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THE MODERN SLAVERY ACT 2015

Even after most countries banned slavery over 150 years ago, and despite significant progress in protecting human rights in the laws and systems set up to provide greater scrutiny, the reality is that people from around the world remain vulnerable to modern slavery and human trafficking.

Commitment Statement

Whistles is committed to respecting, protecting and advocating for the human rights of all stakeholders who are involved in our own business operations and supply chains. As such, we accept that it is our responsibility to act with transparency and integrity, to be proactive in resolving problems and to collaborate with others to protect the human rights and labour standards of workers.

By putting human rights and labour standards at the centre of our sustainability strategy, we believe our efforts are reflected in our commitment to provide our employees and supply chain partners with dignified work. Whistles is proud to partner with organisations including Anti-Slavery International, the Ethical Trading Initiative and the International Transport Workers’ Federation in our efforts to combat modern slavery.

What is Modern Slavery?

Contemporary slavery, as defined in the 1956 UN supplementary convention, takes many forms, including debt bondage, servitude, child slavery, forced labour and human trafficking.

Anti-Slavery International defines modern slavery as “exploitative labour that places one person in the control of another”. Slavery thrives on every continent and in almost every country and is still prevalent in the fashion industry and other labour-intensive industries.

Modern slavery is a violation of human rights where victims are denied their basic rights to dignity, freedom and security. Victims are trapped in a situation where they are often powerless and vulnerable, and therefore unable to leave because they are subject to deception, mental and/or physical abuse, threats and punishment.

To help us better identify the different forms of modern slavery, we have established definitions in the four key areas.

Slavery is now less about people literally owning other people – although that still exists – but more about being exploited and completely controlled by someone else, without being able to leave.

The International Labour Organisation (ILO) estimates that around 49.6 million people are involved in forced labour worldwide.

Who does modern slavery affect?

Modern slavery can affect anyone, but most commonly affects people who are vulnerable and at risk of being taken advantage of, often as a result of poverty, discrimination and exclusion and because laws do not properly protect them.

People can be particularly vulnerable to modern slavery when external circumstances push them into taking risky decisions in search of opportunities to provide for their families, or when people find they are simply pushed into jobs in exploitative conditions. Anyone could be pressed into forced labour, but people in vulnerable situations – such as being in debt, or not having access to their passport – are most at risk.

A typical scenario features someone who is enticed to accept a job offer abroad that turns out to be very different to that what was promised and then remain bounded to the organisers of the scheme, often referred to as ‘gangmasters’.

Issues in global supply chains

The lack of transparency and traceability across global supply chains is a major challenge. This means that it is extremely difficult to know how many people are working directly or indirectly in global supply chains, and the conditions that they are working in.

Although the highest prevalence of forced labour is found in low-income countries, it is deeply connected to demand from higher income countries. The production and movement of goods between countries – from the sourcing of raw materials to manufacturing, packaging, and transportation – creates complex and opaque supply chains, many of them tainted with forced labour.

In 2021, G20 countries imported USD468 billion worth of goods at risk of modern slavery. The UK alone imported USD26.1 billion of goods at risk of modern slavery.

Modern slavery in a global context

International NGOs
Non-governmental organisations (NGOs) have a big impact on modern slavery legislation and awareness. They provide research and data about the current impacts of modern slavery, helping businesses and governments to take action and manage risk.

Our partner Anti-Slavery International is the world’s oldest anti-slavery charity, founded in 1839. They advise governments on legislation and were part of the development of some of the world’s major slavery laws. They work with us to help assess, identify and mitigate modern slavery risks in our business operations and supply chains.

Whistles also refers to the Global Slavery Index and its interactive data maps that list countries according to the number of people in modern slavery, and analyses government actions in response to this issue. It was created by the Walk Free Foundation, which has a mission to end slavery in all forms.

Global legislation
Legislation aimed at preventing modern slavery and enhancing human rights due diligence have been rapidly spreading right across the world. This is as demand grows for companies to publicly disclose their efforts to address slavery and human trafficking in their supply chains.

The UK Modern Slavery Act 2015
Introduced in 2015, the UK Modern Slavery Act 2015 (MSA) is designed to prevent modern forms of slavery and protect victims. As required by section 54 of the MSA, Whistles – under its parent company, TFG Brands – produces an annual transparency statement that provides detailed steps of the actions we have taken to assess and identify risks to mitigate modern slavery in our own business operations and supply chains.

Published in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) and covering the financial year ending 31st March 2023, you can find the TFG Brands transparency statement here

TFG Brands Positioning Statement on human rights violations and abuses in Xinjiang, December 2020.

As part of TFG Brands approach to responsible sourcing and ethical trade, we are committed to prevent the use of forced labour in our supply chain. TFG Brands takes seriously reports of human rights abuses being perpetrated against Uyghurs and other Tukic-and Muslim-majority people in Xinjiang Uyghur Autonomous Region and other parts of China, which has been highlighted by the Coalition to End Uyghur Forced Labour. TFG Brands has signed the Call to Action and is committed to taking all steps laid out within, in line with our responsibilities under the UN Guiding Principles on Business and Human Rights.