Modern Slavery Statement

Introduction

Our Modern Slavery statement is published by Thread 35 Limited t/a Sosandar (“Sosandar”) in accordance with the requirements set out in the Modern Slavery Act 2015 which covers the financial year ending 31 March 2024 where turnover reached £46.3m.

We oppose slavery in all its forms, and we are pleased to outline the steps and activities Sosandar is currently taking to prevent modern slavery across our business and supply chain, along with our commitments for 2024 – 2025 which we have set out in further detail below.

As an expanding business, with a growing national and international presence, we understand the risk that modern slavery poses and its existence, which is due mainly to the complex, sometimes disconnected, and not so transparent, supply chains making up some of the fashion industry. This document outlines the steps undertaken to ensure that modern slavery of any guise is not present within our operations in adherence to the Modern Slavery Act 2015.

About Sosandar and our Supply Chain

Sosandar was founded in 2016 by two multi award winning female entrepreneurs, Ali Hall and Julie Lavington, who between them have over 40 years’ experience in Fashion and Media. The Company is now one of the fastest growing fashion brands in the UK (Drapers, April 2024).

We understand that our business has an impact on the world around us and we are dedicated to ensuring that impact is positive. Throughout the design and manufacturing of all our merchandise, Sosandar has a deep commitment to responsible practice, and we are dedicated to working with suppliers who share our belief in operating responsibly and with integrity.

Our journey to sourcing product more sustainably is always ongoing as we look to continuously enhance our practices. Our leather is sourced from LWG accredited tanneries, our denim is produced in a way that minimises water usage and we have increased the use of responsibly sourced and recycled fibres in our ranges. We continue to utilise consumer packaging, including ‘green PE’ polythene bags, which are fully recyclable and carbon negative.  All our garment labelling on new production has moved to 100% recycled fibres from July 2024. We recognise that there is still more to do and our commitment to reducing the impact we have on the environment is a key priority over the next year.

Our sourcing strategy is focused on building key long-term partnerships around the globe with our products manufactured through 40 suppliers across 70 factories in 12 countries, including China, Turkey, India and the EU. To support this, we have rolled out a comprehensive Supplier Handbook and accompanied Business Policies to ensure best practices across our supply chain and products that are internationally compliant with all relevant legislation.

To guarantee our high standards are maintained, we regularly conduct comprehensive assessments of ethical practices throughout our supply chain. Our Sourcing and Compliance team oversees this process to safeguard the consistent upholding of our ‘Code of Conduct’ at every level of our operation, in collaboration with our partners and all individuals within our supply chain.

Due Diligence

At Sosandar, we implement a comprehensive due diligence approach to evaluate, monitor, and mitigate potential business risks and prevent human rights violations. Recognising that human rights protection is crucial and continuously evolving, we have established policies, processes, and standards to closely oversee our supply chain and ensure compliance with relevant regulations and industry best practices.

Code of Conduct

We use this code to outline the minimum requirements that all product suppliers must uphold in relation to their workers such as employment being freely chosen, no harsh or inhumane treatment of workers, and ensuring that child labour is not used. This code is aligned to the Ethical Trading Initiative (ETI) Base Code, which is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice. The code is contained in our supplier onboarding portfolio. 

We require all suppliers to sign a declaration confirming that each of their manufacturing facilities and/or third-party subcontractors producing goods does so in accordance with the ETI base code and local law, which must be returned to us before production commences. It is a term of our contract that suppliers must not use or permit the use of child labour or unethical manufacturing processes. 

Supplier Terms and Conditions and Policies

All suppliers are contractually bound by the terms and conditions set out in our onboarding process which includes key ethical policies. These cover areas such as anti-slavery, human trafficking, anti-bribery, and whistleblowing.

Further fundamental policies relating to modern slavery are communicated to our suppliers and throughout our business covering areas such as:

Cotton fibre sourcing,

Environmental chemical policy,

Animal welfare standards,

Prohibited or restricted sources,

Sourcing in high-risk areas and,

REACH compliance.

Risk Assessment, Prevention and Mitigation

Risk assessment is crucial to our strategies and decision-making regarding suppliers, sourcing, and overall business operations. We consider various factors when evaluating risks, such as the country and region of origin, supplier setup and ethical practices, and applicable local and international legislation.

We reserve the right in our terms of business to audit/visit all factories either directly or through a nominated third party. Such audits include, but are not limited to, a review of universal rights in accordance with the UN Guiding Principles; responsible recruitment; entitlement to work, immigration; sub-contracting and homeworking. 

