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Human Rights Statement

Our Responsibilities 

As a business operating across global supply chains, Mi Hub Ltd are committed to ensuring that the rights of workers are consistently respected. We understand that we have a responsibility to protect human rights and advocate better working practices in our own operations through our supply chains, respecting our colleagues, suppliers and the communities we operate in. We further recognise that responsible purchasing practices and transparency plays a key role in this responsibility, and as such our Human Rights Policy Statement seeks to support our commitment to human rights due diligence (HRDD) through outlining the steps we are taking as a business to address and mitigate our potential human rights impacts.

Our Commitments

Our approach to human rights due diligence is aligned with the UN Guiding Principles on Business and Human Rights and reflects the human rights as defined in the International Bill of Human Rights. We are further aligned to the International Labour Organisation’s Core Conventions and International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work and are guided by the OECD Guidelines for Multinational Enterprises.

As members of the Ethical Trading Initiative (ETI), we also follow the ETI Base Code and require our suppliers to do the same. We follow and adhere to all local laws and regulations, and where these laws and human rights standards may differ, the higher standard is followed.

Mi Hub Ltd is committed to operating a robust HRDD process to avoid potential human rights impacts which are either caused by, contributed to, or linked to our activities. In the case of any impacts which do occur, we are committed to addressing and remediating these. We also recognise that our approach will need to remain adaptable, and as such will be reviewed at least annually.

Our HRDD strategy is fully endorsed by our Chief Executive Officer who receives monthly updates via our ESG team.

Our Colleagues

Mi Hub Ltd maintains several internal policies and procedures which support our commitment to human rights within our own operations. These include our Anti-Corruption Policy, Bullying and Harassment Policy, Child Labour Remediation Policy, Equality, Diversity and Inclusion Policy, Grievance Policy, Whistleblowing Policy and Modern Slavery Policy.

All Right to Work checks are conducted in accordance with the Immigration, Asylum and Nationality Act 2006 and the Immigration Act 1971 to ensure that all employees have the right to work in the UK for the duration of their employment. We also check that our employees are the correct legal minimum age to work in the UK.

We adhere to all minimum wage legislation globally, and within the UK all employees and consultants are paid in accordance with the National Living Wage requirements. We also have a Remuneration Committee that is chaired by our non-executive director.

Our Equality, Diversity and Inclusion Policy ensures that we are creating a culture of inclusion. All decisions about recruitment and selection, promotion or training are made objectively and without discrimination. All complaints of discrimination are dealt with through our Grievance Procedure.

Worker committees are active within all parts of the business. Membership comprises of employee representatives who have been elected by their colleagues. The forums are designed to allow for an employee voice within the organisation to address a variety of issues including working environment, working practice improvements and day-to-day health and safety matters.

Our Approach

Identification and Prioritisation

Our HRDD approach follows the UN Guiding Principles on Business and Human Rights, and as such has been progressively developed from an initial identification of human rights risks within our own operations and supply chains.

It is key to our approach to take time to understand the specific risks to our business and supply chain. In 2023, we identified our preliminary salient issues and in 2024 we have added one further salient issue to those already identified.

The Start of our Journey (2023)

At the beginning of 2023, we began our saliency assessment with an analysis of industry guidance combined with a detailed collection of historic data collated from sources such as questionnaires, third-party audits and targeted projects. To gain an understanding of the current trends within our industry, a customer and industry analysis was conducted using sources such as the Sedex Radar Tool, the Global Slavery Index, ETI reports and the Business & Human Rights Resource Centre. This highlighted where the human rights focus areas were across the textile industry, and where we may need to prioritise our own research and analysis.

After gaining an understanding of the industry and origin specific risks to human rights, a full supply chain analysis was conducted across all origins of our Tier 1 and Tier 2 Goods-for-Resale (GFR). Beginning with the data available to us through Sedex SAQs, SMETA audits and worker voice programmes, risks were assessed and analysed based on stakeholder mapping, and an assessment of whether we have the potential to cause, contribute to, or be linked to specific human rights impacts. Together, these two tasks highlighted who (based on worker type and country of origin) had the highest potential to be impacted by human rights violations both internally and externally, based upon the data and resources available to us at the time.

