Opening statement from Edward Griffith, LoveCrafts’ CEO and Founder
At LoveCrafts we're here to build an online home for makers; a place to shop craft supplies and feel inspired. What's just as important as building a community for makers, is how we do it. We care about the impact we have on the world, and how we can create a better place to live and work. This means ensuring our business and supply chain reflect our ethical values and respect for human rights. We are passionate about creating a happy home for our employees and our customers alike, and there is no place for exploitation of any kind in our business. We're committed to improving our practices to combat all forms of exploitation - particularly slavery, servitude, forced or compulsory labour (including child labour) and human trafficking.
While the greatest risks of modern slavery are typically associated with countries outside the G20, it is within the G20 that most products of the crime of modern slavery are sold. We have a responsibility to ensure we prevent this from happening within our business or supply chain.
Who we are
LoveCrafts is a leading international platform for the crafts market. We began in 2012, with a simple mission to help makers find all their knitting supplies and inspiration in one place. Since then, we’ve expanded beyond knitting, to carry products in crochet, papercraft, sewing, embroidery, cross stitch, needlepoint, and quilting, with more craft categories in the pipeline.
LoveCrafts is the UK parent company of a group of companies, which includes our trading entities in the UK and US (namely LoveCrafts Makers Limited, Lovecrafts Inc and Valley Fibers Corporation (trading as “WEBS”)) and our subsidiary in Ukraine, which operates as a service company. We employ approximately 250 members of staff globally.
As an international platform, we have customers all over the world. Our sales are approximately 34.5% in the UK, 57.3% in North America, 2.7% in Australia and New Zealand combined, 4.4% in the EU and 1.2% in ROW.
Our supply chain
Crafting supplies are available on our platform from hundreds of distributors and brands globally, which we refer to as our “third party suppliers”. We also work directly with over 20 manufacturers to develop and source a growing range of exclusive, proprietary products that we sell under our own brands. We refer to these suppliers as our “private label suppliers”. Our supplier network covers a number of product types and materials, including cotton fabrics, cotton and other yarns, crafts materials and craft accessories. Third party suppliers are mostly based in the United States, United Kingdom and Europe, with some additional suppliers based in Canada, India and the Netherlands, with more added every week. Our private label suppliers are also largely based in the United States and Europe (particularly Italy, Bulgaria, Greece), with additional significant private label suppliers located in Turkey, Brazil and Peru, among others.
During the process of compiling this statement, we engaged with 114 suppliers of stock. Of those 114 suppliers, we determined that 34 of our suppliers have a moderate to high risk profile based on their location, or the nature of products provided.
We partner with many other service providers, in order to facilitate our end-to-end business operations. These include software providers, professional advisers, companies that provide marketing solutions, logistics companies and carriers: essentially, all the providers a business would require to seamlessly support a customer’s purchase journey and/or online community visit from start to end. We have assessed that risk levels with these service providers are low, based on the nature of the services they provide, their locations and their relatively simple supply chains. We have, however, included them in our due diligence process described below (unless they fell under very minimal financial thresholds) in order to fully benchmark our current risk profile so that we may effectively assess our progress over the next 12 months.
We partner with Clipper Logistics plc in the UK and DM Management in the US as our third party logistics providers - these are reputable partners with whom we have long held relationships and visit regularly. We have a high level of visibility over these facilities. WEBS also maintains warehouses out of two separately leased properties in Massachusetts, USA, over which we have full control and full authority to maintain the wellbeing of our workers with appropriate health and safety policies and procedures in place.
Our due diligence process
Prior to publishing this statement, we took specific steps to identify, assess, and monitor potential areas of risk in relation to our supply chains.
- We sent a detailed questionnaire covering modern slavery issues to all our material ongoing suppliers, both stock and non-stock (excluding those with whom we did very little business in either value or frequency).
- We collated, reviewed and assessed all responses, assigning risk levels (1-3) to each supplier. “1” being the highest risk based on value to the business, location, or type of product.
- For those suppliers assigned a “tier 1” risk level we have taken further steps to independently verify the responses and assign further actions. Actions include meetings, further questions and potential for external audits to address specific risks.
