Free shipping on all UK orders over £20  Click here for details.
Get $10 off when you give $10 to a friend → Give $10, get $10 off →

Menu

Account

Modern Slavery Statement

  1. We acknowledge that the Modern Slavery Act (2015) demonstrates the UK’s commitment to identify, remediate and lead the global fight against modern slavery. We are committed to ensuring that there is no form of modern slavery or human trafficking within our organisation or our supply chains. This statement sets out our actions in 2019-2020 to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business - and that our suppliers share the same commitment.

  2. For the purposes of this statement we have defined the acts of modern slavery to include:

    • ●  slavery or slavery like practices,

    • ●  servitude,

    • ●  forced labour,

    • ●  debt bondage,

    • ●  deceptive recruiting for labour or services,

    • ●  human trafficking; and

    • ●  child labour

  3. This statement constitutes our modern slavery statement for the Australian financial year ending 30 June 2020. It sets out an explanation of:

    • ●  who we are as an organisation and what we do

    • ●  where we believe our risks of slavery and human trafficking exist

    • ●  how we currently manage those risks

    • ●  what further steps we are taking to ensure we continue to manage those risks

  4. We have used materials from the Ethical Trading Initiative as guidance for this statement

About us

  1. We are a privately-owned profit-for-purpose social enterprise selling toilet paper and related tissue products direct to consumers in Australia, the USA, EU and the UK. We give 50% of our profits to charity partners that share our mission to bring toilets to the 2.3 billion people in the world who need one.

  2. We are registered at the following locations:

    • ●  United Kingdom (UK):Who Gives A Crap Limited, c/o MHA MacIntyre Hudson, 6th

      Floor, 2 London Wall Place, London, UK; VAT 268 3946 55

    • ●  Australia:Good Goods Pty Ltd, Suite 816, 585 Little Collins St, Melbourne VIC 3000;

      ABN: 67 154 870 452

    • ●  United States of America (USA):Who Gives A Crap Inc, 5042 Wilshire Boulevard

#43291, Los Angeles, California, 90036

Modern Slavery Statement


Introduction

  1. We acknowledge that the Modern Slavery Act (2015) demonstrates the UK’s commitment to identify, remediate and lead the global fight against modern slavery. We are committed to ensuring that there is no form of modern slavery or human trafficking within our organisation or our supply chains. This statement sets out our actions in 2019-2020 to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business - and that our suppliers share the same commitment.

  2. For the purposes of this statement we have defined the acts of modern slavery to include:

    • slavery or slavery like practices,

    • servitude,

    • forced labour,

    • debt bondage,

    • deceptive recruiting for labour or services,

    • human trafficking; and

    • child labour

  3. This statement constitutes our modern slavery statement for the Australian financial year ending 30 June 2020. It sets out an explanation of:

    • who we are as an organisation and what we do

    • where we believe our risks of slavery and human trafficking exist

    • how we currently manage those risks

    • what further steps we are taking to ensure we continue to manage those risks

  4. We have used materials from the Ethical Trading Initiative as guidance for this statement

About us

  1. We are a privately-owned profit-for-purpose social enterprise selling toilet paper and related tissue products direct to consumers in Australia, the USA, EU and the UK. We give 50% of our profits to charity partners that share our mission to bring toilets to the 2.3 billion people in the world who need one.

  2. We are registered at the following locations:

  • United Kingdom (UK):​ Who Gives A Crap Limited, c/o MHA MacIntyre Hudson, 6t​h Floor, 2 London Wall Place, London, UK; VAT 268 3946 55
  • Australia: Good Goods Pty Ltd, Suite 816, 585 Little Collins St, Melbourne VIC 3000;ABN: 67 154 870 452
  • United States of America (USA):​ Who Gives A Crap Inc, 5042 Wilshire Boulevard
  • We commenced trading in Australia in 2013 and expanded into the USA and the UK in 2016 and 2017 respectively.

Our Structure and Operations

  1. At 30 June 2020, we employed 37 permanent staff and 76 casual, freelance and contracted workers

  2. Our operational functions are spread across four global working hubs:

    • Australia: Finance, B2B Sales, Logistics, Supply Chain, Legal, People & Culture,

      Procurement

    • USA: Creative, Marketing, Digital, Recruitment

    • Philippines: Customer Service, Training & Development

    • China: Production, Sourcing, Quality Assurance, Quality Control

  3. We are B Corp certified which means that we meet the highest standards of verified social and environmental performance, public transparency, and legal accountability to balance profit and purpose. More information regarding B Corp certification can be found on the B Corp website: https://bcorporation.net/

Our People

We wouldn’t be Who Gives A Crap without our uber-devoted and talented people. We value each of our employees, both full-time and freelance friends, and ensure that we provide structured and holistic opportunities for career development and growth within the business. We stand by a transparent and fair recruitment and interview process in order to reduce bias and provide equal opportunity to all candidates.

