Transparency Statement - At Chilly’s, we respect human rights and do not tolerate any form of modern slavery.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Chilly’s Bottles Limited’s (Chilly’s) slavery and human trafficking statement for the financial year commencing 1 August 2022 and ending 31 July 2023. This statement sets out the steps we have taken (and continue to take) to prevent slavery and human trafficking within our supply chain during our 2022/23 financial year.
We recognise that no supply chain is without risk of modern slavery, and it is our responsibility to ensure we understand these risks and work in partnership with our suppliers and other stakeholders to identify and mitigate them.
This statement has been published in accordance with the UK Modern Slavery Act 2015 which requires businesses to disclose the steps they are taking to tackle slavery, servitude, forced or compulsory labour and human trafficking (known as modern slavery).
Chilly’s is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers. Our statement includes six areas outlined by the legislation and takes into account guidance issued by the Home Office.
Company Overview
Chilly’s is a multi-channel consumer product business incorporated in England and Wales with the Head Office registered in London.
Chilly’s mission is to accelerate the adoption and everyday use of reusable products. We aim to do this by creating products for an urban lifestyle, with the perfect balance of distinctive design and unrivalled performance. Chilly’s is a leader in reusable water bottles, coffee cups, food pots and reusable products.
We employ 50+ people in the UK. We have millions of customers around the world who shop directly with us or through other distribution channels.
The Business Structure & Supply Chain
Chilly’s primarily operates as a multi-channel consumer product business worldwide.
To produce our reusable water bottles, cups, food pots and related products, we work with a range of suppliers. The products we sell are sourced globally from the UK, Europe and China. Our two main supply chain partners are based in China and the UK, both manufacturing in China. It is with these partners that we have focused most of our efforts.
There are additional indirect suppliers in our extended supply chain, including suppliers of raw materials and components used in the products we sell and buy.
We also source goods and services not for resale (GNFR) in the UK and Europe
Our Policies in relation to Modern Slavery and Human Trafficking
Chilly’s has the following policies relating to social standards within our supply chain, including anti modern slavery standards:
Chilly’s Supplier Code of Conduct
Chilly’s supplier code of conduct outlines the social standards that we require our suppliers who make our products to adhere to. Our Code includes standards related to working conditions, freedom of association, working hours and health and safety. This is aligned to the ETI Base Code, and internationally recognised code of labour practice, founded on the conventions of the International Labour Organisation (ILO).
Ethical Trade & Human Rights Policy
Our Ethical Trade & Human Rights Policy outlines our baseline requirements, and links back to our Code of Conduct. It also includes how we address non-conformities and corrective action plans.
Our Due Diligence in relation to Modern Slavery and Human Trafficking in our supply chains
Being an online ecommerce operating company, Chilly’s outsource a number of functions for both goods and services. We recognise that our most significant human rights and modern slavery risks are in our supply chain. We continue to roll out programmes of ethical audits for high-risk production site both home and abroad. Each production site is required to have a valid audit.
Our due diligence processes
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we undertake due diligence in relation to our Code of Conduct and general anti modern Slavery standards:
Supplier Assessment Questionnaire (SAQ)
To understand how our suppliers who produce Chilly’s products are meeting our standards outlined in our Code of Conduct, we ask them to complete a supplier assessment questionnaire. The questions align directly to the standards within our Code of Conduct, enabling us to highlight any non-conformities or areas for improvement.
Chilly’s SAQ has been used throughout 2022/23 to understand the performance of our supply chain. As members of Sedex, we will be moving away from our own SAQ, instead utilising Sedex’s SAQ. The platform will enable us to analyse the results and identify risks and trends within our suppliers.
Sedex Membership
In 2023, Chilly’s became a member of Sedex, a data platform for supply chain assessment which enables us to effectively monitor our suppliers social and environmental practices. Through the platform, our suppliers can share information relating to their practices and the data is stored, analysed, and reported on through the platform. This provides us with a clear overview of our suppliers sustainability practices, analyses risks and identifies trends, allowing us to create clear action plans to mitigate these.
We’re excited to be on our journey with Sedex, as it will enhance our management of our suppliers, holding them to high, industry agreed social and environmental standards, as well as increasing transparency throughout our supply chain.
We look forward to sharing more information as we progress on this.
Audit Reports
Chilly’s requires its two main product suppliers to supply them with SEMTA audit reports. SMETA is the audit methodology defined by Sedex. In 2022/23 we have received and reviewed these.
In 2023/24, we will be using Sedex to understand our risks and identify which other suppliers should be undertaking these audits.
Chilly’s commitments which will be worked on during 2023/24:
- Build on our current responsible procurement processes to formally integrate sustainable considerations into all types of procurement by end of 2023
- Onboard to Sedex 100% of tier 1 and tier 2 product suppliers by end of 2024
- Review, update and publish our policies every 2 years. Resharing these with our suppliers when we do this.
Risk and Compliance
Given that our products are largely produced in China, we acknowledge that we operate in a location that has a high risk of modern slavery potentially occurring. To combat this potential risk, we have relied on third party audits for our three key manufacturers as well as our Supplier Assessment Questionnaires to understand compliance to our Code of Conduct.
In 2023, Chilly’s signed up to Sedex, a platform which has a tool (Radar) which enables companies to evaluate risks across key topics, including modern slavery, based on sector and geographic location. Sedex’s platform also enables companies to evaluate the level of compliance its suppliers have against social standards. We will support our suppliers to complete a supplier questionnaire (SAQ) on Sedex. From this, Chilly’s will be able to identify any risks and themes. In 2023/24, Chilly’s will define how it will address these risks to ensure they are mitigated.
Also in 2023/24, Chilly’s is committed to building on its use of Sedex, transitioning its risk and compliance management to the platform. Chilly’s has a public target to onboard 100% of tier 1 and tier 2 product suppliers to Sedex by end of 2024. This will give us a clear oversight of the level of modern slavery and human rights risk and compliance throughout our supply chain.
Chilly’s does not tolerate slavery and human trafficking within our supply chains. If we find evidence of a failure to comply with our policy, we would engage with the supplier and discuss remediation plans. If there are continued non-compliances, we reserve the right to terminate our relationship with the supplier concerned.
Our effectiveness, measures and performance indicators
In 2023/24, Chilly’s will define how it will use the Sedex platform to measure our effectiveness at preventing or mitigating risks of modern slavery in our supply chain. We will report on this in future years.
Training
In 2022/23, modern slavery training was undertaken with the Supply Chain, Customer Service and Merchandising teams. These were selected as they communicate most with our suppliers and operate in areas which are more at risk of coming into contact with incidents of modern slavery.
In 2023/24, we will continue with training our teams. The ambition is to provide training on modern slavery to the whole team and to run more in depth sessions with the Operations Team.
