The Modern Slavery Policy of The SMC Group underscores our unwavering commitment to identifying, preventing, and addressing any forms of modern slavery within our operations and supply chain. Rooted in our core values of participatory research, decolonisation, and intersectional feminism, this policy mandates rigorous due diligence processes, regular training for staff on recognising and preventing modern slavery, and a precise, confidential reporting mechanism for any concerns. Reflecting our dedication to transparency and ethical practice, we actively ensure our partnerships and engagements are free from exploitation, supporting a fair, equitable, and just global community.

I am committed to the highest standards of ethical behaviour, particularly given that I ran an ethical fashion business for many years. As an Indian woman, the numerous injustices within modern slavery are very personal, and this policy should be seen as an overview of my approach, the measures taken and planned to ensure that modern slavery and human trafficking, and all forms of human suffering, are absent across our operations and supply chain. For further details, please get in touch with me.

All forms of modern slavery, including human trafficking, forced and child labour, and women’s indentured servitude, are utterly unacceptable. We adopt a zero-tolerance stance towards such practices, and in alignment with our support for whistleblowers, we actively encourage the exposure of all such practices.

Related Policies

1. Each project has its own Safeguarding Policy, which includes duty of care.
2. Each client is also given a separate Code of Conduct, relevant ethical practices and policies, and data protection.
3. Each partner and subcontractor is also given their privacy policy and Code of Conduct.

This Modern Slavery Policy applies to The SMC Group as a whole, is purposely generic, and is supplemented by other policies specific to the work, context, client, partners, communities, and subcontractors.

Our Approach to Business

The SMC Group supports social impact work and organisations with workshops, courses, technical support, skill-building, and JEDI+ consultancies. Our approach to work and business is participatory, decolonised, intersectional, and inclusive. As such, it encourages the calling out of harmful practices and politics and is rooted in activism. I have operated and continue to work on every continent of our beautiful planet except Alaska.

Supply Chain

At The SMC Group, we prioritise supply chain transparency as a cornerstone of our ethical commitments. This involves openly sharing information about our sourcing practices and ensuring all stakeholders, from suppliers to consumers, understand our rigorous standards against modern slavery and unethical labour practices. By maintaining clear, accessible records of our supply chain operations, we foster trust and accountability and empower our partners and the public to hold us to our promise of upholding human rights and dignity across all our engagements. A record of all suppliers is available to anyone requesting it.

Slavery and Human Trafficking

I actively combat these injustices, aligning with the EU Directive 2011/36/EU, which emphasises the importance of protecting victims and preventing trafficking. My efforts are grounded in the belief that everyone deserves freedom and dignity.

I contribute personal funds and time to support Fashion Revolution’s campaigns and research, including their flagship annual reports.

The SMC Group also actively seeks out clients who engage in this space as clients or partners on the journey.

Due Diligence

I meticulously scrutinise our supply chains and partnerships, guided by the EU’s Corporate Social Responsibility framework. This ensures our practices comply with legal standards and uphold our ethical commitments.

I regularly conduct risk assessments, particularly of new vendors, to highlight potential areas of high risk within the supply chain. I also conduct mixed-method due diligence on each new supplier. The procurement process also undergoes training on modern slavery and human rights and is independently verified to mitigate against the bias of a self-employed person leading a business.

Mechanisms are established, monitored, and updated to ensure that employees, suppliers, partners, and the community also conduct their due diligence on our partnership.

Risk Assessment

Risk assessment involves a proactive approach, identifying potential vulnerabilities within our operations. I use Spain’s national strategies as a blueprint to mitigate risks and ensure a safe and ethical working environment.

Training and Awareness

Training and awareness programs are crucial to fostering an informed workforce. By aligning with EU awareness-raising initiatives, I ensure our team is equipped to recognise and act against slavery and human trafficking.

Professional development funds are available to support ongoing training and skill-building around modern slavery and human rights, particularly as they relate to business practices.

Reporting, Monitoring, and Implementation

Our reporting mechanisms are designed for safety and confidentiality. They encourage stakeholders to voice concerns in accordance with EU whistleblower protections, fostering a culture of transparency and accountability.

Monitoring and review processes are rigorous, reflecting our dedication to continuous improvement. This aligns with EU guidelines, which advocate for regular evaluations to enhance policy effectiveness.

Finally, in implementation, I commit to engaging deeply with our policies and ensuring they are lived out in our daily operations, reflecting the best practices outlined in the EU and Spanish frameworks.

Approvals and Reviews

This policy was formally approved by management at The SMC Group in March 2024. I will notify you of any changes by posting the new Anti-Corruption Policy on our website. It was independently reviewed by one expert in modern slavery and human trafficking. Though their identity is anonymised for the website, it is available to those who would like further information. Please get in touch with me for more.

[This policy was last updated in March 2024. It is reviewed semi-annually and fo