Our Modern Slavery And Human Trafficking Statement

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. 

Baker Brothers has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. 

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. 

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes and we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. 

Our Business and Supply Chains

Baker Brothers sell jewellery and watches of exceptional quality, along with many sought-after brands. Impeccable quality and unparalleled service are at the heart of everything we do, and our business and culture are built around corporate philanthropy. Our purpose is to provide an enriched and memorable experience, which means making a positive difference to the world we live in, our customers, our team, our suppliers and our wider communities.

We purchase jewellery and services directly from suppliers, 95% of which are based in the UK. Baker Brothers is a highly trusted jewellery and diamond specialist and have been since 1839. As a family-owned business, we benefit from long-standing relationships with many of our suppliers. Procurement of gemstones, precious metals, jewellery, watches, services and non-stick supplies is managed by our senior specialist buyers. 

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and onboarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.

We have not been made aware of any allegations of human trafficking or slavery activities against any of our suppliers, but if we were, then we would immediately cease trading with the supplier and report it to the authorities.

There have not been any major changes in our business structure since the last statement was made.

Policies

Baker Brothers operates the following policies for identifying and preventing slavery and human trafficking in our operations:

• Recruitment Policy – we operate a robust recruitment policy, including conducting eligibility to work in the UK and reference checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

• Whistleblowing Policy - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. All concerns can be reported via iamconcerned@bakerbrothersdiamonds.com. We also provide independent support to all employees through access to the Retail Trust on 0808 801 0808 or [email protected].

• Code of Conduct - our code ‘Baker Brothers Core Values’ encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain.

• Purchasing Code - we have updated our Supplier Agreement to make explicit reference to slavery and human trafficking. Every supplier of diamonds or diamond jewellery to Baker Brothers has given a written assurance that all diamonds purchased by us are conflict-free and conform to the ideals of the “Kimberley Process Certification Scheme” which came into effect in January 2003.

• We welcome feedback from any of our customers about concerns they may have around our supply chain, colleague recruitment or observations they may like to raise and have us consider under our Modern Slavery Act policy. They may do this by contacting our customer services team at [email protected], calling on 01234 352343 Monday to Saturday 9:15am to 5pm or going online and using our live chat. 
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Alternatively, we can be contacted by writing to us at Baker Brothers Customer Services, Diamond House 11-13 St Peter’s Street Bedford MK40 2PN. If the customer provides us with their name and contact details, we are committed to responding to their enquiry within 3 working days and where they have concerns that they wish us to consider, working with them to discuss reaching a full resolution within 7 working days.

Supplier due diligence

Baker Brothers conduct due diligence on all new suppliers during onboarding and on existing suppliers at regular intervals. 

This includes:

• Supplier Agreement issued every 18 months setting out our expectations of our suppliers with regard to:
  • Kimberley process and gemstone confirmation
  • Dirty Gold and Conflict Minerals
  • Responsible Jewellery Council code of ethics
  • Modern Slavery Act status
• We require all new suppliers to attest that:
• They are fully compliant with the Modern Slavery Act 2015
• They are fully transparent, accountable and auditable and free from ethical ambiguities
• They don't use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
• They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons
• They don't require employees to surrender their passports or work permits as a condition of employment
• Sanctioning suppliers that fail to perform in line with our requirements

Risk of slavery and human trafficking in our business

During the year we have revisited our risk assessment of our supply chain by taking into account:

• The risk profile of individual countries based on the Global Slavery Index – all of our direct suppliers are within the Global Slavery Index ’low prevalence of modern slavery’ category.

• The business services rendered by the suppliers – we have assessed the level of risk with our product suppliers to be low. This assessment is supported by the requirements of our Supplier Agreement pack and our involvement with the Kimberley process. Our risk assessment of existing non-product suppliers indicated low risk. Every supplier must now provide confirmation and evidence of awareness and compliance with the Modern Slavery Act before we commence trading with them.

• Length of the business relationship and knowledge of supplier operations, ethics and policies – we place great emphasis on building and maintaining strong, respectful relationships with our suppliers. Many of these relationships have been in place for several generations of our family business. Regular communication with senior management and opportunities to visit operational sites gives us confidence in the alignment of ethical beliefs including those underpinning the Transparency in Supply Chains provision.

• Response to Supplier Agreement request for information/policy agreement - Within our product supply chain we have a 100% return rate for our ‘Baker Brothers brand’ suppliers. For suppliers of watch and fashion products, 90% either signed our agreement or provided their own Modern Slavery Act statement. 

A high proportion of our supply chain is based in the UK. Due to the nature of our business, the original source of many of our core product components originates from a worldwide supplier base. We continue to work with our suppliers to ensure that to the best of our and their knowledge, our supply chain is free from abuse by slavery and human trafficking.

Awareness and Training

All members of the Senior Manager teams have been made aware of the Modern Slavery Act and Transparency in Supply Chains requirements. Key members of the Buying department have also received training in order to ensure compliance with the Act.

In addition to the general awareness programme, Baker Brothers developed colleague e- training which is refreshed and completed every 12 months:

• Various forms of modern slavery in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
• How employees should respond if they suspect slavery or human trafficking
• How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
• An attestation from employees that they will abide by Baker Brothers anti-slavery policy

89% of Baker Brothers colleagues have completed this training to date, our objective is 100% completion by the end of our next financial year.

Measuring how we're performing

These performance indicators will assist us in assessing the effectiveness of the steps taken to ensure our supply chains are slavery-free:

• Number of colleagues completing training on modern slavery - XX% to date
• Number of suppliers completing the MSA section of our Supplier Agreement
• Actions taken to strengthen and communicate our policies – Company-wide distribution of information, colleague training
• Number of modern slavery cases reported and actions taken - zero
• Steps taken to initiate and strengthen supply chain management

This statement covers the 52-week period from 09 January 2023 to 08 January 2024 and has been approved by the Directors of Baker Brothers (Jewellers) Ltd.

- Updated 30/1/23