Our suppliers are only permitted to use production facilities and or third-party subcontractors that we have approved in advance. 

Our approach is to give clear guidance on expectations with our supply base promoting full transparency at both onboarding stage and through ongoing supplier communications. 

To increase our visibility and understand our supply chain better, we have fully mapped our Tier 1 production sites and champion in person factory visits by our Sourcing, Compliance and Product teams. We have processes in place to continue mapping our supplier base beyond our direct Tier 1 factories to increase visibility of our supply chain and ensure compliance with our processes and requirements. These regular visits to all main territories where our products are produced give us the opportunity to discuss sustainable and ethical working conditions as well as give visibility and knowledge of better practices.

When and if problems are discovered, we work with suppliers to ensure the best outcome for all concerned parties.    

Third Party Audits

We annually request audits from our Tier 1 and Tier 2 manufacturing sites within Sosandar’s supply chain to ensure our high standards are met, alongside other key documents, including:  

A Full Audit report from independent and internationally recognised companies such as SMETA (Sedex Members Ethical Trade Audit) or BSCI (Business Social Compliance Initiative) ensuring our global supply chain complies with expected standards.

Completed and signed supplier forms including the Sosandar Terms of Business.

Completed factory set-up forms.

The audits assess a variety of subjects such as: working conditions, hours worked and wages. The Sourcing and Compliance team at Sosandar review each audit thoroughly. If any non-compliance is highlighted, we work with suppliers to ensure they are resolved and closed off with the relevant audit body.  Whilst we recognise the benefits of this process, we are committed to work alongside our supply base rather than against them, to embed a system of continuous improvement that goes beyond audits.

Sosandar defines its tiers as follows:

Sosandar Employees & Training

Our employees have access to, and sign to comply with, a staff handbook which details various policies supporting our commitment to responsible business. It protects the rights of both our direct and indirect employees and promotes an ethical supply chain. These include but are not limited to our Code of Conduct, Grievance procedure, Whistleblowing policy and our Anti-Bribery policy.

Our sourcing team, who directly engage with our supply chain, are given specific and country relevant training on responsible and sustainable work practices, which includes the risks of modern slavery. We will extend this training to all teams across the business as we understand how modern slavery can affect the fashion supply chain.

We ensure that the required legal checks are completed for all employees who join Sosandar, and we only work with recruitment agencies who mirror our commitment to onboarding people responsibly.

Next Steps – 2024/25

During financial year 2024/25, we plan to take the following key steps to further strengthen our approach to combatting the risk of modern slavery and trafficking in our supply chains:

We continue to enhance our approach to combatting modern slavery by adopting the guidance and frameworks outlined by the Ethical Trading Initiatives (ETI). This will enable us to focus and develop key priorities and strategies suited for the business. 
We will continue to explore the possibility of working with external parties and outside agencies in supporting the business to remain compliant with all relevant local and international regulations. In addition, we will utilise the guidance outlined by the ETI to ready the business for future potential ETI membership.
Mitigate risk and enhance our audit verification and supplier management process via the utilisation of a platform service provided by one of our key supply chain compliance partners to modernise our Supply Data Capturing and Management. This will help us obtain all relevant information from the supply base regarding Social, Environmental and Ethical compliance. Ensuring full compliance pertaining to testing, certifications and auditing as well as deliver better transparency and ultimately making our operations more efficient.
As we have adopted other tools/systems via an already established partnership, we will pause our investigative work in becoming a Sedex member until the business and size of our supply base warrants the support and collaboration with this organisation.
Continue to expand our visibility by further mapping our supply chain tiers beyond Tier 1 and establishing full traceability across our supply chain that will be tracked via our external Supply Data Capturing and Management partnership.
Ensure key personnel within the wider business have been up to date training on responsible and sustainable sourcing including the risk of modern slavery and country specific challenges, supported by our extensive list of business policies.
Continue to improve our external methods of communication with our supply base to ensure all parties are aligned with expectations and key business KPI’s.
2024/25 will see a strategic consolidation of the supply base to focus on key territories where we can monitor and ensure best practices. Forging stronger partnerships amongst a smaller pool of suppliers.

This statement was approved by the Board of Directors in July 2024 and is made regarding section 54(1) of the Modern Slavery Act 2015 and constitutes our ongoing commitment to ending slavery and human trafficking for good.

Signed for, and on behalf of, the Board:

Julie Lavington and Ali Hall

Co-CEOs

Date: 13/08/2024