MODERN SLAVERY ACT STATEMENT 2018

This transparency statement is published by Esege Ltd T/A Delta Connex in accordance with section 54 of the Modern Slavery Act 2015 and covers the calendar year ended 31 December 2018.

Introduction

We acknowledge that modern slavery, forced labour, human trafficking and bonded labour (together “Modern Slavery”) is a global issue across all business sectors and are continuously striving to ensure that Modern Slavery does not occur in our business and supply chains.
As part of the retail sector we recognise our responsibility to take a robust approach to Modern Slavery and already have policies and controls in place as part of our ethical policy and core value of honesty. These policies are reviewed annually following valuable input from various departments within our business.

Our business and supply chains

Delta Connex is a designer of own brand womenswear, footwear and accessories. We operate internationally online (including on third party websites), through boutique stores in the UK and Ireland, concessions in department stores in the UK, Ireland and the Netherlands, as a franchise in the United Arab Emirates and via a joint venture in Switzerland.

Delta Connex sources its products from 49 suppliers spread across 78 factories in China, India, Asia and Europe. We operate an ethical policy and pride ourselves on responsible sourcing and our commitment to high ethical standards of our supply chain.

Delta Connex is committed to working in collaboration with our suppliers to encourage continual development and best practice. During the period, we more robustly addressed the issues covered in the Modern Slavery Act 2015 and work with our suppliers to ensure best practice is followed. We have due diligence processes in place for both new suppliers and new factories to risk assess our supply chain.

As part of our due diligence process, we require completion of supplier and factory set-up forms prior to placing orders, the provision of an audit from a recognised independent organisation such as SEDEX and on the rare occasion these are not available we will work closely with the supplier to ensure they are adhering to the ETI base code and our Anti-Slavery & Human Trafficking Policy as set out in our Supplier Handbook. We then actively encourage them to move to obtaining an audit as soon as possible.

The audits include, but are not limited to, working conditions, health and safety, hours worked, whether wages are above the legal minimum, ability to leave the premises after work shifts and whether any ID documents are held by the employers.

If any issues are identified in the audits we work with the suppliers to ensure that they are followed up satisfactorily within a reasonable period.

Further audits are requested on a regular basis, with a maximum period of 2 years in between audits, so that we can work with suppliers to better their practices and help achieve a better way of life for employees in our supply chain.

This year we have visited some of our key sites and experienced the efforts our suppliers are making to provide a good quality of life for their workers.

We recognise that there are multiple tiers of the supply chain which can change with each new order so we will continue to strive for complete transparency by working through the tiers with our due diligence process.

Relevant Policies

All product suppliers are contractually bound by our terms and conditions which includes adherence to our Anti-Slavery and Human Trafficking Policy and ethical policy which requires adherence to the ETI Base Code as a minimum standard.

All employees must follow our code of conduct which makes it clear the actions and behaviour expected of them when representing the company. They are also required to follow our Employee Handbook which includes our Anti-Slavery & Human Trafficking; Anti-bribery; and Whistleblowing policies.

Within our business, our recruitment policy covers due diligence on right to work, addresses and proof of identification and we only work with reputable recruitment agencies.

Delta Connex is committed to being part of the global eradication of Modern Slavery and recognise that in a continually moving business environment we need to continue to improve on our actions and processes in order to fulfil our part of it.