The Cotton On Group (‘the Group’) has a zero tolerance approach to any form of modern slavery including; servitude, human trafficking and forced labour. We are committed to an ethical and transparent approach to business, ensuring effective systems and controls are in place to safeguard against any form of modern slavery within our business operations or our supply chain.

This statement sets out the steps the Group takes to ensure that modern slavery or human trafficking does not occur within our business or supply chain, operating in accordance with the Transparency in Supply Chains Act of 2010 in the United States of America and the Modern Slavery Act 2015 in the United Kingdom.

Our Business

Established in 1991, the Cotton On Group is one of Australia’s largest fashion retailers, with over 1,500 stores in 18 countries and a team of 22,000 people. Over the last 27 years, the Group has grown to seven brands including Cotton On, Cotton On KIDS, Cotton On BODY, Rubi Shoes, factorie, Typo, Supre and its philanthropic arm, the Cotton On Foundation.

As a global fashion business, we know we have a responsibility to do the right thing, and ensure our supply chain is both ethical and sustainable.

Our Ethical Sourcing Program, including our 14 Rules to Trade, was formalised in 2009 and governs the sourcing, manufacturing and supply of our products. As part of this program, all suppliers who manufacture goods for the Group undergo periodic audit assessments, and based on the findings of these audits may be required to undertake corrective actions.

Over the last nine years, we have continued to build our program through the addition of new resources and initiatives, working closely with suppliers, industry leaders, government and NGOs to ensure our practises are reflective of industry standard.

The Group is also working to trace our full end-to-end supply chain from farm gate to shop floor to ensure we have a full understanding of our supply chain and every facility used in the production of our merchandise.

1. Auditing Process

Through our audit program, corrective action plans and NGO engagement, we have been able to determine the high risk areas of our supply chain and implement steps to mitigate risk in these areas.

Under our Ethical Sourcing Program, we have implemented stringent policies including the annual re-signing of our 14 Rules to Trade, to ensure suppliers have a clear understanding of the Group’s expectations.

Additionally, to ensure a strong two-way dialogue with our production partners, we hold an annual supplier conference that alternates between our key sourcing markets of China and Bangladesh. These conferences are an opportunity to talk openly with suppliers on matters relating to ethical sourcing, while providing them with an opportunity to update us on the challenges they face and the steps they are making to bring about positive change.

In addition to these conferences, we hold face-to-face training and education sessions on all areas of human rights, undertake audit programs and factory inspection training sessions with workers and management, and maintain confidential in-country hotlines for workers to report any misconduct or human rights breaches.

2. Internal Accountability

We have a number of internal policies to ensure we are conducting business in an ethical and transparent manner, these include:

  • Supplier Agreements: This is signed every year by our suppliers and explains the manner in which we behave as an organisation and how we expect our suppliers to act. All suppliers including any subcontractors engaged by our suppliers must agree to and abide by our code of conduct.
  • Traceability: As we work towards full traceability of our supply chain, it is a requirement that all suppliers disclose the details of their subcontractors as required by the Group.
  • Human Rights Policy: This policy sets out our stance on modern slavery, human trafficking, child labour and forced labour and explains the response and actions in the event that instances are identified.
  • Whistleblower Policy: We operate a whistleblower policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

3. Certification

Before engaging with a new supplier, the Group conducts due diligence checks on all potential partners, and any disclosed subcontractors. In doing so, the Group maintains an approved supplier list and any supplier that is not approved may not be used for any stage of production.

This due diligence includes a factory assessment and an audit assessment which include a review of working conditions and building safety.  In addition to the above, and as outlined in our code of conduct, we require all existing suppliers to confirm to us that:

  • There is no contradiction to the Cotton On Group code of conduct in any area of a suppliers operation, including subcontractors.
  • All employees are paid at least the national minimum wage in line with local labour law/regulations applicable within their country of operation.
  • We may terminate the contract at any time should any instances of modern slavery or a zero tolerance breach of any human rights issues come to light.

4. Training

We conduct internal training of our buying and sourcing teams to ensure they have a clear understanding of the Group’s expectations for ethical sourcing.  In addition, we include training on understanding the signs of modern slavery and what to do if they suspect any form of modern slavery is taking place within our supply chain.

5. Verification

The Group is committed to ensuring modern slavery does not exist in our supply chain and that the human rights of all workers are upheld.  We monitor the effectiveness of our Ethical Sourcing Program to ensure that slavery and/or human trafficking is not taking place within our business or supply chain, through:

    • Reviewing any reports received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
    • Remediation and management reporting of breaches identified by our audit program or confidential hotlines.

Approval for this statement

This statement was approved on behalf of the Board of Directors on 19 December 2018, by Peter Johnson, CEO.