MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

We know that slavery, servitude, child labour, forced labour and human trafficking (“Modern Slavery”) are global and growing issues given the rapid increase in global migration, existing in every region in the world and in every type of economy, whether industrialised, developing or in transition. No sector or industry can be considered immune or untainted. Modanisa is very keen on having high standards for supply chain and working conditions. Modanisa has zero-tolerance approach to Modern Slavery including but not limited to human trafficking, slavery, servitude, child labour, forced labour within our operations and supply chain. We all have a responsibly to be alert to the risks in our own business and in the supply chains. Any evidence of violations of the applicable laws will be investigated and appropriate measures will be taken.

Our organisation and business

Founded in 2011, Modanisa enables modest women to look good and feel self-confident in today’s world. Our mission is to build a global ecosystem that combines fashion and technology to serve the life style needs of modest women. We bring fashion and technology together with iconic brand and smart operations to create great value for our customers. We invest in each and every customer’s experience. We strongly believe in putting people first – our customer, our team, our partner. We bring accessibility to latest fashion, embrace differences and honor diversity. We build mutual trust with our stakeholders and we are a brand good on our word.

Our policies on Modern Slavery

It is one of our guiding principles to build and maintain the highest standards amongst our suppliers and take practical steps to guard against exploitation of workers, forced labour, harassment, intimidation and human trafficking. Equally, Modanisa is focussed on providing a working environment in which our People can thrive. Our suite of people-related strategies and policies ensure that integrity is ingrained as a core value, and annual delivery of our specialist modern slavery training validates our shared understanding of our compliance culture. It is the responsibility of all our People to adhere to the strategies, policies and training provided, in addition to any specific local requirements. Our strategies and policies are extended to our prospective supply chain partners through our SCWC Policy and are made available through our corporate website.

Modanisa internal policies include our Supply Chain and Working Conditions Policy (“SCWC Policy”) where we confirm that we will not tolerate or condone abuse of human rights within any part of our business or supply chains and will take seriously any allegations that human rights are not properly respected. In addition, our other internal policies and procedures such as our Employment Procedure and Code of Ethics envision rules which embody our utmost attention and sensitivity for fight against Modern Slavery.

Our supply chains

Almost all of Modanisa’s product suppliers are based within Republic of Turkey but we are provided with the services from all over the world, especially technology suppliers based overseas.

We have zero tolerance to Modern Slavery. As part of the Modanisa’s commitment to these principles, in May 2019 Modanisa developped the Modanisa Supplier Situation Analysis System for its suppliers (“Supplier Analysis System”) as part of its supply chain management. Modanisa requests to be informed about suppliers’ situations and their commitment on ethical business principles in several areas where human rights can be affected. These include the prohibition of forced labour, child labour and inhumane treatment. In connection with the priority issues established in the different areas, enhancing management of the entire supply chain from the viewpoint of corporate social responsibility has been established as a priority area.

All Modanisa employees around the world are required to abide by SCWC Policy in order to ensure that Modanisa exhibit and promote ethical business activities. Modanisa do not use child or forced labour in any of our global operations or facilities. None of us should tolerate any form of unacceptable treatment of workers in our operations or facilities. This means, among other things, that we do not permit exploitation of children, physical punishment or abuse, or involuntary servitude. We fully respect all applicable laws establishing a minimum age for employment, in order to support the effective abolition of child labour worldwide. Workers under the age of 18 shall not perform hazardous work and all workers under the age of 18 are employed solely with legal intern status. Employees understand that they must know and follow our policies, as well as the policies and procedures that apply to their job. Employees are expected to report known or suspected violations. Finally, failure to follow the law or the policies will subject employees to disciplinary action, up to and including termination.

We promote action to ban slavery and human trafficking from our supply chain. For the products that we sell, suppliers of those products are requested to commit to the ethical business principles set out in SCWC Policy. Further, we reflect those standards in agreements with suppliers. For products that we source ourselves and for services, all our suppliers receive a statement within their terms of business of our expectation that they, and their own supply chain, are free of slavery, servitude, forced labour and human trafficking. The statement refers to confirmation that our suppliers are deemed to be giving if they continue to supply products and/or services to us.

We take all reasonable levels of assurance and undertake the following activities on an ongoing basis to assess and address these risks:
 

• Due diligence process with a supplier in order to determine whether that they comply with Modern Slavery,
• Informing the suppliers related with SCWC Policy and Modern Slavery regulations and obtainment of statement in which suppliers undertake to comply with them,
• Determining the parts of the supply chain where there is a risk of slavery and human trafficking and implementation of a special audit program for the suppliers possessing such risks,
• Providing Modern Slavery trainings to all employees, and
• Implementation of a process on reporting violations.

Training

In order to promote the compliance with the SCWC Policy, Modanisa provides specific training to all Modanisa Employees. This training will be tailored in accordance with the relevant needs and circumstances as well as Modanisa Employees' seniority and position. This training will be related to the Modern Slavery and Human Trafficking Laws and the SCWC Policy. Modanisa Employees, regardless of their positions, are all required to participate in any such training.

Declaration

This statement has been published in accordance with the Modern Slavery Act 2015 and it sets out the steps taken by Modanisa Elektronik Mağazacılık ve Ticaret A.Ş. and its group companies (“Modanisa”) during year 2019 to prevent modern slavery and human trafficking in its own business and its supply chains.

As always, Modanisa will approach the fight against Modern Slavery with sensitivity and further develop the measures it takes in this context every year.