Modern Slavery Act

High Seat Holdings Limited

Modern Slavery Act Statement for the year ended 31st December 2018.

This statement is written in accordance with Section 54 of the Modern Slavery Act 2015 in relation to the financial year ended 31st December 2018. 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 what further steps 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 take steps 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

During 2018 HSL celebrated its Golden Jubilee.  Over our 50-year history, 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 partners.  We sell only directly to consumers through a network of 59 retail stores across the UK and a national home consultation operation.

In 2018 we employed an average of 524 people, based solely in the UK.  These staff operate from Comfort House: our factory, head office and warehouse facilities in Batley, West Yorkshire; as a well as our stores and remote operations nationwide.

The Group’s supply chain

Across all of our product ranges, there is a significant focus on British manufacturing.  In the year ended 31st December 2018, in value terms a very significant majority of customer orders placed were of products manufactured in the UK, either by HSL itself, or through three key UK manufacturing partners, all of which are long-established and reputable businesses.  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 one include the close involvement of HSL’s board of directors and senior management team.

Other internationally-sourced products, including occasional furniture historically sold through HSL’s stores, represented an insignificant proportion of the Group’s sales during the year (less than half of one percent), and we made the strategic decision to exit these partnerships either during the year or in early January 2019.

Even within the UK-based supply chain, HSL’s proportion of in-house manufacturing continued to grow over the course of 2018, and during the year a number of historical partnerships ended and were either brought into our own factory, or consolidated into the Group’s more focussed third party supply chain.

Within HSL’s manufacturing operations, raw materials, including wood, foam, fabric, mechanical actions, motors and handsets, are sourced from longstanding suppliers, many of these 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 the Group.

Our distribution activities are fulfilled by a combination of HSL’s in-house logistics operations and by third party carriers who deliver furniture on our behalf.  We directly employ our delivery drivers and warehouse operatives.  Our third party carriers are also based in the UK, and more than 90 percent of our delivery volumes during 2018 were managed by two other key partners with whom we have worked in close collaboration for several years.  Consistent with other Group operations, the proportion of logistics activity fulfilled by our own delivery teams increased during the year, and in addition we invested in logistics staff and infrastructure which laid a platform for further growth in our own distribution volumes in the first half of 2019.  This increases our visibility and 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 with all significant suppliers our commitment to the Modern Slavery Act, the standards we expect from them, and our stance that HSL will not tolerate any breaches of the act by suppliers.

Due diligence processes

HSL is a family business, and continues to be owned and managed by the family which established it in 1968. The trusted brand we have carefully built over that period continues to be based on traditional family values and a passionate care for people, be this customers or colleagues.  All members of staff, through structured training programmes and brand communication recognise their collective responsibility for protecting that brand and the Group’s wider role in society.

The performance and suitability of our third party suppliers is monitored and measured through ongoing customer satisfaction assessments, undertaken via 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 HSL’s centralised People Support team.  This includes checking that all appropriate right-to-work documentation is in place.  Furthermore, all recruitment activity 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 real-time and, periodically, more formal feedback from staff across the Group, including the opportunity to report any concerns in relation to human rights.  These channels include clear management hierarchies, regular staff listening groups with directors, and a confidential annual employee engagement survey sent to all employees in the business, which we again undertook during the year.

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 a relatively small number of suppliers, we acknowledge there is always a risk of exposure to modern slavery within our supply chain.

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.

Employee training

During 2019 we will implement a programme of external training for staff for whom the implications of the Modern Slavery Act could impact upon their roles, to ensure that the Group’s knowledge of risks of Modern Slavery reflects current industry guidance and best practice.

Assessment of effectiveness

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

  • Have increased the share of product manufactured in-house, or managed by in-house service functions.
  • Further invested in the relationships and 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.  As such, in 2019 we intend to:

  • Write to all suppliers to remind them of our commitment to the Modern Slavery Act and that we will not tolerate any breaches of the act by suppliers.
  • Continue to explore the appropriateness of visits to suppliers, in particular those operating overseas.
  • Undertake wider scale communication across our workforce to build a wider understanding of the risks of modern slavery and human trafficking.

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

22nd May 2019