Modern Slavery Act Statement 2023

Here at The Cotswold Company, we take all forms of slavery and human trafficking very seriously. This is the fifth Modern Slavery Statement issued by The Cotswold Company in accordance with S54 of the Modern Slavery Act 2015.

Drawing on the Ethical Trading Initiative Base Code and the International Labour Organisation’s Forced Labour Protocol for guidance, we continue to ensure we take action to address and effectively mitigate risks relating to modern slavery.

We remain steadfast in our commitment to preventing any form of modern slavery within our business and throughout our supply chain.

The Cotswold Company Ltd – Who We Are

The Cotswold Company is a multi-channel furniture and homewares brand that proudly champions real, lived in homes. With 12 retail locations across the UK, multiple logistics centres in the Midlands and offices in Norwich, China and Vietnam, our supply chain, showroom network, and logistics footprint is continually expanding.

Whilst The Cotswold Company’s Board of Directors hold responsibility for compliance with this statement, it is the Chief Operating Officer who takes day-to-day responsibility for compliance within the organisation and the supply chain. Our senior managers working within our warehouse, retail, sourcing, and people departments will also ensure that both they and their staff comply with this statement at all times.

Supply Chain – Who They Are

We work with suppliers across the world, who are in line with our brand values, to bring beautifully made furniture at surprisingly affordable prices. We understand, given the scope and nature of our supply chain, that we do risk exposure to forms of modern slavery. That is why we work diligently to identify where these risks are in our supply chain – allowing us to focus our efforts accordingly to both mitigate and eliminate them.

Tier 1	Tier 2	Tier 3
Furniture Workshops & Finishing Centres	Component Suppliers	Material Suppliers (Timber, Leather, Foam, etc.)

Organisational Policies

We have several policies in place for Cotswold Company employees to ensure that we are conducting business in an ethical manner.

Firstly, the eligibility to work is verified for all employees working for The Cotswold Company worldwide. This ensures all employees are in possession of their own travel documents and that they have the right to work in the given territory.

Secondly, the Employee Handbook ensures that policies on health and safety, diversity, and discrimination are followed with clear procedures in place for the reporting of any possible issues.

Supply Chain Policies

We don’t just ensure these requirements are made in-house though, we also take steps to guarantee our supply chain meets these important requirements too.

Supplier Code of Conduct

All suppliers that we place orders with are required to make a contractual agreement guaranteeing that they will adhere to The Cotswold Company Ltd Ethical Sourcing Policy and all relevant local legislation. Where the two differ, we will always follow the policy that offers the greatest protection. If a supplier was to breach these terms, it offers us grounds to terminate the business relationship immediately. The compliance element of these agreements is renewed every 24 months.

Supplier Ethical Data Exchange (SEDEX)

All Tier 1 suppliers are required to register to SEDEX and complete the self-assessment questionnaire. By doing so, it will highlight any risks relating to labour standards, health and safety, environment, and business ethics – therefore allowing us to make a well-informed decision.

Inspections

We ensure that all our Tier 1 suppliers are visited by management at least twice a year. These visits allow us to identify and work with suppliers to resolve any issues as quickly as possible. Our UK-based managers have resumed regular travel to support our locally based teams who frequently visit and work at the sites of our Tier 1 suppliers. Having a permanent presence at all our suppliers provides considerable insight into the supplier’s processes and the day-to-day conditions of the site.

The Steps We're Taking

We continue to progress improvements to visibility and minimise the risks associated to modern slavery within any supply chain that we have exposure to.

Ethical Sourcing Policy

This policy clearly outlines our position on Modern Slavery and sets the minimum standards that we require all our suppliers to comply with. Based on the International Labour Organisation’s ETI Base Code, this policy is designed to ensure ethical standards are maintained throughout our supply chain globally.

Due Diligence

Our due diligence system has been developed to make sure we are constantly reviewing and updating information on our supply chains that helps us monitor and assess risks. A key part of this due diligence system is the Supplier Ethical Data Exchange (SEDEX). This platform allows us to review audit findings and run risk assessments based on the location and industry of the supplier. All new suppliers are required to complete a questionnaire that will highlight any possible areas of risk before a full SMETA audit is carried out. SMETA audits are one of the most widely used audits in the world.

Through diligent work with our Far East suppliers 100% of our Tier 1 suppliers based in China and Vietnam audited independently. 90% of our production outside of the UK is covered by SMETA and SEDEX audited factories, with the remaining 10% in progress.

Further to this we strengthen our due diligence with frequent visits to all our suppliers by our compliance and technical teams based in China and Vietnam as well as regular visits from our UK teams. All Tier 1 suppliers are visited a minimum of twice per year, during which time spot reviews are carried out of employee records, timesheets and working facilities.

Employee Awareness & Training

We recognise that the effectiveness of the above policies does rely heavily on the awareness and ability of our teams to identify these potential issues. We therefore ensure that employees who are directly involved in the supply chain have received training on how best to identify and address any possible breaches of our sourcing policy, with a focus on how to recognise signs of modern slavery.

Assessment & Effectiveness

As we grow, we will continue to review and develop all these processes to ensure we adapt to any challenges that may arise in identifying ethical issues within our supply chain. It’s important to note that all the information collected from our suppliers is weighted and measured against key performance indicators that cover not only ethical but also environmental, management and quality standards too.

This statement has been approved by the organisation’s Board of Directors who will continue to review and publish it annually. It is signed on their behalf by our Chief Executive Officer,

Ralph Tucker
CEO, The Cotswold Company Ltd
November 2023