In each of our office “hubs” we work closely with legal counsel to ensure we are consistently up to date on all employment laws and standards, and we take pride in the fact that we then go beyond the baseline expectation for employee satisfaction.

We approach employee wellness with the nuances of each of our hub cultures in mind and work our hardest to create work conditions that allow flexibility and balance for personal and family life. From our recruitment process to our employee performance assessments, to our choice of impact partners we embody our company values and keep them as the driving “north star” in all our business decision-making.

Our Supply Chain:

Product Manufacture:

  1. We work directly with factories who manufacture our products in six locations across two countries, using raw materials from eleven locations across three countries. We view supplier choice as critical in establishing a safe and sustainable supply chain and have strict controls around supplier sourcing, vetting, engagement and supervision.

  2. Our selection criteria for suppliers is based on sustainable practices, organizational ethics, price, quality, capacity, transparency, and raw materials management. Our core suppliers account for 95%+ of our volume and have been working with us for a number of years. Our supplier selection criteria includes Forest Stewardship Council (FSC) certification and our finished products benefit from this chain of custody.

 Tier Definition Example Status
Tier 1 Main Production Sites

Factory that manufactures and packs the end product

Fully Mapped
Tier 2 Materials and Components

Factory that produces the packaging and the jumbo ‘mother’ rolls

Fully Mapped
Tier 4 Raw Materials Processing

Factory that pulps the recycled inputs or bamboo

Partly Mapped
Tier 4 Raw Materials

Recycled Paper: schools & offices Bamboo: forest farms

Partly Mapped

 

Warehousing

1. We use nine 3PL facilities in three countries to receive our goods and conduct processing for delivery to end-consumer:

  • Australia: Melbourne, Sydney, Brisbane, Adelaide, Perth, Hobart.
  • USA: Los Angeles, Lancaster
  • UK: Coventry

    Distribution

    1. We use nine national fulfilment partners across three countries to deliver our products from warehouse to end consume
    • Australia: four national delivery partners
    • USA: three national delivery partners
    • UK: two national delivery partners
    Policies and Contractual Controls
    1. We expect our partners and stakeholders to adhere to ethical business conduct standards which are consistent with our own, and we are committed to working with them to fulfil this common goal.
    2. In 2017, we adopted the ​amfori BSCI Code of Conduct​ and this is the standard for behaviours and values that we have cascaded to our manufacturing partners and use as the benchmark for our social audit program.
    3. In addition to the amfori BSCI Code of Conduct, we have created a suite of policies designed to target the causes and symptoms of modern slavery. These policies will be incorporated into our commercial contracts and used to inform, gain commitment, guide training programs and enhance our audit process.

    Policy guidance includes: 

    • How to recognise the signs of modern slavery
    • How to act upon discovery of modern slavery
    • Remediation for victims of modern slavery
    Policy suite includes:
    • Modern Slavery Policy: Overarching
    • Anti-Bribery and Corruption Policy
    • Migrant, Contract & Temporary Workers Policy
    • Gender Equality In the Supply Chain Policy
    • Forced, Bonded and Child Labour Policy
    • Responsible Purchasing Policy
    Risk Assessment & Due Diligence within our Manufacturing Operations
    1. We have fully mapped our T1 and T2 manufacturing sites ​and have direct relationships incorporating regular visits to all T1 and T2 suppliers.​ We have scheduled completion of mapping for T3 by the end of this calendar year, and T4 by June 2021. We have active improvement plans and Corrective Action Plans (CAPs) in place in all T1 level manufacturing sites with regular progress updates and capacity building where required.
    2. We have an active auditing program in place and have completed audits for 95% of T1 level manufacturing sites with the balance sites scheduled for completion before October 2020. Our audit criteria are informed by ​amfori BSCI Code of Conduct​ and include confidential worker interviews. We understand that women, children and migrants are most at risk of falling victim to modern slavery and our audit criteria highlights these demographics in summary findings. We use this audit data to assess risk and inform the corrective action plans for each site. We are in the process of expanding our auditing program to include T2 level manufacturing sites and have set a target for completion of June 2021.
    3. We review business activities and identify the presence of associated contextual risk factors by maintaining a human rights risk register. This is split into three categories: country and sector context, workforce demographics, and the characteristics of risk management processes or controls. Where multiple modern slavery risk factors are present, we investigate further in order to establish best response. Most recently this risk register has been expanded to include risk associated with COVID 19. We use this risk register to prioritise our activities across regions of manufacture and to augment our audit criteria.
    4. We have long relationships in place with our suppliers and invest heavily in our commercial partnerships. ​This investment takes the form of regular weekly and monthly visits and feedback sessions, full transparency around pricing and supplier cost centres, financial support towards the costs of auditing and training sessions in response to audit findings. Long term relationships help us to work closely with our suppliers to safeguard human rights. ​Over the past two years, it has been necessary to engage additional suppliers in order to meet growth and increased demand. We took great care when expanding our supplier network and developed an extensive vetting process to ensure values alignment, adequate management systems in place, local legal compliance and safe working environments. This process includes business license verification, environmental certificate review, assessment of existing audit criteria and three separate on-site visits before initial orders are placed.
    5. We have a team in China that visits most of our T1 level manufacturing partners on a weekly basis and provides feedback to our core operations. This feedback informs, supports and guides business levels and CAPs at each site with higher levels of business granted to partners demonstrating the strongest commitment to our ethical standards.

