Modern Slavery Policy
Ruia Group is a family run UK business, which was established in the 1950’s. Ruia Group primarily procures textile products from the Far East, Indian Sub-Continent, Middle East and Europe and distributes and supplies to customers in the UK, Europe and further afield.
Ruia Group acknowledges that forced labour and modern slavery are major and current issues facing both the garment industry and civil society worldwide.
Ruia Group has fully adopted best practice principles to make forced labour and modern slavery awareness a significant part of our everyday business practice which includes supply chain mapping, risk assessment and potential remediation activities. The Group will continue to consider purchasing practices that in cooperation with suppliers will reduce the potential vulnerability of workers and the risk of modern slavery occurring in our supply chains because of our commercial activity.
Ruia Group modern Slavery Policy has been established to make the group position clear to customers, suppliers and their co-workers, as well as any other stakeholders. The requirements in this code of conduct are mandatory for all suppliers and their sub-contractors.
1. General Principle
The Group does not accept any form of slavery, indentured labour or forced labour.
The Group supports the United Nations (U.N.) Forced Labour Convention, 1930 (No. 29)
• This fundamental convention prohibits all forms of forced or compulsory labour, which is defined as "all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily."
The Group supports the United Nations (U.N.) Abolition of Forced Labour Convention, 1957 (No. 105)
• This fundamental convention prohibits forced or compulsory labour as a means of political coercion or education or as a punishment for holding or expressing political views or views ideologically opposed to the established political, social or economic system; as a method of mobilizing and using labour for purposes of economic development; as a means of labour discipline; as a punishment for having participated in strikes; and as a means of racial, social, national or religious discrimination.
The Group supports the ambitions of the United Nations (U.N.) Protocol of 2014 to the Forced Labour Convention, 1930 and Forced Labour (Supplementary Measures) Recommendation, 2014 (No. 203).
• The new Protocol establishes the obligations to prevent forced labour, protect victims and provide them with access to remedies.
2. Implementation
A continuous program to identify the potential risks of forced labour and slavery occurring in our supply chains has been operating since 2020 and has been fully implemented by all teams across the group regardless of geographical location or position within the company.
The Group requires that all suppliers shall recognise the U.N. Conventions listed in the general principle and that the suppliers comply with all relevant national and international laws, regulations, and provisions applicable in the country of production.
Where the national laws do not provide sufficient obligation, or the UN Conventions have yet to be ratified the supplier companies are still expected to comply. Suppliers that do not wish to comply or feel they are unable to comply are required to notify Ruia Group and alternative methods of recognition, protection for workers and monitoring can be discussed and adopted.
Suppliers are obliged to take the appropriate, demonstrable, and robust measures to ensure that no forced labour or slavery occurs at suppliers’ and their sub-contractor’s places of production.
If forced labour or slavery is found in any place of production, The Group will require the supplier to notify the relevant national authorities and report the criminal activity to the appropriate bodies. The supplier is required to place the welfare of the worker at the forefront of all activity keeping in mind that exposing criminal activity may endanger the worker. The supplier will be required to implement a remediation action plan and take specialist advice to ensure that the rights of the worker, the safety of the worker and appropriate remediation strategies are considered.
If appropriate notifications, due consideration of remediation activity and appropriate corrective actions are not fully implemented within the agreed timeframe, or if concerns persist, The Group will terminate all business with the supplier concerned. The corrective action plan shall take the workers best interests into consideration, recognising all vulnerabilities and the associated reasons that the worker found themselves in a position of forced labour or slavery. Care shall be taken not simply move the worker from one supplier’s workplace or from one vulnerable situation to another, but to enable a more viable and long-term solution as part of the documented and monitored remediation process.
The supplier shall effectively communicate to all its sub-contractors, as well as to its own co-workers, the content of The Group modern slavery policy, and ensure that all measures required are implemented accordingly.
3. Labour force register
The supplier shall maintain documentation for every worker verifying the worker’s date of birth. In countries where such official documents are not available, the supplier must use appropriate assessment methods as per local practice and law.
Where temporary labour agencies are in use either in the workplace production or in the provision of services such as maintenance and security those workers on site shall be under the protection of the supplier or factory and a register shall be kept of all workers regardless of the primary employer.
4. Monitoring
All suppliers are obliged to keep The Group informed at all times about all places of production (including their sub-contractors). Any undisclosed production centres found would constitute a violation of this code of conduct.
