At Churchill Gowns, our mission is to supply the highest quality graduation attire while maintaining focus on our core beliefs: ethical manufacturing, environmental sustainability and social responsibility. And we pride ourselves on doing business thoughtfully, so we take great care at all stages of our supply chain. We know that modern slavery and human trafficking still thrive in Australia and worldwide, so we’ve made an ongoing commitment to make sure that everyone involved in our business and supply chain is treated fairly.
We’re an Australia based, retailer of graduation clothing, accessories and services. Founded in 2012, we launched the first recycled graduation gowns in Australia, saving the equivalent of 28 plastic bottles for every gown produced. Today, we’re proud to say that we offset our carbon emissions by funding offset programs through Climate Care; and we dedicate 10% of all our profits to funding charities and social enterprises.
Our Australian operation is headquartered in Alexandria, NSW and our UK operation is based in London. Most of our workforce is directly employed by us, but we also use contractors and temporary staff, particularly around peak graduation periods.
So that everything we sell is of the highest quality, our suppliers are based in various locations around the world. The majority of our graduation gowns and hoods are manufactured in China while our mortarboards are produced in the EU. Some specialty items are also produced in Australia and the UK.
We adhere to all relevant employment legislation when it comes to hiring, onboarding and training our employees. On top of this, we always work to support the mental and physical wellbeing - and professional development - of our team.
We’ve developed an Equal Opportunities & Diversity policy which guides our People Team (and all employees) on the avoidance of discrimination at work. We also give mandatory training on diversity and inclusion, which covers conscious inclusion, race and ethnicity and LGBTQ+ topics. We also have policies in place to protect employees at Churchill Gowns throughout their employment. And all employees have access to our policies online, which include anti-harassment and bullying, anti-bribery and corruption and whistleblowing policies. All employees experience a rigorous induction process which covers all of these points and ensures they have a clear understanding of what's expected of them when representing the company from the very beginning of their employment.
Soon, we will be providing training to all staff members on modern slavery. More detailed training will be given to employees who are most actively involved in our supply chain and procurement. This will help to increase awareness and identify potential cases of slavery in professional - and personal - environments.
Areas of highest risk
We’ve carried out - and documented - a risk assessment on slavery, and wider human rights abuse, in our supply chain. The areas of highest risk we have identified are:
A majority of our products are manufactured overseas. And some in economically developing countries. While the benefits of this include increased employment opportunities and financial investment, we’re aware that the risks of human trafficking in these areas could also be higher. We have selected suppliers who go above and beyond the minimum requirements and we’re proud to work closely with these manufacturing partners, who prioritise the wellbeing of their workers. Among other things, they support gender equality through equality committees, offer Ethical Awareness training, subsidised food and canteen facilities for staff and health awareness training. Various members of our Senior Leadership team have also visited our manufacturing partners. And we’re in constant conversation with the Senior Leadership teams of these suppliers in order to understand their recruitment and employment practices and how they are mitigating any associated risks.
Contractors and temporary staff
The majority of our workforce are directly employed. But we also use contractors and temporary staff around peak graduation times. When contractors and temporary staff are sourced through agencies (rather than directly by ourselves), we’ll only use agencies with practices that are consistent with our sustainable supplier policy (more details below).
Our sustainable supplier policy - People
We continually assess the risk of human trafficking and slavery within our supply chain and will not enter into business with any suppliers who are knowingly involved in such activities. This commitment is communicated to all employees, partners, suppliers and contractors. And we also aim to cascade our ethical standards throughout supply chains.
Our pre-qualification questionnaire for suppliers helps us understand their employment and recruitment practices - and their own risk assessment methodologies - as well as making sure we understand the full supply chain from end to end. We continue to risk assess each of our partners on an ongoing basis or when the respective risk profile changes.
At a minimum, we require our suppliers to adopt the following principles:
- Employment must be freely chosen
- Child labour must not be used
- Staff must be paid legal minimum wages
- Working conditions must be safe and hygienic
- The Employer Pays Principle (no worker should pay for a job)
We’re now putting these principles in contract with any new supplier. And we’re currently in the process of redrafting our contracts with existing suppliers too. We reserve the right to audit and review the controls of our suppliers (including unannounced visits) and to work with them to address and resolve any issues we find.
We work to have as much dialogue and interaction about these issues with the Senior Leadership teams of our suppliers and also their employees, which helps us better understand and identify any risk ourselves.
Lastly, we have a Steering Committee, which meets regularly to consider how we can work with our suppliers to mitigate any risks in our supply chain.
The term ‘modern slavery’ describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. Coercion, threats and deception can be explicit or implicit. The Modern Slavery Act 2018 (Cth) ‘Act’ defines modern slavery as including eight types of serious exploitation; trafficking in persons, slavery, servitude, forced labour, forced marriage, debt bondage, the worst forms of child labour and deceptive recruiting for labour or services. The worst forms of child labour means extreme forms of child labour that involve the serious exploitation of children, including through enslavement or exposure to dangerous work. The worst forms of child labour does not mean all child work. Under Australian law, modern slavery is defined in the Act. In the event of any inconsistency, the definitions in the Act take precedence over this policy.