Introduction

At Dixons Travel we strive to provide fair and equal treatment to our suppliers, and are committed to acting ethically and with integrity at every stage of the process. We work closely with a number of organisations to ensure our operations and procedures meet the expected standards and continue to provide ways in which our customers can reduce their environmental impact.  

Supply Chain

We value rights and prosperity across our value chain. We treat our suppliers as partners. Our relationships with suppliers are becoming even more important; we want them to strengthen as we grow. And whether it’s a call centre in South Africa or a call centre in Europe, it’s important that working with us delivers a positive local economic impact. We expect all our suppliers to operate in a fair and honest way towards their employees and those with whom they do business.

Resources

Our business is dependent on a number of finite resources. We are increasingly aware of our impact on our people, the communities in which we operate, the environment and our supply chain. We work to improve the way we manage our business every day and to manage the resources available. The resources we focus on include: customers, people, suppliers, distribution, stores, intellectual property, energy, the environment and capital.

Ethical sourcing

We have an Ethical Sourcing Policy, reflecting our commitment to acting ethically and with integrity in all our business relationships. WE require our OEM suppliers to implement and enforce effective systems and controls to ensure slavery and human trafficking us not taking place and we will look to expand that to other areas of our supply chain in the coming year. Our Modern Slavery and Ethical Sourcing policies consider the Social Accountability 8000 standard, ETI Base Code, FTSE4Good criteria and the UN Guiding Principles, as well as guidance from various other subject matter experts.

We will continue to review our existing policies for recruitment, procurement, whistle-blowing, etc. and where necessary make changes or introduce explicit references to Modern Slavery. We will also look to introduce new policies as and when relevant, and as our understanding of the issues and the approaches we need to take improve.

Our social and ethical auditing team carries out comprehensive due diligence of suppliers of our OEM products prior to selection against strict trading terms and operating procedures. Approved suppliers are then subject to regular checks and audits. We will expand this procedure to relevant parts of our supply chain once we have analysedthe results of our workers’ rights questionnaire. Where necessary, we will introduce reporting to monitor and evaluate risk at any given time.

Once complete, the questionnaire will have been sent to approximately 13,00 suppliers globally; our first-tier suppliers in their entirety. The responses received will allow us to assess actual and potential human rights impacts and act upon the findings in an appropriate manner. The questionnaire asks questions in relation to the countries where our suppliers operate, the types of goods and/or services they provide (to us and to others), the types of workers they employ and the way they might treat them (wages, working hours, freedom of movement, the rights of young employees, ect.). We also ask if they must produce their own Modern Slavery statement (and if so, to provide us with a copy) and what policies and procedures they have in place to ensure their business and supply chains are free from Modern Slavery as well as the steps they take to protect workers’ rights in general.

We have in place a confidential (and anonymous, should the caller so choose) whistle-blowing helpline and this is referred to in our Modern Slavery policy. The helpline allows anyone within our supply chain to raised concerns without fear of being harassed or bullied, losing out on opportunities or training, or facing demotion or dismissal, as a consequence of raising their concerns.

Over the next 12 months we will work with the Slave Free Alliance to audit our processes and make appropriate improvements.

Now we have completed the mapping of our supply chain we will be able to overlay the results of our workers’ rights questionnaire. This will help us to identify higher risk areas to target process and resources effectively. As members of the Slave Free Alliance we will be able to utilise their experience to go beyond compliance and audits within our business and supply chain.

Aside from the risk assessment and questionnaire, we have played an active part in the Modern Slavery and Ethical Sourcing groups at the British Retail Consortium, are members of SEDEX and regularly attend events where there is an opportunity to discuss the risks of Modern Slavery with our peers, Non-Governmental Organisations (‘NGOs’) and other relevant stakeholders. This helps to expand our knowledge and highlight countries, product types or services that may be considered to have a higher risk of Modern Slavery. The knowledge and experience that we have obtained will help us identify the risks and issues, assess the level of importance and develop appropriate remedies. We will continue to collaborate and improve our understanding as time goes on.

Through this collaboration we have already identified one key area of risk here in the UK- distribution and worked to reduce that risk. We have engaged with our distribution and recruitment partners, working to understand how they are mitigating risk and the steps that are taking to ensure that workers’ rights are upheld. We will continue dialogue and offer ongoing support to suppliers.

We will also look to develop a written operating procedure to follow in the event of finding a victim of modern slavery. Victims safety is paramount and we shall support them appropriately.
The effectiveness of our work on Modern Slavery will continue to improve over time.

We currently have the following measures in place:

Addressing non-compliance in relation to our OEM supplier factory audits: Our audits include several topics including child / young labour, working hours, wages and deductions, overtime, working conditions and safety, freedom of movement and association, discrimination and disciplinary practices. Each factory is audited prior to selection. Once suppliers have been approved, they remain subject to regular checks and audits. These supplier audits are carried out with a view to assisting them in improving their working practices and we work with factories where failures have been identified. Wherever we can, we work with the supplier to make improvements; where this is not possible or no improvements are made, they will not be approved as a supplier, or will be delisted as appropriate;

The number of calls to our Whistle-blowing hotline that are related to ethical issues (including all forms of Modern Slavery); and

The responses (or lack thereof) received from the questionnaire sent to our suppliers.

Environmental Responsibility

We are fully committed to meeting our environmental responsibilities and limiting the impact of our operations in a way that is both practically and economically feasible. Our environmental policy, endorsed by the Board, covers material issues including energy consumption, carbon emissions, supply chain and operational waste. We conduct activities to address each of these areas and our progress this year is presented below.

We have established a formalised enterprise risk management process that operates at business unit and Group level and includes climate change as a risk category. At asset (store) level, climate change risks are identified as part of business contingency / continuity processes – with the identified risks mainly relating to extreme weather events.

Energy Management

We recognize that the operation of our retail stores is one of our major environmental impacts and have set ourselves an ambitious energy and CO2 reduction target to help mitigate this.

As part of our long-term review we are considering what our longer term targets will be and whether to adopt a science-based target. To ensure we meet our reduction target by 2020, Dixons Carphone has a structured energy management programme within the UK & Ireland that provides an overarching framework of activities and projects to manage and reduce our consumption while maximising our efficiency.

The energy consumption and corresponding CO2 emissions of our business have reduced year on year. For the UK & Ireland portfolio in isolation, we have achieved a reduction in electricity usage of 1.7% on a like-for-like basis and 10.3% on an absolute basis.