Transparency Statement - At Chilly’s, we respect human rights and do not tolerate any form of modern slavery.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Chilly’s Bottles Limited’s (Chilly’s) second slavery and human trafficking statement for the financial year commencing 1 August 2020 and ending 31 July 2021.
We recognise that no supply chain is without risk of modern slavery, and it is our responsibility to ensure we understand these risks and work in partnership with our suppliers and other stakeholders to identify and mitigate them.
This statement has been published in accordance with the UK Modern Slavery Act 2015 which requires businesses to disclose the steps they are taking to tackle slavery, servitude, forced or compulsory labour and human trafficking (known as modern slavery).
Chilly’s is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers. Our statement includes six areas outlined by the legislation and takes into account guidance issued by the Home Office.
Company Overview
Chilly’s is an online e-Commerce company incorporated in England and Wales with the Head Office registered in London.
Chilly’s mission is to accelerate the adoption and everyday use of reusable products. We aim to do this by creating products for an urban lifestyle, with the perfect balance of distinctive design and unrivalled performance. Chilly’s is a leader in reusable water bottles, coffee cups, food pots and reusable products.
We employ 40+ people in the UK. We have millions of customers around the world who shop directly with us or through other distribution channels.
Responding to COVID-19
As stated in our first Modern Slavery Act statement, the Coronavirus pandemic continues to present a huge challenge to society, to business and to all our colleagues, customers, and suppliers. Before the pandemic hit, the founders of Chilly’s and the Supply Chain Manager visited all the sites used for the manufacture of Chilly’s products in China. As a result of Covid-19, we have been unable to carry out any further in person visits. We have up to date factory audits from our two main factories.
The Business Structure & Supply Chain
Chilly’s primarily operates as an online business worldwide.
To produce our reusable water bottles, cups, food pots and related products, we work with a range of suppliers. The products we sell are sourced globally from the UK, Europe and China. The map shows location of production sites by continent based on data disclosed to us by suppliers.
There are more indirect suppliers in our extended supply chain, including suppliers of raw materials and components used in the products we sell and buy. We also source goods and services not for resale (GNFR) in the UK and Europe.
Our Policies in relation to Modern Slavery and Human Trafficking
Chilly’s had one Sustainability Policy; over the past year we created two separate policies; one focusing on Ethical/Social sustainability and another on Environmental sustainability in order to give each area additional focus throughout our supply chain.
We also produced a Code of Conduct for our suppliers that includes a section on Modern Slavery.
We make sure our suppliers are aware of our policies and adhere to the same high standards and services not for resale (GNFR) in the UK and Europe.
Embedding our policies into procurement
We have begun work to embed the requirements of our Code of Conduct, policies, and supply chain standards into our procurement processes in a number of ways. This includes:
• New suppliers completing a New Supplier Assessment Questionnaire
• Potential new suppliers are informed our requirements on compliance during supplier qualification validation stage.
• Our supply contract includes clauses on compliance to our ethical audit requirements.
• Our supply chain team review compliance reports before working with a new vendor
• Suppliers have a valid third-party social audit.
Whistleblowing
Our whistleblowing policy and procedures enable staff to report any concerns, including concerns over modern slavery and human rights violations.
Our Due Diligence in relation to Modern Slavery and Human Trafficking in our supply chains
Being an online ecommerce operating company, Chilly’s outsource a number of functions for both goods and services. We recognise that our most significant human rights and modern slavery risks are in our supply chain. We continue to roll out programmes of ethical audits for high-risk production site both home and abroad. Each production site is required to have a valid audit.
Our due diligence processes
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we operate a due diligence process in relation to the Modern Slavery Act whereby we undertake steps including overseas site inspection and third-party audits of the factories, warehouses and tied accommodation operated by our suppliers.
Our procedures are designed to:
• Establish and assess areas of potential risk in our business and supply chains
• Monitor potential risk areas in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains
Our effectiveness, measures and performance indicators
Chilly’s is committed to measuring how successful we are being in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains and will report on this is future years.
Risk and Compliance
Chilly’s regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by carrying out a Human Rights review of the supply chain every two years.
Given that our products are largely produced in China, we accept that we operate in a high-risk location. To combat this potential risk, we have relied on third party audits of suppliers to ensure that suppliers engaged by us are aware of and do not engage in modern slavery and, when possible, factory visits.
We ensure all our suppliers are aligned with our policies in relation to modern slavery. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, we have refused to contract with companies that cannot demonstrate compliance by producing independent third-party audits. If we find evidence of a failure to comply with our policy, we would engage with the supplier and discuss remediation plans. If there are continued non-compliances, we reserve the right to terminate our relationship with the supplier concerned.
Training
In 2022 we will be investing in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programme, employees will be encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy.
The programme will emphasise the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.
This statement was approved by the Board on 01.02.2022
