Human Rights Statement
As a business operating across global supply chains, Mi Hub Ltd are committed to ensuring that the rights of workers are consistently respected. We understand that we have a responsibility to protect human rights and advocate for better working practices in our own operations and through our supply chains, respecting our colleagues, suppliers and the communities we operate in. We further recognise that transparency plays a key role in this responsibility, and as such our 2023 Human Rights Policy Statement seeks to support our commitment to human rights due diligence (HRDD) through outlining the steps we are taking as a business to address and mitigate our potential human rights impacts.
Our approach to human rights due diligence is aligned with the UN Guiding Principles on Business and Human Rights and reflects the human rights as defined in the International Bill of Human Rights. We are further aligned to the International Labour Organisation’s Core Conventions and International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work and are guided by the OECD Guidelines for Multinational Enterprises.
As members of the Ethical Trading Initiative (ETI), we also follow the ETI Base Code and require our suppliers to do the same. We follow and adhere to all local laws and regulations, and where these laws and human rights standards may differ, the higher standard is followed.
Mi Hub Ltd is committed to operating a robust HRDD process to avoid potential human rights impacts which are either caused by, contributed to, or linked to our activities. In the case of any impacts which do occur, we are committed to addressing and remediating these. We also recognise that our approach will need to remain adaptable, and as such will be reviewed at least annually.
Our HRDD strategy is fully endorsed by our Chief Executive Officer who receives monthly updates via our ESG team.
Mi Hub Ltd maintains several internal policies and procedures which support our commitment to human rights within our own operations. These include our Anti-Corruption Policy, Bullying and Harassment Policy, Child Labour Policy, Equal Opportunity and Diversity Policy, Grievance Policy, Whistleblowing Policy and Modern Slavery Policy.
All Right to Work checks are conducted in accordance with the Immigration, Asylum and Nationality Act 2006 and the Immigration Act 1971 to ensure that all employees have the right to work in the UK for the duration of their employment. We also check that our employees are the correct legal minimum age to work in the UK.
We adhere to all minimum wage legislation globally, and within the UK all employees and consultants are paid in accordance with the National Living Wage requirements. We also have a Remuneration Committee that is chaired by our non-executive director.
Our business adopts an Equal Opportunity and Diversity Policy which ensures that we comply with all obligations. All decisions about recruitment and selection, promotion or training are made objectively and without discrimination. All complaints of discrimination are dealt with through our Grievance Procedure.
Worker committees are active within all parts of the business. Membership comprises employee representatives who have been elected by their colleagues. The forums are designed to allow for an employee voice within the organisation to address a variety of issues including working environment, working practice improvements and day-to-day health and safety matters.
Identification and Prioritisation
Our HRDD approach follows the UN Guiding Principles on Business and Human Rights, and as such has been progressively developed from an initial identification of human rights risks within our own operations and supply chains.
As we source from 18 countries within the global textile industry, which is widely known to have a lack of transparency. It is key to our approach to take time to understand the specific risks to our business and supply chain. In 2023, we have preliminarily identified our salient issues, and will focus next on further understanding the specificity of these issues relevant to our business.
At the beginning of 2023, we began our saliency assessment with an analysis of industry guidance combined with a detailed collection of historic data collated from sources such as questionnaires, third-party audits and targeted projects. To gain an understanding of the current trends within our industry, a customer and industry analysis was conducted using sources such as the Sedex Radar Tool, the Global Slavery Index, ETI reports and the Business & Human Rights Resource Centre. This highlighted where the human rights focus areas were across the textile industry, and where we may need to prioritise our own research and analysis.
After gaining an understanding of the industry and origin specific risks to human rights, a full supply chain analysis was conducted across all origins of Tier 1 Goods-for-Resale (GFR). Beginning with the data available to us through Sedex SAQs, SMETA audits and worker voice programmes, risks were assessed and analysed based on stakeholder mapping, and an assessment of whether we have the potential to cause, contribute to, or be linked to specific human rights impacts. Together, these two tasks highlighted who (based on worker type and country of origin) has the highest potential to be impacted by human rights violations both internally and externally, based upon the data and resources available to us at the time.
Following this, the risks were categorised into a matrix for likelihood and severity at a more granular level to allow for prioritisation. This allowed for a more visual overview of our greatest risks to human rights, assisting when sharing with the wider business. Upon review of the matrix and following stakeholder feedback, three salient issues were selected based on both risk and prevalence. Also selected were two unintended consequences which run as concurrent themes with the ability to impact upon the salient issues.
Health and Safety
All the salient issues and unintended consequences were prioritised as a result of risk and prevalence, but also due to both our potential leverage and our ability to delve deeper into the issues to understand greater specifics over the next three years.
One of our key initial priorities for 2023 which aligns with our reporting goals and KPIs is to further understand this specificity of our salient issues, with the wider goal of setting more specific measures in 2024 and beyond. This decision arose from external stakeholder feedback during our HRDD work in 2023 in defining our salient issues and is one which we believe will serve to strengthen our overall HRDD approach in subsequent years.
Prevention and Mitigation
Mi Hub Ltd are committed to preventing and mitigating any human rights impacts which may be caused by our operations, or which we may contribute to or be linked to. Our prevention and mitigation strategies will undoubtedly vary dependent upon the situation, however our HRDD approach underpins this work.
As a grounding principle to this, we ensure that the ETI Base Code is followed by ourselves and our supply chain. Internally, posters are displayed highlighting this to colleagues, and at supplier level this is included within the Supplier Code of Conduct.