Following this, the risks were categorised into a matrix for likelihood and severity at a more granular level to allow for prioritisation. This allowed for a more visual overview of our greatest risks to human rights, which we were able to share with senior leadership within the business. Upon review of the matrix and following stakeholder feedback, three salient issues were selected based on both risk and prevalence. Also selected were two unintended consequences which run as concurrent themes with the ability to impact upon the salient issues.


Our initial salient issues and unintended consequences were prioritised as a result of risk and prevalence, but also due to both our potential leverage and our ability to delve deeper into the issues to understand greater specifics.

In 2023 we set our preliminary set of KPIs, which aligns with our reporting goals. This was to begin to further understand the specificity of our salient issues. This decision arose from external stakeholder feedback during our HRDD work in 2023 in defining our salient issues. We have updates on progress against those KPIs and also set our new KPIs that we aim to be working on over the next year in the ‘Our Measures’ section below.

New Salient Risk for 2024

Following our engagement with our customers and factories in Bangladesh as a result of unrest we identified the need for stronger policy. We then joined the working group offered by the Ethical Trading Initiative in 2024. Subsequently, we have added a new salient risk.

When we look at the ETI Base Code in it’s entirety, clause 2, ‘Freedom of Association and the right to collective bargaining are respected’, is the enabling right that supports improved performance in other clauses of the Base Code.

We recognise that within the sourcing countries where our manufacturing partners are, that systemic labour rights challenges exist. Unions can also face significant difficulties to carry out legitimate activity and face frustration in engagement where there are barriers, or a culture of mistrust has been created.

Mi Hub recognises the importance of the right to access Trade Unions or Worker Committees in order to legitimately raise concerns and have their voices heard. We encourage and support an open attitude towards worker representation and see it as essential in effectively progressing with the other ETI 9 Point Base Code Clauses.

Prevention and Mitigation

Mi Hub Ltd are committed to preventing and mitigating any human rights impacts which may be caused by our operations, or which we may contribute to or be linked to. Our prevention and mitigation strategies will undoubtedly vary dependent upon the situation, however our HRDD approach underpins this work.

As a grounding principle to this, we ensure that the ETI Base Code is followed by ourselves and our supply chain. Internally, posters are displayed highlighting this to colleagues, and at supplier level this is included within the Supplier Code of Conduct.

Our supplier monitoring programme consisting of annual SMETA audits for all Category 1 and 2 suppliers, regular communication and review of SAQ responses collectively provides a baseline against which we can measure and monitor progress.

In addition to this, our HRDD approach will utilise this data to regularly trend human rights impacts. Such data will be crucial through 2025 as we develop a more detailed view into the specificity of our salient issues as we make decisions around how best we can work with suppliers to mitigate impacts. This will allow us to plan targeted projects throughout 2025.

Internally, our HR team ensures that the relevant policies and procedures remain up to date to protect our colleagues and provide them with a safe and respectful environment in which to work.

Our final focus area within the HRDD plans for this year relating to prevention and mitigation is centred around ensuring that this work is not completed in isolation. Our human rights work is intrinsically about our people, and therefore it is vital that our people are involved. Through embedding the strategy within that of the wider business ESG strategy, it will become a focus for everyone at Mi Hub and our value chain. We will be looking to our colleagues and supply chain for supporting in reaching our goals, as we appreciate that human rights issues can only be tackled in collaboration.

Remediation

In line with our HRDD approach, Mi Hub Ltd are committed to ensuring that access to remedy is available for human rights impacts. As we advance through our HRDD plans, we will seek solutions to any impacts identified.

Our internal whistleblowing policy is available to all colleagues of Mi Hub Ltd and is communicated to them on the commencement of their employment. Any issues can be reported anonymously through a hotline administered by the independent organisation, The Network. This operates 24 hours a day, seven days a week.

Within our supply chain, our suppliers have access to an email address which is linked directly to the Mi Hub Ltd UK Ethical Compliance team. This is detailed on a poster which suppliers are provided with during onboarding.

In our last Human Rights Due Diligence Statement, we said that we are also aiming to further understand potential opportunities for improvements in access to remedy through our supply chain in terms of freedom of association and collective bargaining.

