Modern Slavery Statement

At TOAST, we have a responsibility to prevent slavery and human trafficking occurring, regardless of market or region. We do not tolerate any form of modern slavery in our operations and supply chains.

This statement sets out the actions we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent forced labour and human trafficking within our business operations. It is published in accordance with the UK Modern Slavery Act 2015.

Modern Slavery Statement 2023

This statement constitutes the “TOAST Modern Slavery Statement” for the year ended on 31 July 2023 and has been approved by the board of directors.

Our Organisational Structure and Supply Chain

TOAST is a global lifestyle brand providing women’s and men’s clothing, accessories and home wares online and through 20 own branded stores, and in approximately 39 multi branded department and independent stores across the UK, Europe and the USA.

TOAST has no ownership interests in the production chain but cooperates with approximately 80 suppliers who develop our designs across the UK, Asia, Europe, Africa and South America. We also buy directly from 130 brands and small businesses and support individual makers through our New Makers programme. Our Code of Conduct sets out our requirements to our suppliers, and our audit programme is the core mechanism for ensuring that our suppliers comply with our requirements.

TOAST recognises that a collaborative approach is needed, we work closely with our regional sourcing offices, and directly with our suppliers to assist our producers in building capacity to make long term improvements at their factories and organisations.

Risk Assessment

In the past year, we conducted a risk assessment of our business by considering:

The risk profile of individual countries based on the Global Slavery Index
The business services rendered by our suppliers
The presence of short-term migrant workers within our value chain

Based on the above we have identified that the highest risk of violating human rights is in our global supply chain, with Türkiye as the biggest risk; and the temporary staff employed at our warehouse during peak times throughout the year. We have identified forced labour, discrimination and child labour to be the most likely forms of slavery and human trafficking across these areas.

Policies and Due Diligence Processes

We apply a zero-tolerance policy on slavery, human trafficking and any form of forced labour in our supply chain.

We require all suppliers and sub-contractors to sign our updated Code of Conduct attesting that:

They do not 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 do not require employees to post a deposit/bond and do not withhold their salaries for any reasons
They do not require employees to surrender their passports or work permits as a condition of employment

We aim to roll out and expand, within our supply chain, due diligence on all new suppliers during on boarding and existing suppliers at regular intervals. This includes:

Identify, prevent and mitigate any risk of adverse impact on human rights in all our operations and business relationships
Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
Requiring improvements to substandard employment practices, working environments or health and safety standards
Off board suppliers that fail to improve their performance in line with our requirements

Alongside this we will conduct the same due diligence within our bought in Brands to ascertain that they too are taking the necessary steps to ensure that the supply chains they control are adhering to the same standards; and due diligence to ensure that all their suppliers are monitored to the same extent that suppliers we work directly with are.

TOAST has raised awareness of modern slavery issues committing to the training of all Key employees at our locations and facilities, who interact with our supply chain and temporary workers, within that is focused specifically on modern slavery which explains:

Our commitment in the fight against modern slavery
Red flags for potential cases of slavery or human trafficking
How employees should report suspicions of modern slavery

Training

Key members of product teams, as the employees most engaged with our global supply chain, completed Modern Slavery Awareness training with our social auditing partner Verisio. The training covered:

Understanding current UK legislation i.e. Modern Slavery Act 2015
Learning the 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
How employees should respond if they suspect slavery or human trafficking
What external help is available in the UK for the victims of slavery

Measuring how we’re performing

TOAST has defined controls to combat modern slavery and human trafficking in our organisation and supply chain. Within these we have set key performance indicators which we will report and expand on annually. These include:

Mandatory awareness training at TOAST

By the end of the current financial year, all key employees across our two offices, and warehouse will receive a condensed version of the above training
This training will then be rolled out on a periodic basis, ensuring continued awareness of our commitment to the prevention of Modern Slavery in our organisation and supply chain

Supply chain awareness

We will complete a review of how many suppliers have anti-slavery policies and training programmes for employees
We will ensure the above is true of our top manufacturers by spend (producing 80% of our product spend)

Supplier endorsement of our updated Code of Conduct with our Anti-Slavery policy

From 1st August 2024 we will ensure all tier 1 manufacturers sign our updated Code of Conduct policy

Enhanced social auditing programme

Previously we requested a third-party social audit at onboarding stage for large commercial factory units only
Our focus will now expand to all tier 1 manufacturers, with annual reviews of social audits to ensure compliance
We will create compliance policies and Self-Assessment Questionnaire’s for Homeworker suppliers, and bought in Brand suppliers to sign, as full social audits are not workable for these suppliers

Supplier due-diligence visits

We will visit all our top manufacturers by spend in the new financial year (producing 80% of our product spend); either by TOAST staff or staff from our local regional sourcing offices