Lifetime Brands Europe Company Statements
Our 2021 Gender Pay Report can be found here
Our 2020 Gender Pay Report can be found here
Our 2019 Gender Pay Report can be found here
Our 2018 Gender Pay Report can be found here
Our 2017 Gender Pay Report can be found here
Lifetime Brands Europe Modern Slavery Act Company Statement
For the period 2023 - 2024
Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes on various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another, in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to Modern Slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls.
Policy, compliance and due diligence within our business
Lifetime Brands Europe ensures compliance with all local and national employment laws and commits to ensuring fairness in the hiring and advancement of all colleagues without discrimination. We require all staff to comply with the company’s code of conduct and ethics in all business dealings.
As an organisation we are committed to being best in class by operating ethically and responsibly and with a culture of giving back to society, maintaining our strong family values and sense of making a difference.
We are transparent and regularly review our recruitment processes, ensuring full and stringent verification for all labour providers used.
A culture of openness and accountability is essential with a robust and confidential whistle-blowing policy firmly in place. Our zero-tolerance approach extends to all persons working for us or on our behalf in any capacity.
All our employees upon joining the company receive our Handbook of Employment from our Human Resources Department, which explains our code of conduct, code of ethics, whistle-blowing policy and insider trading policy to further reinforce our stance.
All new employees are made aware of our ethical and compliance standards. As part of this process they are made aware of the indicators that would signal human trafficking and forced labour and how to report and deal with such an instance.
Any recruiters who we engage with for the supply of temporary workers must be licensed by the Gangmasters and Labour Abuse Authority (GLAA) and will work to the same strict standards as per our own operating procedures.
Policy, compliance and due diligence within our supply base
We operate a zero-tolerance approach to slavery and human trafficking and require our suppliers to ensure they do not use forced labour, bonded or involuntary prison labour within their operation.
We have also embarked on a programme to communicate and regulate our policies to existing and new suppliers, as well as our sourcing agents and employees throughout the business where we make it clear from the outset our expectations; insisting on only working with suppliers who share our ethical values. We encourage open transactions and lines of discussions and work through challenges together with suppliers, with a refusal to trade with any suppliers that offer little or no engagement or transparency.
Assessing and identifying risk
We understand the key to assessing risk is to build relationships with suppliers and providers where we develop a culture of mutual respect and trust in order to understand and offer support in the evaluation of risk. We insist on full transparency and visibility throughout all aspects of our Supply Chain.
Aspects of modern slavery can be extremely subtle, with forced labour, labour trafficking and exploitation of workers often being a hidden blight on global society. Whilst third party ethical and social audits in factories can offer benchmarks and indicators, we therefore go above and beyond by engaging key factory stakeholders, in the completion of a robust Self-Assessment Questionnaire (SAQ) and mapping our supply chains. This is supplied by our Quality Assurance Department and requires completion during the factory onboarding process and at least every three years thereafter. We also adopt a diligent approach in our selection of suppliers through factory visits and our rigorous factory evaluation and verification process.
Awareness and collaboration
Lifetime Brands Europe recognise that goods we manufacture and import are at risk of slavery and human trafficking - we commit to working collaboratively with suppliers in order to raise continued awareness and continually review our verification processes to address and eradicate any such risks. We are actively working towards streamlining our supply base through resourcing projects in order to build upon our relationships and ensure we can reinforce our values with all suppliers.
Assessment of Effectiveness
We use the following Key Performance Indicators to monitor our effectiveness:
● Investigations undertaken into reports of Modern Slavery and remedial actions taken
● Employees’ knowledge of Modern Slavery, recognising the signs and how to report. This is checked during the formal employee interviews that take place as part of the BSCI and SMETA ethical audits
● Actions taken to improve communication of our expectations to suppliers and customers – Circulate Modern Slavery & Trafficking Policy to our suppliers and customers as well as obtaining copies of their own policy and statement.
● Internal training to improve awareness amongst the senior and operational management teams.
● Implementation of further checks and audits
1. HR undertakes monthly checks on duplicate accounts and addresses
2. Operations check for common telephone numbers and duplicated emergency contact details
3. HR view the workers bank card/bank statement to ensure they are named on the account – salary payments will only be made into worker named bank accounts
4. HR cross-reference bank details and name and ensure the account holder is in possession of his/her bank card
5. HR request copies of tenancy agreements to identify any common landlord details where duplicated addresses exist
Evidence of all the above measures are also part of the documentation review that take place as part of the BSCI and SMETA ethical audits, performed at intervals no more than every three years by an Internally accredited Auditor
The Key Performance indicators indicated above suggest that in 2022-23 there were no issues of Modern Slavery or human trafficking in the Lifetime Brands Europe supply chain. We will continue to apply these indicators annually and maintain vigilance as to their effectiveness.
Lifetime Brands Europe’s commitment
All businesses must play their part in tackling Modern Slavery and combating it effectively requires improved traceability, increased transparency and through working collaborations. Lifetime Brands Europe will commit to review annually our Modern Slavery policies to ensure their relevance, whilst factoring in social and economic factors and changes. We will continue to maintain our SEDEX membership and continue to assess and improve on all ethical business practices and assessment of risks, current and new. Our policies, procedures and approach to ethical compliance are what we believe to be balanced, reasonable, effective and practical.
This statement has been approved by the Lifetime Brands Europe board of directors.
Matthew Canwell
Managing Director, Lifetime Brands Europe