Modern Slavery Statement
This statement is made, on behalf of TIGI International Limited, trading as Elida Beauty (“Elida Beauty”), pursuant to the UK Modern Slavery Act 2015, section 54(1) Transparency in supply chains and as such constitutes our modern slavery and human trafficking statement for the year ending 31 December 2023.
Elida Beauty is committed to maintaining the highest standards of honesty and integrity in all our dealings, wherever we operate. We have a zero-tolerance approach to bribery, corruption, the use of child or forced labour and human trafficking.
The Modern Slavery Act 2015 covers both our supply chain and our own business operations. In this statement therefore, we have covered our approach to both activities.
Signed: Mark Bleathman, General Manager Elida Beauty UKI & ANZ
1. The Business
Elida Beauty, is a stand-alone business, within the Elida Beauty group. Until June 2024 the Elida Beauty business was owned by the Unilever Group, at which point it was sold to Yellow Wood Partners. Yellow Wood Partners is a US based private equity firm, founded in 1981.
The Elida Beauty is a consumer led personal care business comprising various well-known beauty and personal care brands including TIGI, V05, Impulse, Alberto Balsam and Tony & Guy. We partner with trusted third-party manufacturing facilities around the world to manufacture our goods, with the main countries of origin being the USA, UK, Turkey, Egypt and Indonesia. Sourcing of raw materials and packing and some manufacturing is also carried out by Unilever. These partners are businesses with whom we have long-standing relationships.
Elida Beauty Group produces around 420 million units of product each year.
2. Policies
Our Elida Beauty Code of Conduct and associated policies clearly state that we have zero tolerance of forced, trafficked or compulsory labour. The same standards are flowed down through our supply chain. For 2023, our suppliers were subject to the Unilever Responsible Partner Policy, shared with all suppliers, which states that “Forced labour will never be used, including slavery, trafficked labour, indentured labour, bonded labour or other forms including mental and physical coercion.” From June 2024, we will begin to transition suppliers from Unilever to Elida Beauty’s own Supplier Code and assurance systems, which will include the same statement prohibiting forced labour.
Our suppliers are expected to notify Elida Beauty if any critical human rights issues including modern slavery are found so that we can work together on a solution.
3. Employment practices
Elida Beauty has approximately 200 permanent employees (including those on full time and part time permanent contracts).
We comply with all local employment legislation and where possible exceed requirements. Right to work documentation is checked and confirmed before any employment offer is made and names, bank accounts, details are all checked to ensure identity fraud is not committed and payment is made directly to employees. All terms and conditions are shared prior to employment and policies are made available on joining, including our complaint mechanisms and ethics helpline.
4. Supplier assurance
4.1 Risk assessment
We carry out risk assessments on our supplier base on an ongoing basis, including risks relating to individual countries and products.
4.2 Due Diligence
For the year to 31 December 2023, our supply chain was governed by Unilever processes:
· All suppliers were subject to Due Diligence screening.
· Indirect suppliers over a certain threshold were expected to complete an EcoVadis assessment.
· High-risk direct suppliers were expected to submit a SMETA (SEDEX Members Ethical Trade Audit) audit report or equivalent as a minimum. SMETA reports are published in the SEDEX system, ensuring transparency and efficient information sharing. SMETA audits use the ETI Base Code, founded on the conventions of the International Labour Organization, as well as relevant local laws to assess working conditions and provide a corrective action plan where improvements are needed. As at June 2024, we had no instances or issues related to modern slavery in our supply chain.
From June 2024, we will begin to transition suppliers from Unilever to Elida Beauty’s own Supplier Code and assurance systems, which will be detailed in our modern slavery and human trafficking statement for the year ending 31 December 2024.
5. Training
Our commitment to ethical working practices is built into our Elida Beauty Code of Conduct and Policies – annual training is rolled out to all employees. Going forward, the requirements of our new Supplier Code will be included in training for employees who have contact with suppliers.
6. Key Performance Indicators (KPIs)
In addition to our supplier audits, our Ethics Helpline is available to employees, contractors, family members and all members of our supply chain to report a wide variety of incidents, including modern slavery. As at June 2024, we have had no reported instances or issues relating to modern slavery. Training data on our Code of Conduct and Supplier Code requirements will be collated going forward.
This Statement has been approved by the board of TIGI International Limited by written resolution dated 31 May 2024.