWORTHUK LTD believes addressing critical human rights risks, such as forced labour, often requires a collective approach. WELLWORTHUK LTD has long partnered with multi-stakeholder and external organizations. Through our partnerships with these organizations, we work on a wide range of human rights risks, including those related to forced labour.

WELLWORTHUK LTD shares the aims of the LGRR to drive positive change in the international recruitment industry, starting with a focus on prohibiting workers from paying fees for their employment. We believe the adoption of the Employer Pays Principle, which states that no worker should pay for a job and the costs of recruitment should be borne by the employer, is a critical factor in helping eliminate forced labour risks in our supply chain, industry and beyond. We also engage in moving forward the agenda on this important topic through our support of LGRR’s advocacy to governments and organizations for the adoption of the Employer Pays Principle.

We will continue to expand and evolve our work with other peers, NGOs, and organizations to increase respect for human rights and to accelerate positive impact in the countries where we and our suppliers operate.