Modern Slavery Statement 2022Published on September 27, 2022
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. We are now in our second year of reporting under the Modern Slavery Act and our statement below sets out what we have implemented since last year, as well as our plans for the next 12 months.
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, paper craft, 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 230 members of staff globally.
As an international platform, we have customers all over the world. Our sales are approximately 28% in the UK, 65.1% in North America, 2.6% in Australia and New Zealand combined, 2.4% in the EU and 1.9% 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 North America, South America and Europe.
During the process of compiling this statement, we engaged with 122 suppliers of stock. Of those 122 suppliers, we determined that 32 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. Based on this risk assessment, formed having surveyed each one last year, we have not resubmitted our questionnaires to these providers this year, but will reassess risk levels again for the next financial year. Many of them are also required to report under the Modern Slavery Act (or international equivalents) so we have been able to assess their compliance via their own public statements.
We continue to partner with third party logistics providers in Europe and the USA - 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 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.
Since our last statement, we have seen the outbreak of war in Ukraine - where many of our employees live and work. As a result, we have made the difficult decision to remove Russia from our supply chain - both upstream and down - in part to wholeheartedly support our Ukrainian colleagues and also to avoid any risk arising from economic sanctions. We have made significant efforts to help our colleagues relocate to areas of safety, to ensure they can continue to work for us and provide for their families and to adopt policies designed to assist flexible and remote working. We have raised funds from investors, employees and customers to help those who have needed to relocate. We will continue to support our colleagues and remain committed to our Ukrainian hub.
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 stock suppliers (excluding those with whom we did very little business in either value or frequency), following up on the similar process we ran last year.
- 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 which may be required on a case by case basis.
- 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.
- Our ‘onboarding’ process for new suppliers includes robust conversations about human rights (including modern slavery), animal welfare, sustainability and other ethical, social and environmental issues. This is supplemented with regular ongoing conversations with suppliers and site visits where possible.
Our internal policies
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
Our Anti-Bribery and Corruption Policy deals with the specific risks faced in our business in the jurisdictions where our operations are based. We provide compulsory training for all staff 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.
Child Safeguarding and Protection Policy
This policy outlines and provides practical assistance on how we should provide children with appropriate safety and protection whilst we are working with them. It also provides guidance on indicators of child abuse and neglect and how any concerns can be disclosed confidentially.
Makers In Need Policy - Social and Domestic Violence
This policy sets out how we are committed to providing a safe working environment and supporting any members of our team who have experienced, may experience or be victims of domestic abuse or at high risk of harm. It also provides guidance on how any concerns can be disclosed confidentially.
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. This group has been responsible for supporting and/or pushing forward many initiatives that have directly impacted the day-to-day working environment at LoveCrafts. Examples include: a robust Diversity & Allyship Training E-learning course that is compulsory for all staff; adopting a bias decoder on job adverts to reveal and remove any gendered or biassed language to support fully inclusive global hiring; and all teams adopting specific company objectives dedicated to DE&I (diversity, equity and inclusion).
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.
Over the last 12 months, we have:
- Updated our Supplier Handbook which now contains a minimum set of clear requirements that all our suppliers must comply with, including that they do not utilise forced, prison, or endangered labour, or subject workers to any form of compulsion or coercion. We have also outlined ways in which we expect our suppliers to support us in ensuring our supply chain reflects our wider ethical values and respect for human and animal rights.
- Discussed modern slavery issues and other supply chain concerns with suppliers as needed.
- Implemented the Child Safeguarding and Protection Policy and the Makers In Need Policy - Social and Domestic Violence.
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:
- As the world emerges from COVID-19, we will resume visits to our private label suppliers and key third party suppliers to assess compliance in person.
- In our regular virtual and face-to-face 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.
- We continue to develop 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 assess and repeat our supply chain audit in June 2023 with a view to providing a further statement in relation to FY23.
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 2022.
Edward Griffith, CEO and Founder, on behalf of the Board of Directors