MODERN SLAVERY STATEMENT
For Fiscal Year 2019
As the UK’s leading furniture rental provider, RoomService by CORT is committed to continually improving our practices to ensure there is no slavery or human trafficking in our supply chain or in any part of our business. RoomService and its parent company, CORT Business Services, takes its obligations under the UK Modern Slavery Act 2015 very seriously and will set out to put in place a robust working practice in order to comply with such obligations. This policy document sets out those practices and gives insight into the supply chain and business processes of CORT Business Services (CORT), and all its subsidiaries and divisions, including RoomService by CORT.
CORT Business Services’ network of vendors and supply chains are worldwide and complex. Since CORT does not manufacture its own goods, we consider the greatest risk of modern slavery and human trafficking can exist in our supply chain. CORT remains committed to eradicating slavery and human trafficking through a combination of risk assessments, collaborative programs, policies, and procedures that will help identify, mitigate, and manage the risk.
CORT VENDOR CODE OF CONDUCT
CORT’s Vendor Code of Conduct is the cornerstone of our approach to a responsible supply chain, outlining our legal, humane, and ethical standards of production. Any form of forced labor, including but not limited to indentured and bonded labor, involuntary overtime, and prison is a zero tolerance violation to our Code of Conduct. The Code of Conduct details CORT’s expectations that its partners and vendors will comply with both the UK Modern Slavery Act and the California Transparency in Supply Chains Act reporting requirements. CORT also expects our partners and vendors to respect and uphold the principles of our Vendor Code of Conduct with their own supply chains. In the event of suspected or known non-compliance, the Code provides CORT with the ability to take remedial actions, up to and including termination of the relationship with that partner or vendor.
Supplier compliance to CORT’s Vendor Code of Conduct will be monitored in different ways, predominantly through a “Supplier Appraisal Questionnaire” which will be issued to new suppliers upon on-boarding. Additionally, CORT Business Services will implement plans in the coming fiscal year to conduct Vendor Code of Conduct assessments of existing and new suppliers on a regular basis. The frequency of subsequent assessments will depend on if the supplier operates in a high-risk context. In addition, we will assess subcontractors that trigger specific risk categories, including the presence of foreign migrant workers. Future statements will specify whether the assessments are conducted by trained CORT employees, or from an outsourced social responsibility firm partner.
CORT is not engaged in conducting remote audits to ensure suppliers comply to our Vendor Code of Conduct requirements for trafficking and slavery in supply chains. Should a concern arise, CORT will use other methods at our disposal, not limited to unannounced and independent visits, to validate compliance with the Vendor Code of Conduct. Future statements will provide details to any changes on such assessments.
As part of the formalization in our on-boarding process with suppliers, we will require our approved vendors to certify in writing that materials incorporated into the products in which we rent or sell will comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. Our Vendor Code of Conduct requires all vendors, pursuant to its purchase order terms, to warrant, represent, and agree that all merchandise shipped to CORT Business Services and any of its subsidiaries is manufactured and produced in full compliance with any applicable current, or later adopted, laws of the country of manufacturer governing the use of child labor, illegal forced labor, illegal prison labor or similar illegal working conditions, as well as any other applicable human rights statues, regulations and laws. In cases where there is a difference between the requirements of local law, international law, and our Vendor Code of Conduct, the more stringent standards apply.
CORT Business Services and its subsidiaries maintain internal accountability policies and procedures for employees and contractors failing to meet the Company’s standards regarding slavery and human trafficking for imported products. While we would always seek to work with our suppliers to address and remediate any concerns about their ethical practices, ultimately, if we are unable to satisfy ourselves that any supplier will be able to comply with the ethical standards set out in CORT’s Vendor Code of Conduct, we have the option to terminate the business relationship.
We are committed to creating a working environment that is inclusive and supportive, based on mutual respect and trust, and where everyone is of value. CORT Business Services has a number of internal policies and procedures in place, including an Ethics Hotline; all of which showcase our commitment to uphold exemplary ethical standards and demonstrate our ambition for our employees to enjoy equal opportunity in an environment that is free from discrimination, harassment, and victimization.
We ensure that we have the requisite competencies within our organization, attained through training relating to human rights and experience. We will work to protect the integrity of our supply chain by regularly engaging and educating our suppliers, assessors and internal teams on supply chain issues, including those related to modern slavery, human trafficking and forced labor. We will do this by:
- conducting formal training on our Vendor Code of Conduct program for our employees, and providing specialized training to senior management in our supply chain and merchandising departments.
- providing new vendors with an education of CORT’s business standards and the Vendor Code of Conduct for all finished-goods and raw materials suppliers.
This statement has been approved by the Directors of Roomservice by CORT and signed on their behalf.