Human Rights

HUMAN RIGHTS POLICY

Contents:

  1. Introduction
  2. Scope
  3. Purpose
  4. Governance
  5. Policy commitments
  6. Group’s expectations for employees
  7. Group’s expectations for suppliers and business partners
  8. Human Rights Due Diligence and Impact Assessment
  9. Human rights complaints procedure
  10. Violations of this policy

Policy introduced: November 2024
Policy owner: Legal Department

1. INTRODUCTION

Truworths International Ltd is an investment holding and management company based in Cape Town, South Africa. The main operating subsidiaries, Truworths Ltd (“Truworths” operating in South Africa) and Office Holdings Ltd (“OFFICE” operating primarily in the United Kingdom) are leading retailers of fashion clothing, footwear, homeware and related merchandise. Truworths International Ltd and all its subsidiaries is collectively referred to as “the Group” or “we”.

The Group acknowledges its responsibility to contribute to the promotion and protection of human rights. We recognise that our employees and other people with whom we work are entitled to human rights such as (but not limited to) freedom from discrimination, the right to life and security, freedom from slavery, freedom of association, including the right to join or not to join trade unions, and fair working conditions. We take particular care to ensure that our supplier connections and security arrangements do not lead to human rights abuse.

The Group recognises the inherent dignity and equal rights of all humans, and we acknowledge our moral, ethical and legal duty to respect human rights within our sphere of influence, in line with national and international standards, throughout our operations and supply chains.

We expect our staff, contractors, visitors, customers, suppliers, business partners and any person or entity that has any dealings with the Group to share the same commitments to and respect for human rights.

Our approach to human rights follows the United Nations’ “Protect, Respect, and Remedy” framework as set out in the United Nations’ Guiding Principles on Business and Human Rights. Our commitment to human rights involves respecting and promoting the rights of all involved in activities linked to the Group as a responsibility that transcends both our workplace and our operations and extends to include suppliers and other business partners in a wider sphere of influence.

The Group is also committed to adhering to the Organization for Economic Cooperation and Development (“OECD”) Guidelines for Multinational Enterprises on Responsible Business Conduct, which are recommendations jointly addressed by governments to multinational enterprises to enhance the business contribution to sustainable development and address adverse impacts associated with business activities on people, planet, and society. In respect of our supply chain, we are guided by the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector (2018).

2. SCOPE

This Policy applies to all employees of the Group, irrespective of the nature of their contract or role, as well as independent contractors, non-executive directors, consultants, advisers, suppliers, service providers, representatives and persons acting on behalf of the Group in any capacity.

Together with our employees and business partners, we are committed to drive forward the implementation of this Policy throughout our operations and supply chains.

3. PURPOSE

This Policy seeks to promote and protect, with dignity, the human rights and fundamental freedom of employees in the workplace and across all stakeholders of the Group.

Our Human Rights Policy fosters greater awareness of human rights issues throughout the Group and enhances our capabilities to identify and manage human rights issues in key areas relevant to our business: employees, suppliers, security providers, other service providers and customers.

This Policy also reinforces our existing policies, processes and activities that support our human rights values and commitments.

4. GOVERNANCE

The Group is guided by its fundamental corporate principles that value and promote respect for human rights, consistent with the following laws and guidelines, both local and international:

  1. South Africa’s Constitution and Bill of Rights
  2. Human rights applicable to all the countries in which the Group operates
  3. Modern Slavery Act, 2015 (UK)
  4. Prevention and Combating of Trafficking in Persons Act, No. 7 of 2013 (South Africa)
  5. United Nations Universal Declaration of Human Rights
  6. United Nations Guiding Principles on Business and Human Rights
  7. International Labour Organization’s Declaration on Fundamental Principles and Rights at Work
  8. International Bill of Human Rights
  9. Voluntary Principles on Security and Human Rights
  10. United Nations Sustainable Development Goals
  11. Ethical Trade Initiative (“ETI”) Base Code

5. POLICY COMMITMENTS

We are committed to meet our responsibility to respect human rights and to contribute to positive human rights outcomes. As such, this Policy:

  • Is approved at the most senior level of the Group, being the board of Truworths International Limited;
  • Is informed by relevant expertise;
  • Contains the Group’s human rights expectations of employees, business partners and other parties directly linked to its operations, products and services;
  • Is publicly available and communicated internally and externally to all employees, business partners and other relevant parties; and
  • Is reflected in operational policies and procedures necessary to embed it throughout the Group’s business enterprises.

