Modern Slavery Act 2020

High Seat Holdings Limited

Modern Slavery Act Statement for the year ended 31st December 2020.

This statement is written in accordance with Section 54 of the Modern Slavery Act 2015 in relation to the financial year ended 31st December 2020. 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

We are committed to taking all appropriate actions across the Group to support the abolition of modern slavery. We will not tolerate any form of slavery, forced labour or human trafficking.  We strive to implement and enhance controls which mitigate the risks of modern slavery within our operations and supply chain.

Overview of HSL

Since 1968, the Group’s trading subsidiaries have manufactured and sold specialised furniture ranges for individuals, typically of an older demographic.  We improve the lives of these customers through products which enhance comfort and postural support, and make sitting and standing easier.  We design and manufacture a large majority of these products in-house, as well as working with a small number of carefully selected partners.  We only sell to consumers directly, via a network of retail 55 showrooms at 31st December 2020 and a national Home Visit operation which together allow customers to experience our products before making a purchase.

In 2020 the Group employed an average of 514 people, based solely in the UK.  The majority of colleagues work within one of our showrooms around the UK; or at Comfort House: our factory, head office and warehouse facility in Batley, West Yorkshire.  A number of field-based colleagues undertake home appointments and delivery services; but these too are typically based either from Comfort House or one of our showrooms, and so work in close collaboration with fellow HSL colleagues.

HSL’s supply chain

Furniture

There is a significant focus on British manufacturing across all of our product ranges.  In the year ended 31st December 2020, a very significant majority of orders placed by customers were of products which were manufactured in the UK.

HSL’s UK supply chain for products is dominated by its own factory based in Batley, West Yorkshire.  The balance of UK furniture supply largely comprises two manufacturing partners, both also based in Yorkshire, which have operated in the upholstered furniture industry for more than 50 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.

Manufacturing components

Within HSL’s factory operations, raw materials including timber, foam, fabric, lift-and-recline mechanisms, and electrical components 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 HSL board-level relationships.

Indeed during 2020 the impact of COVID-19 necessitated even closer working relationships and the use of new technologies to improve the ease and regularity of open dialogue.

Logistics operations

Our distribution activities are fulfilled by a combination of HSL Logistics – own in-house delivery team – and by third party carriers who deliver to customers on our behalf.  HSL Logistics, which contributes a large proportion of our total delivery activity, directly employs drivers and warehouse staff who operate from our own facilities, in particular our warehouse at Comfort House.

Our external delivery partners are also UK-based.  We worked predominantly with three national, ‘2-man’ delivery partners during 2020; and our two continuing relationships at the end of 2020 are family-owned businesses which share HSL’s values and which are managed day-to-day by senior-level colleagues within HSL.

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 supply chain.  We have a Group purchasing policy and standard buying terms and conditions, which include an anti-slavery policy.

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

Due diligence processes

HSL remains owned and managed by the family which established it 53 years ago.  Our brand continues to reflect the same traditional values of trust, integrity and a passionate care for people that it was founded with.  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, follow-up calls from HSL’s customer services team, customer surveys and other independent feedback mechanisms including Trustpilot.

Recruitment activity is rigorous and follows clear procedures, managed by our 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 authorised by the directors.  Agency labour, albeit representing a small proportion of the Group’s working time, used to address absence or temporary recruitment gaps, is again managed by HSL People Support and coordinated through established recruitment agencies in the UK.

A number of channels exist to allow feedback from all HSL colleagues, including the opportunity to report any concerns in relation to human rights or similar matters.  These channels include clear management and support structures, staff listening groups, and a confidential annual engagement survey sent to all colleagues in the business.

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, the directors understand that there is always a risk of exposure to modern slavery.

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

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

Assessment of effectiveness

In 2020, the COVID-19 pandemic severely impacted on many businesses in the UK. A large proportion of HSL’s operations were forced to temporarily close following the government measures introduced on 23rd March, and our showrooms and factory did not reopen until late May 2020.

For the remainder of 2020, like many other British businesses, HSL continued to face both volatility in consumer demand and disruption in its supply chains. However, our focus has remained on our core values and our responsibilities to society including the safety and wellbeing of people, both in the UK and worldwide.

The actions taken during the pandemic included ensuring that rigorous safety measures were in place to protect staff and customers from the disease and that these were regularly reviewed.  It also ensured that adequate headroom existed in financing facilities to allow business controls to be consistently maintained even in the event of repeated future economic downturns.

Although the pandemic meant the need to adopt new ways of working, the relationships, both with staff and our key suppliers, were closer than ever – enhanced by the use of technology.  COVID-19 and the end of the Brexit transition period together led to some changes within our supply chain, including the addition of a new logistics partner and a trend towards sourcing a greater share of components from within or closer to the UK.  These have continued to adopt our supplier due diligence processes and remain closely managed by senior colleagues and overseen by the board.

We recognise that the commitment to a zero-tolerance approach to abuses of human rights is a process of continuous improvement. We will continue to regularly assess our effectiveness in this regard.

Future impacts

In early 2021, further lockdown measures continued to impact on UK consumer behaviour; however these began to be eased as measures were relaxed from April 2021 onwards.

As the UK emerges from the pandemic, our colleagues increasingly return to work and our operations revert to normal levels, our focus will be on continuing to refine processes which minimise risk, developing supplier relationships and ensuring that training and support are sufficient to ensure that the risks of modern slavery remain visible of all colleagues across the Group.

 

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

 

 16th June 2021

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