However, in 2024, we have learned that freedom of association and collective bargaining goes far beyond the reach of discrimination and can positively effect performance in almost all other Base Code clauses. The importance of focus of Base Code clause 2 has increased significantly within our strategy in 2024 and we fully expect this to retain momentum in 2025.

In our previous report, we also aimed to review and assess policies and procedures on this topic, as well as increasing our dissemination of worker voice programmes. In 2024 we have utilised Sedex and the responses given by our Category 1 and 2 suppliers to assess their stance on freedom of association and were pleased to find that all suppliers that were reviewed stated that workers were free to join a Trade Union or form a worker committee. We are also beginning a worker voice program and have already onboarded 5 of our supply partner factories ready for call cycles to begin. Our original target was to work with 3 factories, however, as we see this as vital to our strategy, we have increased participation numbers.

Our Supply Chains

The main supply route for production is from Bangladesh. As a country classed as high-risk, we have a dedicated office based in Dhaka with 25 employees, including a compliance team, who have a constant presence in our supplier factories.

Location of garment manufacturers and fabric suppliers as of November 2024.


Bangladesh and China, make up over half of our Tier 1 supplier sites. This prevalence brings with it an overall heightened risk in the number of workers impacted through these sites, however each of the two origins also bring their own specific risks to workers.

In Bangladesh, the Sedex Radar tool and various third-party reports indicated to us that gender discrimination is a prevailing issue. This is of particular relevance because, in 2024, 61% of all the workers within our supply chains are located within Bangladesh and 56% of those are women. Further, the Global Slavery Index ranked Bangladesh with a prevalence of 7.1 for Modern Slavery, one of the highest risk scores within our sourcing countries. As a result of this, we are placing focus on digging deeper into the root causes of discrimination and Modern Slavery through analysis of management systems and have begun our journey in utilising worker voice programs.

In China, the prevalent risks detected from a combination of the Sedex Radar tool and worker information are Forced Labour and Freedom of Association. Again, the prevalence of this risk is high within our supply chains as it has the potential to impact over 6000 workers. With a similar approach to work on risk mitigation in Bangladesh, in the next year we will be placing focus on understanding the management systems in place. For China though, this will be centred around Freedom of Association. In terms of Forced Labour, we will be utilising the SFA Modern Slavery questionnaire project to understand more detail around the systems that our China-based sites have in place.

In building these foundations over the next year, the aim is that we can place more specific, focused mitigation projects and activities within our supplier sites once we have more knowledge on how and where impact can be best made.

Our Measures

In order to ensure that we remain on track with our HRDD approach, we established specific KPIs in 2023 in relation to this work aimed at providing mitigation. These KPIs have also fed into our wider ESG strategy and updates are fed into the business on a monthly and quarterly basis.

Description

KPI

Updates November 2024

RAG rating of SMETA audit

% of each colour rating

Health and safety NC prevalence

Health and safety NCs as a % of overall NCs

There were 212 Health and Safety related NCs found in 2023 which makes up 56% of all NCs found.

Supplier completion of the SFA SC3 SAQ

% of suppliers sent the SAQ and % of those suppliers who complete it

89% of suppliers completed the SAQ.

Implementation of a worker voice programme

Number of supplier employees who partake in the programme

We have partnered with &Wider on implementing a worker voice program in 5 of our factory partners.

Assess the prevalence of worker committees in our suppliers

% of supplier sites who have an active worker committee and supporting evidence of its effectiveness

100% of suppliers have confirmed via the Sedex SAQ that workers are free to join a Trade Union or Worker Committee.


We have now set new KPIs to keep momentum on the progression of our strategy, building on the work already carried out and advancing our deeper dive into our salient issues as we move to the prevention, mitigation and remediation of human rights impacts.

KPIs for 2024/2025


Our Future Plans

As in 2023, transparency is key to our future plans in HRDD, and key to sharing our vision both up and down the supply chain. We recognise that collaboration is essential to our plans, and so hope that in annually reporting our progress in this area, we will continue to open up the conversation both internally and with suppliers to drive this work forwards and reach the people most at risk. The progress already made will help us gather the data needed to have meaningful conversations with our suppliers about measures that can be taken by us and our supply chain partners that is going to make real and impactful change. We will also look to set a KPI in relation to our newest salient risk and how it can link and affect our other salient risks.