We believe that human rights are basic rights and freedom for everyone based on dignity, fairness, equality and respect:

  • Equality, Dignity and Respect – We aim to ensure that all individuals affected by the Group’s operations are treated equally and with dignity and respect, and that the Group adheres to the provisions of the Promotion of Equality and the Prevention of Unfair Discrimination Act, No. 4 of 2000 (SA), the Equality Act, 2010 (UK), and the African Charter on Human and People Rights. In addition, the Group is committed to advancing gender equality in the workplace and community, and aligns to the United Nations’ Women Empowerment Principles, including high-level corporate leadership, fair treatment without discrimination, health, well-being and safety, and education and training for career advancement.
  • Prohibition of child labour – We comply with the legislative and moral principles relating to the prohibition of work by children under the age of 15 (UK: 16 years). In this regard, the Group complies with laws within South Africa and other countries in which it operates and abides by the ILO Minimum Age Convention 1973 (C138) and the principles enunciated in the ILO Worst Forms of Child Labour Convention, 1999 (C182). The principles in respect of the employment of children aged 15 to 18 (UK: 16 to 18) are equally adhered to by the Group, and no child of such age may be required to do work that is inappropriate for their age or work that places at risk thechild's well-being, education, physical or mental health, or spiritual, moral or social development.
  • Freedom from forced labour - Employees are recruited in line with international standards and may resign from their employment as set out as a term in employment contracts. We are committed to the International Labour Organization’s Forced Labour Convention of 1930 (C029) and comply with the provisions of the UK Modern Slavery Act, 2015. All our suppliers and business partners are required to implement recruitment and sub-contracting practices that are free from forced labour, slavery, servitude and human trafficking, and cruelty or degradation of the human condition.
  • Freedom of association – We respect our employees’ right to freedom of association, and to belong or not to belong to a trade union, and to collective bargaining.
  • Right not to be discriminated against or harassed or be subject to gender-based violence – We have a zero-tolerance policy towards any form of bullying, harassment, gender-based violence or unfair discrimination in the workplace.
  • Working conditions and workers’ rights – We respect employees’ rights as prescribed by the labour laws of the countries in which we operate, and their rights to adequate water, sanitation, and safe working conditions. We are committed to the protection of health and safety of employees and other persons present in our work areas or business units. We abide by legislative requirements relating to employment rights, freedom of association and collective bargaining.
  • Privacy – We are committed to respecting and protecting the privacy rights of our employees, customers, suppliers, business partners and all individuals and entities with whom we do business, and to establishing appropriate controls to safeguard personal data in line with the provisions of the Protection of Personal Information Act, 2013 and the General Data Protection Regulation (EU).

The Group also acknowledges that it may affect people’s human rights through its own activities or through its business relationships. The impact can be positive, such as by providing decent and safe working conditions and fair pay. However, it may also include negative impacts such as unsafe working conditions within the supply chain, or poor safety or security practices.

To make human rights a consistent part of how the Group does business, works with business partners, manages risks and reports on activities, we:

  • Have governance procedures in place to ensure the most severe and systemic human rights issues are brought to the attention of the senior team
  • Encourage employees to report human rights violations
  • Have improved our approach to identifying and mitigating human rights risks
  • Provide training to employees on human rights
  • Have improved our measures to monitor human rights violations within the Group’s supply chain

6. GROUP’S EXPECTATIONS FOR EMPLOYEES

We believe that if employees live our Values and treat others with dignity and respect, the promotion and protection of human rights will be a natural outcome.

We nurture a culture of trust and mutual respect in which our employees live our Values. We have a zero-tolerance approach towards any conduct that could be considered a violation of human rights, and we aim to create an environment that fosters open communication.

To achieve this, we implement policies and programs to ensure all employees know their rights and the expected behaviours that align with our Values, which are communicated to employees during induction and are available on our internal systems.

We are committed to upholding the human rights and dignity of all prospective job applicants throughout our recruitment process. We ensure that every applicant is treated with fairness, respect, and equality, free from any form of discrimination or bias. We aim to create an inclusive recruitment process that promotes diversity, and which continues to reinforce our commitment to ethical and responsible hiring practices.

