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Modern Slavery Act 2019

High Seat Holdings Limited

Modern Slavery Act Statement for the year ended 31st December 2019.

This statement is written in accordance with Section 54 of the Modern Slavery Act 2015 in relation to the financial year ended 31st December 2019. It sets out the steps High Seat Holdings Limited and its subsidiaries, High Seat Limited and HSL Manufacturing Limited (together “HSL” or “the Group”) have taken to assess the risk of modern slavery arising in our business and supply chain.  It also sets out the ongoing actions which we intend to take to mitigate the risk of it arising.

 

Commitment

The Group is committed to taking all appropriate actions to support the abolition of modern slavery. We will not tolerate any form of slavery, forced labour or human trafficking.  We continue to implement controls and refine business processes which can mitigate the risks of modern slavery within the Group’s operations and supply chain.

 

Overview of the Group

For more than 50 years, the Group’s trading subsidiaries have manufactured and sold specialised furniture ranges, which are ergonomically designed to offer support and a personalised fit for customers.  We improve the lives of our customers by providing products which enhance comfort and posture, and make sitting and standing easier.   We design and hand-make the large majority of these products in-house as well as working with a small number of carefully selected manufacturing partners.  We only sell to consumers directly, via a network of 55 retail stores and a home visits operation which allows customers around the UK to experience HSL’s products in their own home before making a purchase.

In 2019 we employed an average of 569 people, based solely in the UK.  The majority of HSL colleagues work at Comfort House: our factory, head office and warehouse facilities in Batley, West Yorkshire or within one of our 55 stores around the UK.  Additionally, there are a smaller number of field-based colleagues, who for example undertake home visits and home delivery services. These employees too are typically based either from Comfort House or an HSL store, and so work in close collaboration with fellow HSL colleagues.

 

The Group’s supply chain

Across all of our product ranges, there remains a significant focus on British manufacturing.  In the year ended 31st December 2019, a very significant majority of orders placed by customers, in value terms, were of products manufactured in the UK.

HSL’s UK supply chain for products is dominated by HSL’s own factory, which continued its growth trend reported in recent years, further growing its share of overall supply, partly as a consequence of ending a relationship with one of its previous furniture suppliers part way through the year.  The balance of UK supply largely comprises two manufacturing partners, both of which are reputable British manufacturers which share HSL’s values and which have operated in their respective markets for many years.

Almost all of the small minority of upholstered furniture which is made outside of the UK is sourced from a single, reputable international group headquartered in Europe.  The coordination of key partnerships such as this are overseen by HSL’s board of directors and are closely managed day-to-day by HSL’s senior management team.

Within HSL’s manufacturing operations, raw materials including wood, foam, fabric, lift-and-recline mechanisms, motors and handsets are sourced from longstanding suppliers.  Many of these are wholesalers and converters based in the UK, Europe and the United States.  Again these are underpinned by a small number of key suppliers, who are managed by board-level relationships within HSL.

Our distribution activities are fulfilled by a combination of HSL’s in-house logistics team and by third party carriers who deliver to customers on our behalf.  Our own delivery business, which grew as a proportion of total delivery volumes in 2019, directly employs its delivery drivers and warehouse operatives who operate from our own facilities, predominantly our warehouse at Comfort House.  Our external delivery partners are also based in the UK, and a large proportion of the volume of their business during 2019 was managed by two key logistics partners with whom we have worked in close collaboration for several years.

Collectively, this vertical nature of our business means we have high visibility and strong control over our supply chain.

 

Our policies on slavery and human trafficking

HSL is committed to protecting human rights in its business and the supply chain.  We have a group purchasing policy and standard procurement terms and conditions, which include an anti-slavery policy.

We formally document our commitment to the Modern Slavery Act, the standards we expect from each of our key suppliers, and we are clear in our stance that HSL will not tolerate any breaches of the act by suppliers.

 

Due diligence processes

HSL remains owned and managed by the family which established it in 1968. The brand which we have carefully built over the last 52 years continues to be based on the same traditional values of trust, integrity and a passionate care for people, be this customers or colleagues.  All members of staff, through structured training programmes and internal communications, recognise their collective responsibility for protecting our brand and the Group’s responsibilities to society.

The performance and suitability of our third party suppliers is monitored through ongoing measurement of customer satisfaction scores, through follow-up calls from our customer services team, customer questionnaires and other independent customer feedback mechanisms including Trustpilot.

Recruitment activity is rigorous and follows clear procedures, managed by a centralised People Support team, including checks that all appropriate right-to-work documentation is in place.  All recruitment is overseen by members of the senior management team and ultimately approved by a director.  Temporary labour, albeit representing a small proportion of the Group’s working time and used to help manage sickness absence or temporary recruitment gaps, is again managed by the People Support team and coordinated through established recruitment agencies in the UK.

A number of channels exist to allow feedback, both formal and real-time from all HSL colleagues, which would include the opportunity to report any concerns in relation to human rights.  These channels include clear management and support structures, regular staff listening groups, and a confidential annual employee engagement survey sent to all colleagues in the business, which we undertook again in 2019.

 

Risk assessment

The Group’s Board of Directors has overall responsibility for corporate governance, including any anti-slavery initiatives.  Despite the Group’s supply chain being heavily weighted towards the UK, and key sources of supply spanning relatively few suppliers overall, we acknowledge there is always a risk of exposure to modern slavery.

The close involvement of board members in all areas of operation means that if issues were identified or we had reasonable grounds to suspect any slavery or human trafficking within the supply chain, this would be appraised by the board and appropriate action quickly taken to:

  • Protect whistle-blowers.
  • Report such suspicions and provide appropriate information to the relevant authorities.
  • Immediately suspend or terminate any associated business arrangement or contract.

 

Assessment of effectiveness

As part of our continued commitment to mitigating any risks during the year we have:

  • Further increased the share of product manufactured in-house or managed by in-house service functions.
  • Continued to develop the frequency of senior-level contact with our largest suppliers; in particular in our manufacturing supply chain which continues to grow in significance within our Group.

However, we recognise that the commitment to a zero-tolerance policy to human rights abuse is a process of continuous improvement and we will continue to regularly assess the effectiveness of our programme.

 

Future impacts

In 2020, the impact of the COVID-19 pandemic has severely impacted on UK business. Many of HSL’s operations were forced to temporarily close following government measures introduced on 23rd March 2020, and our stores and factory did not reopen until late May 2020.

 

Since reopening, like many other British businesses HSL has continued to face both volatility in consumer demand and disruption in its supply chains. However, our focus has remained on our core values and the safety and wellbeing of people, both in the UK and worldwide.

 

Although COVID-19 has meant the need to adopt new ways of working, our relationships with our key suppliers are closer than ever – enhanced by the use of technology.  COVID-19 has forced some changes within the supply chain, including the addition of a new partnership with a third UK-based logistics partner, but these have continued to reflect our supplier due diligence policies and remain closely managed by senior colleagues and overseen by the board.

This statement is approved on behalf of the Board by Group Chairman William Burrows. 

 

 30th November 2020

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