Modern Slavery Statement

/Modern Slavery Statement
Modern Slavery Statement2019-01-01T10:15:30+00:00

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Closet15 LLC’s slavery and human trafficking statement for the financial year ending 30 June 2018.

Introduction

At Closet15 we are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.

Our Business

Founded in the 2000’s, Closet15 is a global business designing & selling high quality clothing, shoe and accessory collections for men and women in six continents. We also license others to produce and sell eyewear, fragrance, children’s clothing and interior products and in Japan license the production and sale of men’s and women’s clothing.

Our distribution methods remain the same as in previous years; we sell our products through three main channels; our own shops and website, wholesale both in store and on line and licenced partners. From time to time we also expand our offer through a range of product collaboration projects.

Closet15 Group Holdings Limited is the ultimate parent company of the global Closet15 group, including Closet15 LLCand our main US trading company, Closet15 LLC. Our registered office is at 4163 SW Gleneagle Cir Palm City, FL 34990.

Our Employees

The Closet15 group now has over 1,300 employees worldwide. We have thorough recruitment practices in which we check all our employees’ eligibility to work and we are confident that there is no risk of slavery and human trafficking within our group.

Our Supply Chains

Our Products
Our product supply chain remains stable and we continue to source our fabrics and components from circa 350 suppliers with the majority located in Italy and engage circa 300 factories to manufacture our products, over half of which located in Europe.

Indirect Suppliers
We also contract with suppliers for a broad spectrum of goods and services which are important to our business operations but which do not feed into our product production, such as information technology, shop fittings, till systems, logistics.

Our Policies

At Closet15 we are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business and we have zero tolerance to any such practices.
All factories we work with are required to adhere to ethical working practices, which include but are not limited to complying with key principles of ensuring that: employment is freely chosen and that freedom of association and other workers’ rights are respected; the required standards of working conditions are met and the conditions will be safe and hygienic; workers’ hours are not excessive and that regular employment is provided; there is no use of child labour; and that no discrimination or harsh or inhumane treatment will be practiced or allowed in their organisation.

Update from Previous Year

In our last statement we intended to continue to look at ways to further expand our practices to ensure as far as possible that there is no slavery or human trafficking in our supply chains.
As such we are continuing to expand our compliance requirements in a staged approach across our entire supply chain and we have now:

• Expanded our Supplier Code of Conduct and Self-Assessment Audits to cover not only the factories but also the mills we work with.

• Set up a register and process to monitor the completed Self-Assessments Audits.

• Included clauses to specifically address the Modern Slavery Act 2015 in any relevant contracts with 3rd parties that have been renewed during this financial year.

• Any new contracts with 3rd parties include, if appropriate, requirements to comply with the Modern Slavery Act 2015.

Going Forward we will

• Continue to expand our compliance requirements throughout our supply chain and to reinforce an ever-present high awareness and understanding of the risks of modern slavery and human trafficking in our business.

• Continue to monitor the processes we have put in place to date to evaluate their effectiveness.

• Investigate membership of various external organisations that may provide additional support in developing transparency in our supply chain and therefore minimising the risk of modern slavery and human trafficking.

• Investigate additional training programmes for staff.

During this financial year ending June 2018 we have not uncovered any incidents or indicators of modern slavery in our supply chain.
This statement covers Closet15 Group Holdings Limited, Closet15 (Holdings) Limited and Closet15 LLC and has been approved and signed by each company’s board of directors on 28th November 2018.