    Risk Identification & Management

    Financial Year 2020:

    1. In FY20 we manufactured 100% of our products in China across five finished goods manufacturing sites. We conducted social audits at each site using the framework established by ​amfori BSCI. ​Within these in-depth inspections, we uncovered two critical areas of concern; the following section outlines the actions we have taken to address these concerns and the corresponding outcomes
    2. Non-compliance with our labour standards in the supply chain: Fair Pay - Social Insurances:
    • Audit results and feedback demonstrated that some T1 manufacturing partners were not consistently paying legislated social insurances to workers. We carried out our own research to understand root cause:
    1. Knowledge of the social insurance system is generally low amongst workers, with varying levels of understanding about benefits. Workers were not consistently demanding payment of social insurances alongside salary or​ were actively asking for salary instead of insurance payments, ​so factories viewed consistent payment of social insurances as optional. ​In some of our facilities, workers and their families were from local areas and already covered under agricultural insurance plans, so didn't want to add additional legislated levels of social insurance.
    2. Social insurance costs were not reliably reflected in purchasing prices
    • In response to these factors, we met individually with each factory to discuss and confirm the correct social insurance required for the workforce and we added this as a separate cost centre into our transparent costing matrix. We increased the prices we paid suppliers to incorporate correct social insurance contributions and ensured that this was being paid directly to workers.
    • Non-compliance with our labour standards in the supply chain: Excessive levels of overtime
    • Audit results and feedback demonstrated that levels of overtime were above legislative thresholds at times throughout the manufacturing calendar.
    • In response to these findings, we worked with suppliers to develop stable monthly volume forecasts to minimise ‘peaks and troughs’ and support more consistent and stable labour planning at factory level. This eliminated the need for overtime and enabled our factories to plan more reliably
    • COVID-19 impact on workers: We acknowledged that the spread of COVID-19 represented a risk to our manufacturing partners as well as our own operations. We remained in daily contact with all sites during the early stages of the contagion until workers were able to safely return. Throughout this period, we fully supported workers’ wages by honouring all orders placed with no additional fees or charges for late delivery due to factory closure. Once workers fully returned, we monitored conditions per region and site daily & weekly to ensure the safety and health of the workforce under Stage 3 conditions.
    • Contract harmonisation: later this year we will reissue vendor contracts to include updated policies on modern slavery in addition to our supplier code of conduct. This demonstrates our full expectation that commitment to our values is a baseline prerequisite for doing business with us.
    • Warehousing Staff and Couriers: we are in the process of expanding our due diligence to include warehouse staff and couriers. We have enhanced our commercial contracts to include commitment to our policies on modern slavery and developed a questionnaire that will enable us to assess risk on indirect employment and employment of migrants within our third-party partners’ operations.

    Measuring our Effectiveness:

    1. Stakeholder Engagement:

      • As B Corp members, we undergo an annual assessment of our impact on our workers, customers, community and environment. Our ‘B Impact’ report can be found on bcorportion.net. In accordance with B Corp guidelines, we have also amended our legal governing documents to require our board of directors to balance profit and purpose. This combination of third-party validation, public transparency and legal accountability underpin our ability to drive trust and value for our customers and stakeholders.

      • We are highly involved in the responsible sourcing of the raw materials that go into our products and we work closely with our manufacturing partners to ensure that inputs come from sources that are both safe and sustainable. The majority of our products are manufactured by partners holding FSC certification which incorporates standards considering the social and economic wellbeing of workers and working to ensure that harvesting sites are free from forced or bonded labour.

    2. Ethical Sourcing Audit Program: we measure the total number of factories in our audit program as well as their audit results and successful completion of CAPs. Favourable ethical performance is rewarded with increased levels of business.
    3. We are committed to active and transparent engagement with our suppliers to uphold and drive ethical standards throughout their operations. We understand that building strong and collaborative partnerships is key to delivering responsibly sourced products to our customers. We have ​direct and collaborative relationships incorporating regular visits to all T1 and T2 suppliers.
    4.  Training and Capacity Building: We are in the process of building our training program for ethical trade and modern slavery and will deliver it to relevant internal teams, manufacturing partners, audit partners, and third-party distribution partners later this year. Training will incorporate our policy guidance and expectations so that ethical sourcing risks are understood and acted upon. Training will include correct protocol for discovery of modern slavery as well as guidelines for appropriate remediation for victims of modern slavery.

    Simon Griffiths, ​CEO, September 2020

     

    Toilet paper that builds toilets

    We know you'll love our products, but if for any reason you don't, send them back for a full refund.