- Using the Global Slavery Index, we have identified that our biggest risk area of forced labour is in relation to the supply of cotton as a raw material. We have taken extra precautions to investigate our supply of any goods that fall under this category.
- In response, we've set an internal policy for how we will deal with non-compliance and/or non-cooperation of our suppliers.
Our ‘onboarding’ process for new suppliers includes robust conversations about human rights (including modern slavery), animal welfare, sustainability and other social and environmental issues. This is supplemented with regular ongoing conversations with suppliers. Although site visits have been temporarily paused due to Covid-restrictions, they will resume as soon as reasonably possible.
Our internal policies in relation to slavery and human trafficking
As part of our commitment to combat modern slavery and human trafficking, as well as to ensure that our own workers have a safe environment in which to work, we have already implemented robust and comprehensive policies, including the following:
Whistle Blowing (“Open Disclosure”) Policy
Our open disclosure policy sets out the process for our employees to raise any concerns they may have in relation to compliance with our legal obligations, including in relation to modern slavery and human trafficking, and to ensure that there is adequate protection for employees who make protected disclosures or "blow the whistle". Disclosures can be made anonymously if preferred.
Anti-Bribery and Corruption Policy
We have recently reviewed our Anti-Bribery and Corruption Policy to ensure that it deals with the specific risks faced in our business in the jurisdictions where our operations are based. Implementation is in progress and compulsory training for all staff will follow to ensure a full understanding, and acceptance of the legal requirements and ethical issues.
Anti-Bullying and Harassment policy
This policy sets out our commitment, under the Equality Act 2010, to provide a work environment free from bullying or harassment to enable employees to reach their full potential. It details what constitutes bullying and harassment and mechanisms for dealing with any issues which might arise.
Diversity and Equal Opportunities Policy
LoveCrafts firmly believes that everyone has a right to work in an environment that provides equal opportunities, fairness and respect for all, regardless of race (including colour, nationality, and ethnic or national origin), religion, sex, sexual orientation, gender reassignment, marital status, age, disability or social background. As such, we commit to provide a working environment where everyone’s individuality and unique contributions are recognised, valued and respected, and where all of our employees have equal opportunity to grow and attain their full potential.
Under our Diversity and Equal Opportunities Policy, we have established a cross-functional team to propose, develop and support diversity and inclusion initiatives. To date, this group has been responsible for supporting and/or pushing forward 15 initiatives that have directly impacted the day to day working environment at LoveCrafts. This includes a robust Diversity & Allyship Training course that, by the end of this quarter, will have been completed by the majority of LoveCrafts employees.
Understanding the potential for abuse in the labour force, we have implemented robust processes during our recruitment process to confirm that all potential employees have the legal right to work in the location they have been employed and insist on the same from any employee service providers with whom we engage globally.
We want to do everything we can to put a stop to any chance of modern slavery or human trafficking in our business or supply chains. We're also committed to mitigating the risk of any other vital environmental, societal, and governance issues. While we have made a robust start to ensure our supply chain is free from slavery and human trafficking there is much more we can do.
This is what we plan to do in the next 12 months:
- If site visits can take place safely within the constraints imposed by Covid-19, we will resume visits to our private label suppliers and key third party suppliers to assess compliance in person. Until such visits can be conducted safely, we are exploring the engagement of external auditors to investigate any areas of concern, or higher risk product supplies, particularly with regard to any vendors that, directly or indirectly, supply cotton as a raw material;
- In our regular meetings with suppliers, we will continue to cover modern slavery issues as a regular agenda item, and in particular follow up with any suppliers where there are concerns relating to survey responses;
- In our next published version of our Supplier Handbook we plan to include a requirement that all suppliers certify that they do not utilise forced, prison, or endangered labour, or subject workers to any form of compulsion or coercion.
- We are developing a Supplier Management Policy that will enable LoveCrafts’ employees (particularly in procurement roles) to implement our standards for ESG requirements, including Diversity and Inclusion, Modern Slavery and Sustainability for existing suppliers and as part of our onboarding process.
- We will repeat our supply chain audit in May 2022 with a view to provide a further statement in relation to FY22.
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes Lovecrafts Group Limited’s slavery and human trafficking statement for the financial year ending 31 March 2021.
Edward Griffith, CEO and Founder, on behalf of the Board of Directors