Introduction 

Our Modern Slavery statement is published by Thread 35 Limited t/a Sosandar (“Sosandar”) in accordance with the requirements set out in the Modern Slavery Act 2015 which covers the financial year ending 31 March 2023 where turnover reached £42.8m.  

We oppose slavery in all its forms, and we are pleased to outline the steps and activities Sosandar is currently taking to prevent modern slavery across our business and supply chain, along with our commitments for 2023 – 2024 which we have set out in further detail below.  

About Sosandar and our supply chain 

Sosandar was founded in 2016 by two multi award winning female entrepreneurs, Ali Hall and Julie Lavington, who between them have over 40 years’ experience in Fashion and Media. The Company is now the fastest growing fashion brand in the UK and operates within the retail sector. 

We understand that our business has an impact on the world around us and we are dedicated to ensuring that impact is positive. Throughout the design and manufacturing of all our merchandise, Sosandar has a deep commitment to responsible practice, and we are dedicated to working with suppliers who share our belief in operating responsibly and with integrity. 

Our journey to sourcing product more sustainably is always ongoing as we look to continuously enhance our practices. Our leather is sourced from LWG accredited tanneries, our denim is produced in a way that minimises water usage and we are introducing recycled and organic fibres to our range. We have launched new consumer packaging including ‘green PE’ polythene bags that are recyclable and carbon negative.  We recognise that there is still more to do and our commitment to reducing the impact we have on the environment is a key priority over the next year.   

Our sourcing strategy is focused on building key long-term partnerships around the globe with our products manufactured through 55 suppliers across 120 factories in 13 countries, including China, Turkey, India and the EU.  

To ensure our high standards are maintained, we regularly conduct comprehensive assessments of ethical practices throughout our supply chain at Board level. Our Sourcing and Compliance team oversea this process to guarantee the consistent upholding of our ‘Code of Conduct’ at every level of our operation, in collaboration with our partners and all individuals within our supply chain. 

Relevant Policies 

We have several policies which highlight our commitment to high ethical standards which include: 

Code of conduct: 

We use this code to outline the minimum requirements that all direct first-tier product suppliers must uphold in relation to their workers such as employment being freely chosen, no harsh or inhumane treatment of workers, and ensuring that child labour is not used. This code is aligned to the Ethical Trading Initiative (ETI) Base Code, which is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice. The code is contained in our supplier onboarding portfolio. 

We require all of our suppliers to sign a declaration confirming that each of their manufacturing facilities and/or third-party subcontractors producing goods does so in accordance with the ETI base code and local law, which must be returned to us before production commences. It is a term of our contract that suppliers must not use or permit the use of child labour or unethical manufacturing processes. 

Supplier terms and conditions: 

All suppliers are contractually bound by the terms and conditions set out in our onboarding process which includes key ethical policies. These cover areas such as anti-slavery, human trafficking, anti-bribery, and whistleblowing. 

Further fundamental policies relating to modern slavery are communicated to our suppliers and throughout our business covering the following; cotton fibre sourcing, environmental chemical policy, animal welfare standards, prohibited or restricted sources and sourcing in high risk areas. 

Risk assessment, prevention and mitigation 

Risk assessment is critical in our strategy of producing quality products with integrity. 

We reserve the right in our terms of business to audit/visit all factories either directly or through a nominated third party. Such audits include, but are not limited to, a review of universal rights in accordance with the UN Guiding Principles; responsible recruitment; entitlement to work, immigration; sub-contracting and homeworking. 

Our suppliers are only permitted to use production facilities and or third-party subcontractors that we have approved in advance. 

Our approach is to give clear guidance on expectations with our supply base promoting full transparency at both onboarding stage and through ongoing supplier communications. 

In order to increase our visibility and understand our supply chain better, we have fully mapped our Tier 1 production sites and champion in person factory visits by our Sourcing, Compliance and Product teams.  These regular visits to all main territories where our products are produced give us the opportunity to discuss sustainable and ethical working conditions as well as give visibility and knowledge of better practices.   

When and if problems are discovered, we work with suppliers to ensure the best outcome for all concerned.    

Third party audits 

We regularly audit our first-tier manufacturing sites within Sosandar’s supply chain to ensure our high standards are met. This includes:  

• A Full Audit report from independent and internationally recognised companies such as SMETA (Sedex Members Ethical Trade Audit) or BSCI (Business Social Compliance Initiative) ensuring our global supply chain complies with expected standards. 
• Completed and signed supplier forms including the Sosandar Terms of Business. 
• Completed factory set-up forms. 

The audits assess a variety of subjects such as: working conditions, hours worked and wages. The Sourcing and Compliance team at Sosandar review each and every audit thoroughly. If any non-compliance is highlighted, we work with suppliers to ensure they are resolved and closed off with the relevant audit body.  Whilst we recognise the benefits of this process, we are committed to work alongside our supply base rather than against them, to embed a system of continuous improvement that goes beyond audits.   

Sosandar employees & training  

Our employees have access to, and sign to comply with, a staff handbook which details various policies supporting our commitment to responsible business. It protects the rights of both our direct and indirect employees and promotes an ethical supply chain. These include but are not limited to our Code of Conduct, Grievance procedure, Whistleblowing policy and our Anti-Bribery policy.  

Our sourcing team, who directly engage with our supply chain are given specific and country relevant training on responsible and sustainable work practices, which includes the risks of modern slavery. We will extend this training to all teams across the business as we understand how modern slavery can affect the fashion supply chain in particular.  

We ensure that the required legal checks are completed for all employees who join Sosandar and we only work with recruitment agencies who mirror our commitment to onboarding people responsibly. 

Next Steps – 2023/24  

During financial year 2023/24, we plan to take the following key steps to further strengthen our approach to combatting the risk of modern slavery and trafficking in our supply chains: 

• Enhance our approach by adopting the Ethical Trading Initiatives (ETI) ‘ESG SMART Action Plan and due diligence frame works.’ This will allow us to focus and develop key priorities for the business. 
• Utilise the smart action plan to ready the business for future ETI membership. 
• Mitigate risk and enhance our audit verification, and supplier management process, by becoming SEDEX members. 
• Expand our visibility by further defining our supply chain tiers and establishing key traceability KPI’s that we can measure against. Ensure key personnel within the wider business have been trained on responsible and sustainable sourcing including the risk of modern slavery and country specific challenges. 
• Improve our external methods of communication with our supply base to ensure all parties are aligned with expectations and key business KPI’s. 

This statement is made regarding section 54(1) of the Modern Slavery Act 2015 and constitutes our ongoing commitment to ending slavery and human trafficking for good.  

Thread 35 Limited t/a Sosandar 

Date: 06/09/2023