Our supplier monitoring programme consisting of annual SMETA audits for all Category 1 and 2 suppliers, regular communication and review of SAQ responses collectively provides a baseline against which we can measure and monitor progress.
In addition to this, our HRDD approach will utilise this data to regularly trend human rights impacts. Such data will be crucial through 2024 as we develop a more detailed view into the specificity of our salient issues as we make decisions around how best we can work with suppliers to mitigate impacts. This will allow us to plan targeted projects throughout 2024 and 2025.
Internally, our HR team ensures that the relevant policies and procedures remain up to date to protect our colleagues and provide them with a safe and respectful environment in which to work.
Our final focus area within the HRDD plans for this year relating to prevention and mitigation is centred around ensuring that this work is not completed in isolation. Our human rights work is intrinsically about our people, and therefore it is vital that our people are involved. Through embedding the strategy within that of the wider business ESG strategy, it will become a focus for everyone at Mi Hub and our value chain. We will be looking to our colleagues and supply chain for supporting in reaching our goals, as we appreciate that human rights issues can only be tackled in collaboration.
In line with our HRDD approach, Mi Hub Ltd are committed to ensuring that access to remedy is available for human rights impacts. As we advance through our HRDD plans, we will seek solutions to any impacts identified.
At present, we follow the ETI Base Code and commit to respect for freedom of association and collective bargaining. Our internal whistleblowing policy is available to all colleagues of Mi Hub Ltd and is communicated to them on the commencement of their employment. Any issues can be reported anonymously through a hotline administered by the independent organisation, The Network. This operates 24 hours a day, seven days a week.
Within our supply chain, our suppliers have access to an email address which is linked directly to the Mi Hub Ltd UK Ethical Compliance team. This is detailed on a poster which suppliers are provided with during onboarding.
As part of our plans for prevention and mitigation of our salient issue, discrimination, we are also aiming to further understand potential opportunities for improvements in access to remedy through our supply chain in terms of freedom of association and collective bargaining. We will be reviewing and assessing supplier policies and procedures on this topic, as well as increasing our dissemination of worker voice programmes.
Our Supply Chains
Our supply chain is of a global nature and currently incorporates 18 countries as per the table below. The main supply route for production is from Bangladesh. Due to the high-risk nature of this origin, we have an office based in Dhaka with 25 employees, including a compliance team, who have a constant presence in our supplier factories.
Table of number of suppliers per origin.
As the table above indicates, our most prevalent sourcing origins are Bangladesh and China, making up over half of our Tier 1 supplier sites. This prevalence brings with it an overall heightened risk in the number of workers impacted through these sites, however each of the two origins also bring their own specific risks to workers.
In Bangladesh, the Sedex Radar tool and various third-party reports indicated to us that gender discrimination is a prevailing issue. This is of particular relevance as 58% of all the women within our supply chains are located within Bangladesh. Further, the Global Slavery Index ranked Bangladesh with a prevalence of 7.1 for Modern Slavery, one of the highest risk scores within our sourcing countries. As a result of this, we are placing focus over the next year on digging deeper into the root causes of discrimination and Modern Slavery through analysis of management systems, and also assessing where we can best place additional worker voice programmes. The knowledge of the specific prevalence of gender discrimination, Modern Slavery and potentially impacted workers in Bangladesh will be key to this assessment.
In China, the prevalent risks detected from a combination of the Sedex Radar tool and worker information are Forced Labour and Freedom of Association. Again, the prevalence of this risk is high within our supply chains as it has the potential to impact over 6000 workers. With a similar approach to work on risk mitigation in Bangladesh, in the next year we will be placing focus on understanding the management systems in place. For China though, this will be centred around Freedom of Association. In terms of Forced Labour, we will be utilising the SFA Modern Slavery questionnaire project to understand more detail around the systems which our China-based sites have in place.
In building these foundations over the next year, the aim is that we can place more specific, focused mitigation projects and activities within our supplier sites once we have more knowledge on how and where impact can be best made.
In order to ensure that we remain on track with our HRDD approach, we have established specific KPIs in relation to this work aimed at providing mitigation. These will sit under the wider business ESG function and will assist in monitoring and guiding our plans.
RAF rating of SMETA audit
% of each colour rating
Health and safety NC
Health and safety NCs as a % of overall NCs
Supplier completion of the SFA SC3 SAQ
% of suppliers fully completed
Develop an internal training plan for Modern Slavery
% of colleagues who have completed training as required
Implementation of a worker voice programme
Number of supplier employees who partake in the programme
Assess the prevalence of worker committees in our suppliers
% of supplier sites who have an active worker committee and supporting evidence of its effectiveness
These initial KPIs align with our ongoing strategy development in taking time to further understand the areas which we need to specifically place our focus upon in relation to human rights. Our main aim for 2023 has been to concentrate on the development of an HRDD approach, identifying and prioritising our salient issues and embedding the foundations of HRDD within the business. The following two years will see our efforts shift to the prevention, mitigation and remediation of human rights impacts, and new KPIs will be set which reflect our more specific focus.
Our Future Plans
Transparency is key to our future plans in HRDD, and key to sharing our vision both up and down the supply chain. We recognise that collaboration is essential to our plans, and so hope that in annually reporting our progress in this area, we will continue to open up the conversation both internally and with suppliers to drive this work forwards and reach the people most at risk.