Modern slavery is an issue of increasing global concern. It is found at many workplaces – on farms, in factories, private homes and in ancillary services. InTheStyle does not tolerate any forced labour, human trafficking, bonded labour or slavery – including prison labour, or any use of force or other forms of coercion, fraud, deception, abuse of power or other means to achieve control over another person for the purpose of exploitation.

InTheStyle accept it is our responsibility to prevent, mitigate and remedy where necessary the risks of modern slavery in our operations and supply chains. We welcome the transparency and honesty encouraged by the UK Modern Slavery Act and the duty it places on businesses to report on the steps we are taking to address modern slavery.

This is In The Style’s first Modern Slavery Statement, published in accordance with the Modern Slavery Act (2015). This Statement sets out our activities to identify risk and take steps to prevent modern slavery in our business operations and supply chain between January 2020 and December 2020. Additionally, it sets out our commitments for 2021.

About In The Style

In The Style was founded in 2013 by Adam Frisby and is a leading pure play on line fashion business appealing to young women.

Based in Manchester, UK, In The Style is operated from a combined head office and warehouse facility and employs c.120 people.

Our supply chain can be divided into two separate areas:

• Products for resale on our own website or third-party platforms (In The Style brand)
• Goods and services not for resale (including logistics, IT, head office and warehouse services and the use of outsourced fulfilment centre)

We design and develop In The Style brand products at our Head Office and these products are then manufactured by third party factories. To manufacture our products, we work with 41 third party suppliers working with 61 tier 1,2 and 3 factories, across 5 countries being UK, China, Thailand, Turkey and Pakistan. Supply chain transparency is a priority for In The Style. We recognise that knowing our supply chain is the first step towards making sure that we can identify and address any human and labour rights violations. While we are committed to fully mapping our supply chain, we know that to do this well it requires a lot of work, trust and time but this is something In The Style are committed to achieving.

Policies

We continuously develop our ethical trading strategy to ensure that our programme and policies are current and fit to deal with emerging risks and issues.

In The Style core policies relating to respecting, protecting and addressing human and labour rights violations, including modern slavery, are:

The policies are issued and confirmed with suppliers as they are onboarded and form a condition of trading with InTheStyle.

Other documents relevant to preventing modern slavery across In The Style’s business operations are: People Handbook; Grievance Procedures; Anti-Bribery and Corruption Policy; Supplier Manual / Terms and Conditions.

Due Dilligence

Governance

The Chief Executive/Founder and Chief Operating Officer are responsible for ensuring that InTheStyle meets its human rights responsibilities. They are supported by staff members across Product Technology, Buying and Merchandising. CSR progress is a standing agenda point at all monthly Board meetings and a progress and status report is presented to the Board and discussed, action points are noted and followed up.

Risk Assessment

In The Style recognise the risks of human rights abuses and modern slavery in local and global supply chains. While we do not own any of the factories making our products, we acknowledge our responsibility to ensure that all products manufactured for us are done so in a safe and ethical way, respecting universal human rights.

Our current focus is on the manufacture of In The Style brand products. We are committed to establishing a due diligence programme, partnering with key stakeholders to address the risks of modern slavery throughout our supply chain and business operations. For instance, in the UK we are a signatory to the Gangmasters and Labour Abuse Authority (GLAA) Apparel and General Merchandise Public/Private Protocol which aims to address Labour exploitation and modern slavery risk in UK supply chains. Through this partnership we work together with other brands and enforcement bodies to share information, identify priorities risk areas and disrupt exploitative practices.

Mapping and supply chain transparency

Mapping our supply chain is the first step to identifying and resolving issues. We started thoroughly mapping our supply chain in 2019, which has provided us with a good level of visibility of our Tier 1 suppliers. We define Tier 1 suppliers as main product sites that cut, make and trim In The Style brand products.

In 2020 In The Style committed to publish a list of our tier 1 factories [link], which we intend to update twice a year. This includes factory names, addresses, as well as some additional information about the factories. This represents our commitment toward greater transparency in our manufacturing supply chain which we believe is the first step to better enable us to collaborate, identify, address and mitigate against adverse human rights impacts.

Mapping is an ongoing journey that takes a lot of work, trust and time. We will continue to build our relationships with suppliers in a way that promotes full supply chain transparency and responsible business.

Monitoring

In 2020 we instigated a programme to monitor our supply chain and identify potential risk areas. Existing suppliers must continue to support our mapping exercise. New suppliers must declare the factories they intend to manufacture our products in. All factories are requested to provide a social audit. In The Style recognise a number or audit providers including SGS, Intertek, TRN and BV. While we’re mindful of the limitations of social auditing, we feel that coupled with additional due diligence they support our supply chain monitoring programme.

In the UK we joined Fast Forward, an innovative programme designed to uncover hidden exploitation in UK supply chains while driving collaborative continuous improvement. The programme requires our UK manufacturing sites to undergo Fast Forward audits, which includes forced labour indicators, as well as attend supplier and factory workshops. The programme also allows for multi-stakeholder collaboration between brands, suppliers, manufacturing sites and other organisations to continually identify and address human and labour rights issues in UK supply chains. We are an active member of this initiative and have started to carry out our own factory visits and implement the programme across 18 Suppliers working with 29 tier 1,2 and 3 UK factories. This represents 47% of our total product manufacture.

Training

In 2020 we engaged with The Reassurance Network to develop training for relevant internal staff on key challenges, including modern slavery, in garment supply chains and to raise awareness of how our teams’ roles can impact garment workers. This will be rolled out in 2021.

In the UK, the Fast Forward programme runs workshops for all suppliers and manufacturing sites, including a focused session on Modern Slavery. In 2020 we enrolled 9 suppliers and 12 factories on to this training. We will roll it out to the rest of our UK supply base in 2021.

Future Committments

This is our first Modern Slavery Statement and we know that there is much more to be done. Our key focus areas and commitments over 2021 are to:

• Continue to improve transparency of our supply chain, through strengthening supplier partnerships, building trust and exercising due diligence. By the next reporting period we aim to:
  • Map our full Tier 1 supply chain
  • Sign up to the Transparency Pledge and publish our factory list in accordance with their requirements
  • Engage with The Reassurance Network to carry out In The Style ethical audits in both the UK and internationally
  • Visit and carry out our own audits across all of our UK manufacturing sites as part of the Fast Forward programme
  • Carry out audits at key global manufacturing sites
  • Evolve internal policies and procedures to ensure that we only work with manufacturing sites that are committed to In The Style ethical standards
• Strengthen our responsible business governance structure to ensure our operational processes, policies and actions are effective in identifying and addressing human and labour rights risks in our supply chain. Alongside this, we intend to recruit a dedicated expert to take responsibility for developing, implementing and monitoring our human rights strategy and policy, working alongside existing staff who hold responsibility to support our xxx programme.
• Form partnerships with key stakeholders including other brands, audit providers, workers’ organisations and authorities to collaborate on addressing human rights risk in our supply chains.

We will report on progress in our 2021 Modern Slavery Statement at the end or our Financial Year ending March 2022.