UK Modern Slavery Bill

Friday, June 19, 2015

UK Modern Slavery Bill - 
Specialized Disclosure

"Human trafficking affects us all, whether we live in countries of origin, transit or destination. Preventing and combating it requires a comprehensive international approach. We must act together to stop a crime in our midst that deprives countless victims of their liberty, dignity and human rights."

-Ms. Asha-Rose Migiro Deputy Secretary-General of the United Nations

Specialized is committed to upholding human and labour rights, ensuring that every worker has safe and fair working conditions and that there is 'zero tolerance' for human trafficking and slavery in our supply chain.

The policies, procedures and operations outlined in our Sustainable Innovation Program incorporates explicit prohibition of human trafficking and slavery and addresses issues of human trafficking and slavery required under the UK Modern Slavery Bill, as well as addressing other issues of social and environmental sustainability. Standards for workplace conditions for our supply chain partners are outlined in our Code of Conduct and the code element Forced Labour specifically calls out our commitment to prohibiting human trafficking and slavery anywhere in our direct and indirect supply chain.

Below is our disclosure statement pursuant to the UK Modern Slavery Bill.

The disclosure described in subdivision (a) shall, at a minimum, disclose to what extent, if any, the retail seller or manufacturer does each of the following:

1. Verification of supply chains to evaluate and address risks of human trafficking and slavery.
Specialized is a founding member of the WFSGI Bicycle Industry Labour group, which is currently piloting labour standards, auditing protocol and the creation of a shared database of audit results via the Fair Factories Clearinghouse (FFC). Our Code of Conduct is based on the International Labour Organization (ILO) code and states that any form of forced labour, which includes human trafficking, slavery and child labour are prohibited in our supply chain.

2. Audits of suppliers to evaluate supplier compliance with Specialized's standards for trafficking and slavery in supply chains.
Specialized has created both Code of Conduct and Zero Tolerance policies for labour practices and implemented a process for consistent and ongoing auditing of it’s supply chain to ensure compliance with those policies. Proposed new suppliers must undergo auditing and evaluation of their facilities and labour practices before they may be considered to become a formal supplier. Evaluation of those audits is conducted by a senior leadership team, which includes environmental and social responsibility leadership. Proposed suppliers unable to meet our standards will not be considered to participate in our supply chain. This system ensures that we do not contract with new suppliers engaging in substandard human rights practices.

Auditing suppliers with regard to sustainable manufacturing, specifically slavery and human trafficking, is a high priority for Specialized. Audits are conducted through a combination of internal staff, contract labour consultants and third party auditing firms.

3. Certification by suppliers that materials comply with slavery and human trafficking laws of the country where they are doing business.
A key focus of our communication strategy with our suppliers is in building a clear understanding of the risks of non-compliance with our code of conduct, especially around the topics of human trafficking and slavery. Our goal is to build capacity with our suppliers so that they may certify their own suppliers and verify the eradication of human trafficking and slavery further up complex supply webs.

Suppliers are required to acknowledge their understanding of our Code of Conduct by formerly signing a document confirming the factory’s adherence to it’s requirements. In addition, we regularly evaluate a factory’s practices of managing for eradication of human rights and slavery and include that evaluation in our supplier scorecards.

4. Procedures for failures to meet Specialized's standards regarding slavery and human trafficking.
Specialized has developed internal policies & procedures that incorporate disciplinary actions appropriate to the issue at hand with separate tracks for the evaluation of new suppliers and the evaluation of existing suppliers. The focus is on remediation and executing swift solutions for the protection of human rights as well as excluding new suppliers from our supply chain who fail to meet our Code of Conduct and Zero Tolerance Policy.

Our Zero Tolerance policy outlines a swift and binding course of action, requiring immediate factory response and remediation of the identified issue by the factory in question. Issues Specialized strictly prohibits, condemns and has zero tolerance for must be given the highest level of attention and immediate resolution or Specialized reserves the right to cease business with that supplier.

5. Training on human trafficking and slavery, including mitigating risks within the supply chain
Specialized has an ongoing internal training program for employees to understand the issues relating to social and environmental responsibility with a focus on human trafficking and slavery in manufacturing. This training is also extended to suppliers with a long-term partnership approach to remediating issues in conflict with our Code of Conduct in the supply chain.

We understand that accountability is key to an authentic commitment to sustainable manufacturing. Specialized's corporate policy for sustainable manufacturing has been communicated throughout the company, it’s supply chain and informs the ongoing work being carried out in product creation.