Modern Slavery Act Statement

Introduction

Club L London is committed to ensuring that it trades ethically, sources responsibly and works to prevent modern slavery and human trafficking throughout its organisation and in its supply chain.

This statement highlights the key activities we have undertaken to combat modern slavery in our organisation and supply chain. It covers the financial year 2024/25 in accordance with section 54 of the UK Modern Slavery Act 2015.

 

 

What is Modern Slavery?

Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking. Modern slavery exists in both developing and developed countries, including the UK, and can involve UK citizens as well as foreign nationals.

This statement outlines our actions in identifying risks and taking necessary steps to prevent modern slavery within our business. We will cover the areas of:

· Organisation structure

· Our supply chain - Our policies

· Due diligence and risk assessment

· Effectiveness measurements and performance indicators

· Remediation

 

 

Organisational Structure

Club L London is a fashion brand operated by Club L (Retail) Limited, a company registered in England and Wales, United Kingdom with company no. 06109979.

The brand operates globally, selling apparel directly to consumers on its website. Its headquarters are based in England, United Kingdom. It has 127 employees worldwide on the date of this policy.

The Club L London Ethical and People teams are responsible for the day‑to‑day management of modern slavery risks, with oversight and direction from the Board.

 

 

Our Supply Chains

As a first step of our commitment, we’ve mapped our Tier 1 suppliers, and work is ongoing to map our Tier 2–3 suppliers for better visibility. We recognise that deeper supply‑chain visibility is essential, and we have begun a multi‑year process to trace raw materials and lower‑tier subcontracting.

Between February 2023 – March 2025, we sourced stock from the UK, China, India, UAE, Morocco, Australia and countries within Europe, working with 20 MTO (Made to Order) suppliers and over 10 MTS (Make to Stock) suppliers.

We aim to operate a business that is a fair and positive experience for all. We work collaboratively with our partners to foresee upcoming risks and to mitigate modern‑slavery concerns within our business.

 

 

Our Policies on Slavery and Human Trafficking

Our modern‑slavery program is overseen by our CEO to uphold our social‑responsibility and human‑rights standards, with overall management sitting with our CEO and Ethical Team.

We maintain several internal and supply‑chain policies including:

· Anti‑Slavery and Human Trafficking Policy

· Anti‑Bribery Policy - Disciplinary Policy

· Grievance Procedure

· Health & Safety

· Diversity & Inclusion (Equal Opportunities)

· Bullying & Harassment

· Whistleblowing Policy

 

Supply Chain Policies

· Code of Conduct derived from ILO conventions and the ETI Base Code

· Supply Chain Whistleblowing Policy

· Supplier Manual including key ethical requirements

· Anti‑Slavery and Human Trafficking Policy

· Anti‑Bribery Policy

All suppliers are contractually required to comply and are subject to termination if breaches occur.

 

 

Due Diligence and Risk Assessment

Supplier Onboarding

Club L London conducts due diligence before onboarding new suppliers, including:

· Reviewing country‑specific risks via the Global Slavery Index

· Identifying vulnerable areas of the business

· Reviewing any third‑party audits (e.g., SMETA, BSCI)

· Approved suppliers must sign our Code of Conduct and Supplier Contract.

 

Ongoing Monitoring

· We conduct regular unannounced site visits.

· Suppliers in high‑risk countries must undergo annual third‑party ethical audits.

· We reserve the right to audit all suppliers and subcontractors with or without notice.

 

Risk Assessment Approach

We apply a risk‑based model that considers:

· Country‑level risk

· Sector‑specific vulnerabilities (e.g., garment manufacturing)

· Use of temporary, migrant or subcontracted labour

· Depth of supply chain and traceability limitations

· High‑risk suppliers receive enhanced monitoring and corrective‑action requirements.

 

Effectiveness & KPIs

To measure the effectiveness of our programme, we track:

· Percentage of suppliers audited in the financial year

· Number of corrective action plans issued and closed

· Audit non‑compliance trends by geography

· Modern‑slavery training completion rates for staff

· Number and nature of whistleblowing reports (anonymised)

· We will publish these KPIs annually to demonstrate continuous improvement.

 

Remediation

If modern‑slavery indicators are identified:

· We investigate immediately through our Ethical Team

· We work with the supplier on a corrective‑action plan unless severe exploitation requires immediate termination

· We require suppliers to demonstrate remediation for affected workers (e.g., repayment of recruitment fees, contract correction, welfare support)

· Where appropriate, we collaborate with external organisations to support victims

 

Commitment

We’re committed to ensuring there are no forms of modern slavery in our supply chain or business operations.

· Our commitments include:

· Annual third‑party ethical audits for suppliers in high‑risk regions

· Modern‑slavery training for all staff

· A robust whistleblowing system open to all workers, including suppliers

· Continued development of our Ethical and Compliance team

· Year‑on‑year improvement of supply‑chain traceability, including Tier 2 and Tier 3

 mapping

 

 

Approval and Signature

This statement has been approved by the Board of Directors of Club L (Retail) Ltd.

Name: Mr. Richard Wing
Title: Chief Financial Officer, Club L (Retail) Ltd
Date: 04/12/2025