1. Introduction and Commitment

Naked Apparel Ltd. is a brand committed to conducting all business dealings in an ethical, transparent, and socially responsible manner. We are committed to preventing acts of modern slavery and human trafficking from occurring within our business and across our supply chain.

This policy reflects our commitment to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our operations, in compliance with the Modern Slavery Act 2015 (MSA 2015).

 

2. Scope and Responsibility

This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, third-party representatives, and, crucially, our supply chain partners. 

The ultimate responsibility for ensuring this policy complies with our legal and ethical obligations rests with the Directors of Naked Apparel Ltd.

 

3. Definition of Modern Slavery

Modern slavery is a term used to describe a range of serious human rights violations. Naked Apparel Ltd. defines modern slavery in accordance with the MSA 2015, covering:

• Slavery: Where a person is owned or controlled by an 'employer'.
• Servitude: Similar to slavery, but often a form of forced labour where a person is forced to work against their will for little or no pay.
• Forced or Compulsory Labour: Any work or service exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.
• Human Trafficking: Arranging or facilitating the travel of another person with a view to that person being exploited.

 

4. Our Supply Chain and Due Diligence

As a clothing brand, our supply chain is extensive and involves sourcing materials, manufacturing, and logistics, often across multiple international jurisdictions. We recognise that this complexity carries an inherent risk of modern slavery.
To mitigate this risk, our due diligence processes include:

4.1 Supplier Onboarding and Audits

• Initial Vetting: New suppliers are subject to rigorous checks, including requests for evidence of their own anti-slavery policies and ethical certifications.
• Contractual Obligations: All supply contracts include specific clauses requiring compliance with the MSA 2015, international labour standards, and our Supplier Code of Conduct.
• Auditing: We reserve the right to conduct announced and unannounced audits of suppliers (or use reputable third-party auditors) to verify compliance with fair labour practices and working conditions.

4.2 Risk Assessment

We regularly assess the risk of modern slavery by considering:

• The geographical area of operation (countries with known human rights concerns).
• The type of industry (e.g., textile production is a higher-risk sector).
• The nature of the service provided.

 

5. Our Expectations: Supplier Code of Conduct

We require all suppliers to meet the following ethical labour standards:

1. Employment is Chosen: Employment must be voluntary, and workers must be free to leave their employment upon reasonable notice.
2. No Child Labour: No person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest, shall be employed.
3. Wages and Benefits: Wages must meet, or exceed, the national legal minimum standard or industry benchmark, whichever is higher, and be paid regularly.
4. Working Hours: Working hours must comply with national laws and should not be excessive. Overtime must be voluntary and compensated at a premium rate.
5. No Harsh or Inhumane Treatment: Physical abuse, threats of violence, or psychological abuse are strictly prohibited.

 

6. Training and Awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking, we provide appropriate training to relevant members of our staff, particularly those involved in supply chain management, procurement, and human resources.

7. Reporting and Whistleblowing

Employees, suppliers, and external parties are encouraged to report any concerns, suspicions, or knowledge of modern slavery practices immediately.

Concerns can be reported confidentially via:

• Customerservice@nakedapparel.co.uk

All reports will be taken seriously, investigated thoroughly, and handled in confidence. No employee who reports a concern in good faith will suffer any detrimental treatment as a result.

 

8. Breach of Policy

Any breach of this policy, including failure by a supplier to uphold the standards outlined in our Supplier Code of Conduct, will be treated with the utmost severity.

Depending on the gravity of the breach, actions may include:

• Immediate termination of the contract or business relationship.
• Reporting the matter to the appropriate authorities.

9. Policy Review

This Anti-Slavery and Human Trafficking Policy will be reviewed annually by the Directors of Naked Apparel and updated as necessary to reflect changes in legislation, risk profile, and best practice.