7. GROUP’S EXPECTATIONS FOR SUPPLIERS AND BUSINESS PARTNERS

When our customers buy any of our products, we want them to have confidence that our business is committed to being ethical and fair in all our dealings.

We promote the observance of human rights among our suppliers and third parties with whom we enter into and maintain business relationships. We contractually require our suppliers and service providers to comply with and implement measures to promote the protection of internationally recognised human rights.

In line with the Group’s commitment to an ethical supply chain, we evaluate our local and international suppliers’ cultural fit, and technological and manufacturing processes. We expect our suppliers to apply best practice quality control and go beyond compliance with legislation to safeguard employees, local communities and the environment.

The Truworths Code of Ethics and Good Business Practice for Suppliers and Business Partners (“the Code”) specifies the minimum ethical, social and business practices and standards that Truworths requires of its suppliers and business partners. By signing the Code, our suppliers agree to align with our Values. The Code aligns with international standards, and we conduct assessments to mitigate non-compliance.

In the United Kingdom, OFFICE works in collaboration with the supply base to implement OFFICE’s Code of Ethics and Good Business Practice, including a strict auditing program in line with its Modern Slavery Statement and Animal Products Policy. The OFFICE Code of Ethics and Good Business Practice is based upon the following general principles:

  • All OFFICE products are produced lawfully, through fair and honest dealings.
  • All persons who maintain any kind of employment, economic, social and/or industrial relationship with OFFICE are not exploited and are treated fairly and with dignity.
  • OFFICE and all its suppliers must provide decent working conditions for all employees.

Collectively, the Codes require suppliers to comply with international human rights standards, based on the following employment principles:

  • Compliance with legal requirements
  • Employment must be freely chosen (no forced, bonded, indentured, traffic, slave or prison labour)
  • Freedom of association and collective bargaining
  • Working conditions must be safe and hygienic
  • Child labour shall not be used
  • Living wages are paid
  • Working hours are not excessive
  • Fair treatment
  • Regular employment
  • Subcontracting compliance

We continually engage with our suppliers to enhance and update the Codes, and our efforts seek to address the risks of human trafficking and slavery in the supply chain. We maintain internal accountability standards for suppliers/business partners failing to meet our standards regarding human rights violations, including human trafficking and modern slavery.

We expect our suppliers to create conditions so that no worker pays for a job, workers retain control of their travel documents and have full freedom of movement, and all workers are informed of the basic terms of their employment.

We expect suppliers and security providers to respect internationally recognised human rights, and to adhere to the United Nations’ Guiding Principles on Business and Human Rights. Any non-compliance by a supplier that comes to our attention is required to be rectified within a prescribed time period. Any severe human rights violation is viewed in a serious light.

8. HUMAN RIGHTS DUE DILIGENCE AND IMPACT ASSESSMENT

Those human rights as internationally observed and regulated within the legislative and constitutional context of South Africa, the United Kingdom, and the other countries within which the Group operates, are included in a Human Rights Due Diligence and Impact Assessment. In addition, the countries in which our key suppliers operate are mapped to highlight social and geographical risks.

The due diligence process focuses on human rights risks relating to the business model, business relationships, operating context, the workforce and supply chain.

The process includes assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. The impact assessment will be carried out on a regular basis.

9. HUMAN RIGHTS COMPLAINTS PROCEDURE

We have implemented an effective procedure to receive and address human rights complaints from employees. The procedure is accessible and provides adequate assistance to those who may face barriers to accessing the complaints procedure and process.

We encourage all employees to report and express their concerns relating to suspected violations of this Policy. Complaints about actual, potential or suspected human rights violations may be lodged in the following ways:

  • To the Human Resources Department
  • To the Anonymous Ethics Hotline, the details of which are set out in the Truworths and Office Whistle Blowing Policy respectively.

If there are any concerns that our business activities may be responsible for or contribute to human rights violations, we will thoroughly investigate the matter, address concerns raised, and take appropriate corrective action to rectify any violations. In addition, top management must be made aware of any human rights violations and the necessary remedial steps shall be taken as soon as reasonably practical.

10. VIOLATIONS OF THIS POLICY

Failing to comply with this Human Rights Policy is viewed in a serious light and may lead to disciplinary action, including dismissal and reporting the matter to the relevant authorities, where necessary.