Ethical  

Cohen and Wilks International (Holdings) Limited
Modern Slavery StatemenT

Introduction
This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes Cohen and Wilks International (Holdings) Limited (CWI Holdings Ltd) slavery and human trafficking statement for the financial year ended 31 March 2019. Of CWI Holdings Ltd’s wholly owned subsidiaries, this statement covers the activities of Cohen and Wilks International Limited, Paul Dennicci Limited, Brecrest Fashion Limited, Blues Clothing Limited and Smithy Green Apparel Limited.

Our organisation
CWI Holdings Ltd designs and manufacturers apparel and accessories for sale to UK retailers for the UK market.
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We have approximately 80 staff, most of whom are based in the United Kingdom. Our goods our manufactured worldwide including China, Myanmar and India. Our staff are largely directly employed and are not in any category which is generally seen to be vulnerable to modern slavery in this country, so our focus is to ensure there are policies and procedures in place for our contractors and suppliers.

Our supply chain
CWI Holdings Ltd is committed to continuously improving its practices to identify and eliminate any slavery and human trafficking in its business and supply chains, and to acting ethically and with integrity in all its business relationships.
CWI Holdings Ltd uses a wide range of suppliers who manufacturer goods for sale and support our day to day operations.

Policies
CWI Holdings Ltd has policies in place and adheres to international codes which aim to minimise the risk of modern slavery in our supply chain. These include:

Terms of Purchase - our own document covering issues of human rights, child and forced labour and modern slavery, and general code of conduct which CWI Holdings Ltd suppliers are required to comply with and;

​ETI Code of Conduct - who define best practices in ethical trade based on the standards of the International Labour Organisation (ILO)

Due diligence
We continue to monitor suppliers we believe present high modern slavery risks in our supply chain. This includes those who support the procurement of goods and materials for resale particularly where those goods and materials are acquired from suppliers in high risk countries.

CWI Holdings Ltd and all their subsidiaries are members of Supplier Ethical Data Exchange (SEDEX) and Business Social Compliance Initiative (BSCI). These are membership schemes which assist companies to assess and map risks in their supply chains. The SEDEX and BSCI platforms allow CWI Holdings Ltd to access and monitor audited information uploaded by suppliers, giving us a better insight into their supply chains.

For manufacturing facilities in our supply chain and the supply chains of our suppliers we require that the operators of those facilities to:
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​conduct or provide, at minimum, semi-announced independent ethical audits through either SEDEX or BSCI

The compliance team at CWI Holdings Ltd is responsible for assessing the information submitted by suppliers. Should a supplier fail to provide the information requested or to meet CWI Holdings Ltd expectations, CWI Holdings Ltd will take appropriate action, which may include not entering into a relationship or terminating the relationship with the supplier concerned.

Training
During the year, we have continued to provide advice and guidance to those teams who have direct responsibility for relevant supply chains and our staff have participated in modern slavery training. We also disseminate information guides throughout our organisations. We will conduct further third-party training where required.  

Future Aims
Over the course of the next financial year we will continue to enhance our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers. 

Zhen Sun
Chief Executive Officer and Owner
Cohen and Wilks International (Holdings) Limited