Through the General Purchasing Conditions for the supply of products to The Group, The Group has reserved the right to make unannounced visits at any time to all places of production (including their sub-contractors) for goods intended for supply to The Group. The Group furthermore reserves the right to assign, at its sole discretion, an independent third party to conduct inspections in order to ensure compliance with The Group modern slavery policy.
Ruia Group operate a system of supply chain mapping, risk assessment and monitoring of all products and services in its supply chain. New suppliers undergo an induction and risk assessment before being introduced as a mainstream supplier to the company.
The use of second and third-party audits support the monitoring of suppliers.
Suppliers are required to join the SEDEX platform, complete the Self-Assessment Questionnaire (SAQ) and update this on an annual basis. This forms an integral part of the risk assessment process.
5. Remediation
If there is a likelihood of modern slavery or identification of actual examples of modern slavery are found in the supply chains of The Group, it will seek to work in partnership with the supplier and appropriately qualified organisations to develop a responsible solution that is in the best long-term interests of the worker. The supplier and The Group will agree a corrective action plan that is approved by the national legal authorities, and which may comprise the following actions:
• Encouragement to establish grievance mechanisms and Whistle-blowing systems with the possibility of work incentives to encourage use and effective monitoring.
• identifying who to collaborate and engage with to ensure that risks are reduced in the future and that remediation activities are successfully embedded in the workplace.
• Assessing impact on remedial action for workers to ensure they are protected from further victimisation, punishment or retaliation.
• Compensation to workers for the harm caused by modern slavery which could include fees paid, loss of wages, recognition of potential pain and suffering.
• Identifying worker representatives – trade union or others to represent workers’ interests.
• Further and ongoing cooperation with local authorities or police to ensure that there is no possibility that actions could compromise their investigation and ability to prosecute.
• Identifying NGOs, other worker or migrant representative bodies able to provide support for victims, protection and services in the event of an actual situation being identified.
Such actions will be considered by Ruia Group as evidence that the supplier is committed to meaningful remediation, and in compliance with this Policy.
6. Modern Slavery Statement
Ruia Group is a family run UK business, which was established in the 1950’s.
Ruia Group primarily procures textile products from the Far East, Indian Sub-Continent, Middle East, and Europe and distributes and supplies to customers in the UK, Europe and further afield.
Since 2009, The Ruia Group has worked to develop better labour practices within the whole of its supply chains, and a suite of policies have been created and communicated to assist Ruia Group’s business practices. This Modern Slavery Policy focuses upon the 9 key principles of the ETI Base code which include, employment being freely chosen, child labour shall not be used, and no harsh or inhumane treatment being allowed.
Ruia Group teams have been trained to raise awareness of modern slavery including aggressive buying practices that can contribute to the potential of modern slavery occurring. This training has assisted the Group’s due diligence process in making careful decisions of regions, countries, and suppliers that may be operating in areas where the potential risks of modern slavery and forced labour occurring are highest.
Key suppliers are audited by a third party; audits are conducted on a regular basis. The reports are assessed, and non-compliances are worked upon to be closed off in partnership with suppliers. Audits are monitored using the SEDEX online platform.
There are many suppliers that have traded with Ruia Group for more than 20 years and these relationships are constantly nurtured through regular visits to factories, trade exhibitions and visits by the supplier to the UK offices to meet the buying teams. The Group’s ethos has always been to have strong long-term supplier relationships which have been a key factor in the Group’s success.
Regular training takes place to ensure that good practice has been assimilated by directors, buyers, and product developers alike. Since 2011, this process has been greatly enhanced through Ruia Group’s membership of Sedex (Supplier Ethical Data Exchange). Where the company believes there may be a need for a more diligent approach dedicated resources are made available. For example, a small office has been created in Shanghai that has assisted the Group to monitor and support its’ suppliers more diligently and effectively, by breaking down language barriers in a, sometimes, challenging environment.
At Board level, ethical issues are raised and discussed at the quarterly board meetings and decisions taken at the highest level. All directors and buyers are regularly updated with information through briefings, meetings and, in certain cases, bespoke training courses.
Ruia Group participates in conferences, and seminars to keep our knowledge of the risks of Modern slavery fully updated and aligned with best practice. The group remains vigilant to the changing geo-political pressures that drives aspects such as migration, poverty and social disruption acknowledging that Modern Slavery and Forced Labour thrives within this uncertain environment.