It is the responsibility of every business to take account for its impact on people, society and the environment. As members of SEDEX we take the CSR of our entire supply chain very seriously and our membership allows us to store, share and report on all of our suppliers. We only work with suppliers that meet the very stringent checks required to conform to the SMETA Audit process.
Incorporatewear, along with our parent company, Wesfarmers, are committed to making positive economic, social and environmental contributions to society, consistent with the principles of honesty, integrity, fairness and respect. We prohibit discrimination, forced, trafficked and child labour and are committed to safe and healthy working conditions, including the right to freedom of association and collective bargaining. We will only work with suppliers who operate in line with our Code of Conduct and Ethical Sourcing Policy.
Addressing Human Rights Impacts
We recognise that we must take steps to identify and address any actual or potential adverse impacts with which we may be involved whether directly or indirectly through our own activities or our business relationships. We manage these risks by integrating the responses to our due diligence into our internal systems, acting on the findings, tracking our actions and communicating with our stakeholders about how we address impacts.
Anti Slavery Policy
Incorporatewear opposes slavery in all its forms. This statement is made pursuant to Section 54, Part 6 of the United Kingdom’s Modern Slavery Act 2015 and sets out the steps Incorporatewear has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
1. Ethical sourcing audit programs
To mitigate the risk of unethical practices occurring in our supply chains, we apply an ethical sourcing audit program to higher risk suppliers. Suppliers are considered lower risk if they operate in more regulated countries or if they are supplying proprietary brands.
Factories in the audit program are required to have a current audit certificate, which means they have been audited by us or another party whose audits we accept. Those audits identify a range of non-compliances, from minor non-compliances such as minor gaps in record keeping to critical breaches, such as incidents of bribery or forced labour.
Forced labour indicators, such as restriction of movement, intimidation and threats, retention of identity documents, withholding of wages, debt bondage, abusive working and living conditions and excessive overtime are explored as part of the ethical audit formats approved under our audit program.
Where a non-compliance is identified, the supplier site is required to fix the issue, within an appropriate period of time, depending on the nature of the non-compliance. Supplier sites are ‘conditionally approved’ if non-critical non-compliances have been identified and notice has been given that they must be fixed. If a supplier site then addresses a non-compliance, it can move to becoming an ‘approved’ supplier site.
If critical breaches are identified, they must be addressed immediately. If they are addressed satisfactorily, a supplier site can then become approved. In this way, our audit process is contributing to improving conditions for workers by working with supplier site owners to address any issues. If a supplier site is not willing or able to address a critical breach, our business will not continue to buy from that supplier site.
3. Ethical sourcing training
We keep our buying and sourcing teams up-to-date on our ethical sourcing commitments and how their actions may impact worker rights. We regularly deliver ethical sourcing training to our team members in our retail businesses and supply chains to refresh their knowledge on this subject.
We continue to build the awareness and knowledge of our employees and workers on human rights, including labour rights, encouraging them to speak up, without retribution, about any concerns they may have, including through our grievance channels. We also promote the provision of effective grievance mechanisms by our suppliers.
Supplier Sustainability Code
Incorporatewear also abide by a Supplier Sustainability Code. The purpose of this policy is to provide a purchasing framework that will advance the sustainable use of resources. ICW intend to demonstrate to the community that the purchasing decisions of its employees can improve markets for recycled products, enhance environmental quality and be responsible.
Incorporatewear Limited UK Tax Strategy
The publication of this tax strategy is regarded as satisfying the statutory obligation, under Part 2 of Schedule 19 of the Finance Act 2016, for Incorporatewear Limited Incorporatewear for the period ended 30 June 2018. The ultimate parent company of Incorporatewear is Wesfarmers Limited Wesfarmers, an Australian public company listed on the Australian Securities Exchange.
Incorporatewear provides bespoke corporate clothing solutions to large blue chip clients worldwide. Incorporatewear has been supplying inspirational corporate wear for more than 20 years and has a wearer base in excess of 350,000.
Commitment to compliance
Incorporatewear is committed to full compliance with its statutory obligations and takes a conservative approach to tax risk. Incorporatewear aims for certainty on all tax positions it adopts. Where the tax law is unclear or subject to interpretation, professional advice is obtained, and when necessary the UK tax authorities (or other relevant tax authority) are consulted for clarity.
The Incorporatewear tax policy is aligned to the Wesfarmers Group tax policy. Key aspects of the Wesfarmers Group tax policy are outlined within the Wesfarmers 2017 Tax Contribution Report and include an internal escalation process for referring tax matters from the Incorporatewear’s Head of Finance to the Wesfarmers Group Tax Function. The Executive General Manager of Wesfarmers Group Finance is required to report any material tax issues to the Wesfarmers Board.
Attitude of the group towards tax planning
Incorporatewear’s approach to tax planning is aligned with Wesfarmers’ approach to operate and pay tax in accordance with the tax law in each relevant jurisdiction. Incorporatewear will not engage in artificial transactions, the sole purpose of which is to reduce UK tax.
Approach to tax risk management
The Head of Finance of an Australian parent entity, as Senior Accounting Officer, is responsible for ensuring that appropriate policies, processes and systems are in place and that these are reviewed for operational effectiveness.
Incorporatewear’ manages its tax affairs in consultation with PwC. Incorporatewear will always seek external advice on tax consequences where the transaction is material or complex.
Relationship with HMRC
Incorporatewear seeks to adopt a transparent and collaborative relationship with the UK tax authorities (HM Revenue and Customs). In particular, Incorporatewear seeks to:
- engage in full, open and early dialogue with the UK tax authorities to discuss tax planning, strategy, risks and significant transactions;
- make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests in a timely fashion;
- resolve issues with the UK tax authorities in real time and before returns are filed if possible, and where disagreements arise, work with the UK tax authorities to resolve issues by agreement (where possible);
- be open and transparent about decision making and governance;
- have reasonable grounds to believe that transactions are structured to give a tax result which is not inconsistent with their economic consequences (unless specific legislation anticipates that result), nor contrary to the intentions of Parliament; and
- interpret the relevant laws in a reasonable way.
30th June 2018