Rest of World
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Rapha Racing Ltd (Rapha) during the year ending 31st January 2019 to prevent modern slavery and human trafficking in its business and supply chain.
Rapha was established in 2004 as an online retail company, and has since expanded to include physical retail spaces known as Clubhouses. These can currently be found in 23 vibrant cycling locations around the world, as well as temporary Pop-Ups and Mobile Clubhouses out on the road.
At Rapha, we have built a reputation for maintaining the highest possible quality and the most technically advanced production techniques in cycling apparel manufacturing, with a nod to the nostalgia and culture of road cycling. To achieve consistent high standards, Rapha works only with the best in the industry, delivering products ranging from vintage merino tracksuits to WorldTour-winning racing apparel. Rapha is headquartered in London, where it was founded, and has regional offices in the US, Australia, Japan and Hong Kong. In addition, Rapha has a non-retail presence in Switzerland, France, Austria, Germany and Singapore.
For this period, Rapha worked with 33 Tier 1 (finished goods) suppliers globally, including those located in China, Vietnam, Italy, Portugal and the USA. Our suppliers represent leaders in their field and are an integral and valued part of realising our product vision. Due to the high standards of workmanship and the reputation of the suppliers we work with, our suppliers typically provide excellent working conditions for their employees.
As we continue to grow, we understand the very real risk of forced labour, fraud or coercion among employees in global business supply chains, and are committed to help combat modern slavery wherever possible.
At Rapha, we insist that our suppliers share our fundamental ethics and values. These values are presented in our Code of Conduct, which is in line with the Ethical Trading Initiative’s (ETI) Base Code, and the conventions of the International Labour Organisation (ILO). We work closely with our suppliers to ensure these high levels of working standards are maintained, and all of our suppliers are asked to sign this document during the initial on-boarding process. It covers but is not limited to Rapha's expectations of Anti-Bribery, Worker Discrimination, Working Hours, Freedom of Association and Child Labour.
Before committing to production with a new supplier, or a new facility with an existing supplier, we carry out a 3rd party social audit which includes health & safety checks, cleanliness, broken needle policies, timekeeping procedures and social facilities. If any non-compliance is uncovered the supplier must present a remediation plan and timeline, followed by a second audit to give evidence for the improvements made.
Rapha has shared a working relationship with many suppliers since the formation of the company. To maintain relationship integrity, wherever possible, we encourage face to face communication between our staff and suppliers at all levels of seniority. Our staff regularly visit our suppliers in person, touring the factory and its facilities. This allows us to assess firsthand the conditions of the facility on a regular basis. Our staff are acutely aware of the standards we deem acceptable and their feedback following a visit contributes to the ongoing assessment of our suppliers. To date, there have been no instances of exiting a factory due to poor working conditions.
To further improve engagement and accountability, communication with our Tier 1 suppliers is divided between the members of our Supply Chain Team. This ensures that all orders, quality inspections and social audits are requested and received by the same individual, giving them a holistic understanding of a supplier’s performance and any grievances they may have. This depth of relationship allows for the highest quality of communication. It also gives us the capacity to adopt new and more effective ways of working.
As Rapha grows as a business, we are committed to acknowledging our responsibility as a manufacturer. In late 2018 Rapha created a full time position, the Sustainability Lead, which is dedicated to actively seeking out and utilising industry leading programs for the monitoring of social compliance in its supply chain. As a result of this research, Rapha became members of the Sustainable Apparel Coalition (SAC), a community of brands from within the apparel and footwear industry committed to the betterment of the sector through collaboration and the development of standardised performance tools. One of the primary benefits of the SAC is its suite of Higg Index tools, particularly in this case the Facility Social Labour Module (FSLM) which we will use to engage with our suppliers. In the coming financial year, we will look to onboard strategic suppliers, by centralising social audits through this platform. For supply chain partners that are not already part of the Higg Index, we will be working with them on a one to one basis, to ensure confidence and adoption of this system.
We are actively leveraging the SAC tools and network to improve our understanding of our supply chain. Our findings will continue to inform our Modern Slavery policies going forward.
As part of our ongoing efforts, we have conducted an assessment of our existing policies related to Modern Slavery. These findings, in conjunction with expert legal consultation have helped inform a wider, more stringent Master Service Agreement that will be rolled out to all our Tier 1 suppliers in the coming year. This Master Service Agreement will help to expand on and strengthen our Code of Conduct and enforce our position on conditions and working practices related to Modern Slavery.
Simon Mottram, CEO