Modern Slavery Act 2021
High Seat Holdings Limited
Modern Slavery Act Statement for the year ended 31st December 2021.
This statement is written in accordance with Section 54 of the Modern Slavery Act 2015 in relation to the year ended 31st December 2021. 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 and mitigate the risk of modern slavery arising in our business and supply chain, and the ongoing actions which we intend to take.
We remain committed to taking all practical steps 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 subsidiaries have manufactured and sold furniture to consumers, typically of an older demographic. We improve the lives of our customers through ranges of products which give postural support, enhance comfort and make sitting and standing easier. We design and produce a large majority of these products in our own factory in Batley, West Yorkshire, as well as working with a small number of carefully selected partners. We only sell to consumers directly, via 53 retail showrooms and a national ‘Home Visits’ operation.
In 2021 the Group employed an average of 469 colleagues, who were all based solely in the UK. Most of these colleagues work from one of our showrooms around the UK, or at Comfort House: our factory and office facility. A number of field-based colleagues visit customers in their home or deliver furniture, but these are typically based either from one of our showrooms or our two warehouse locations, and so work in close collaboration each day with fellow HSL colleagues.
HSL’s supply chain
There is a significant focus on British manufacturing across all product ranges. In the year ended 31st December 2021, a very large majority of orders placed by customers continued to be of products which are manufactured in the UK.
Although HSL’s supply chain for products is dominated by our own factory, the balance of UK furniture supply largely comprises two manufacturing partners, both also based in Yorkshire, which have each operated in the upholstered furniture industry for more than 50 years.
Almost all of the small minority of 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 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 we have typically worked with for many years and who HSL manages via board-level relationships.
During 2021, the Group extended its in-house logistics operations such that, by the end of the year, the majority of customer deliveries were completed using our own colleagues and infrastructure. This included the Group signing leases on two new warehouses and more than doubling the headcount of our directly-employed logistics team which operates from these sites.
Although our external delivery volumes are now low, during the year under review we worked predominantly with two UK-based, national delivery partners, which are both family-owned businesses which share HSL’s values. Again, these relationships are managed day-to-day by senior-level colleagues within HSL.
Collectively, this vertical nature of our business means we consider that 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 was established by the Burrows family in 1968 and is still owned and managed by the same family today. Our brand continues to reflect the same traditional values of trust, integrity and a passionate care for people that it was founded with. All colleagues, through structured training programmes and internal communications, recognise their collective responsibility for protecting our brand and the Group’s responsibilities to society. This is also reflected in ongoing actions to enhance our positive social impact including the recruitment of an Environment and Sustainability Manager to the Senior Management Team during the year.
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 board of directors. Agency labour, albeit representing a small proportion of the Group’s working hours and typically used to address absence or temporary recruitment gaps, is again managed by HSL People Support and coordinated through established recruitment agencies within the UK. Such temporary staff have clear induction processes and oversight by HSL’s team leaders and managers.
Several channels exist to allow feedback from all HSL colleagues, including the opportunity to report any concerns. These include clear management and support structures, staff listening groups, and a confidential annual engagement survey sent to all colleagues in the business. Colleagues are also given free access to a confidential Employee Assistance Programme, offering counselling and guidance to those who need it.
The Group’s Board of Directors has overall responsibility for corporate governance, including HSL’s anti-slavery initiatives. Despite the Group’s supply chain being heavily weighted towards the UK, and key suppliers comprising relatively few businesses in volume terms, 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 information to the relevant authorities; and
- Immediately suspend or terminate any associated business arrangement or contract.
Assessment of effectiveness
During 2021, like many other British businesses, HSL continued to experience 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. This has included the use of training courses on Modern Slavery risks during the year for colleagues involved in areas where a risk of modern slavery would be most likely to exist.
The impacts of COVID-19 and these supply chain volatilities have meant the need for increasingly regular contact with suppliers, including the rapid deployment of innovative technologies which improve channels of communication. This goes to maintain strong oversight across our supply chains. Where changes occur within the supply chain, we have continued to apply our supplier due diligence processes, which are proactively 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.
HSL is a vertically integrated business, with a long established, trusted brand that it does its utmost to protect. The group’s evolution over recent years have continued to grow its direct control of its supply chain as an increasing number of activities have been fulfilled in house, and this dynamic is expected to continue.
The group will continue to refine processes which minimise risk: developing the transparency of supplier relationships and ensuring that training and support are sufficient to ensure that the risks of modern slavery remain visible to all colleagues across the Group.
This statement is approved on behalf of the Board by William Burrows, Group Chairman.
25th May 2022