MATERIALITY AND DIMENSIONS OF RESPONSIBILITY
In determining the content for the separate non-financial report, the TOM TAILOR GROUP identified and compiled the material issues required for understanding the course of business, the Company’s business performance and situation of the Company as well as for understanding the effects on the non-financial aspects of the Company’s activities. Based on this, and taking into account the business model and their relevance to the management of the day-to-day operations of a medium-sized textile company, the following focus areas of the sustainability dimensions for the TOM TAILOR GROUP have been determined:
ETHICAL RESPONSIBILITY AND COMPLIANCE
Compliance with applicable laws and impeccably ethical behaviour by all employees are important to the TOM TAILOR GROUP in order to maintain confidence in the Company by customers, business partners, capital market participants and other stakeholders, prevent reputational damage and financial loss and contribute to the safety of the Company and its employees. For this reason, the TOM TAILOR GROUP is in the process of setting up a compliance management system. This compliance management system is intended to ensure adherence to locally applicable laws, internal regulations, ethical principles and voluntary obligations. The TOM TAILOR GROUP’s Management Board considers compliance to be one of its principal responsibilities. A compliance officer reporting directly to the CFO of the TOM TAILOR GROUP, who is responsible for compliance at the Company, supports the Management Board in setting up an efficient compliance management system and continually improving that system.
The compliance management system involves analysing the compliance risks facing the TOM TAILOR GROUP and taking measures to reduce these risks, such as risks relating to cartel law or corruption. This is accomplished by means including employee training based on the training needs of individual employees. Currently, compliance training is being developed and will be carried out through an e-learning programme in 2018. The e-learning programme will initially be offered to employees in the German companies and subsequently rolled out throughout the Group. Moreover, a training programme on antitrust law was held in December 2017 for employees in Germany who deal with aspects of this issue. The Company is also are working on efficient and centralized policy management and internal guidelines, for example regarding the signing of contracts. The goal is to provide employees a framework in addition to existing laws that defines the conduct expected and required from them. A Code of Conduct that communicates the Company’s values to employees, such as transparency, integrity and respect, is currently being written.
Supervisors, the Management Board, individual departments and the Compliance unit promote awareness of the statutory and ethical responsibilities of each and every TOM TAILOR GROUP employee.
This effort is undertaken in the Company’s day-to-day business and by way of specific communication measures such as interviews with the Compliance Officer on the intranet in which compliance-related questions are asked. Communication initiatives such as these make employees aware of the importance of conduct in conformity with rules and regulations on an ongoing basis. They will be conducted regularly and the programme expanded.
Consideration of current court rulings and an interdepartmental exchange of information on relevant topics ensure that necessary adjustments to the system can be made in a timely manner and employees are informed about changes in requirements. This approach aims to eliminate the possibility of illegal employee conduct from the start and to make staff aware of the extent to which the conduct expected from them is subject to change.
If employees are unsure or have questions about legal requirements, internal company rules or the ethical behaviour expected of them, the Compliance unit along with their department, the legal department and the data protection officer are available to answer these questions.
Systematically implementing TOM TAILOR’s corporate values and the legal requirements at all management levels, especially the Management Board, ensures that employees accept the Company’s values. Furthermore, this highlights the importance of compliance vis-à-vis the employees. Activities in this context in the 2017 financial year included the Management Board writing a foreword for a compliance article on the intranet or the Chief Executive Officer drawing employees’ attention to an article on compliance on the intranet in a video message.
Supervisors are primarily responsible for monitoring actual employee compliance with legal and internal Company requirements; Compliance also conducts spot checks. The Internal Audit unit is also involved in certain controls. This approach allows for review and optimisation of individual cases as well as of the underlying processes, which are monitored across departments under certain circumstances. Controls such as this may – but are not required to – be carried out based on a specific incident.
Violations of statutory provisions and corporate values may also be reported by employees themselves to various departments, particularly Compliance. TOM TAILOR is currently setting up a more extensive whistleblower system.
The Company has a zero-tolerance policy for misconduct by employees in legal and ethical matters. The term “zero tolerance” at TOM TAILOR GROUP means that action is consistently taken and appropriate sanctions imposed against any behaviour that violates laws or corporate values, including but not exclusively related to disregard for human rights or cases of corruption. Appropriate sanction must take into account the seriousness of the violation and the local legal situation in each individual case. The range of possible sanctions extends from a warning to termination without notice and/or criminal charges. Claims for damages may also be asserted. Sanctions have already been implemented in 2017.
Compliance violations are investigated fairly and transparently, and appropriate sanctions are imposed. Any subsequent modification of the compliance management system ensures that any gaps in the compliance management system used in such cases are closed.
In 2017 no incidents of corruption or bribery involving TOM TAILOR GROUP employees were identified by the Compliance Officer or the Internal Auditor up to the time of preparation of this report.
RESPONSIBILITY TO EMPLOYEES
Human Resources Strategy and Organisation
Employees are a company’s most important resource and are therefore the key to the success of any enterprise. One of the main tasks of human resources work in the TOM TAILOR GROUP is therefore to attract good people, systematically develop them and ensure that they remain with the Company for the long term.
In organisational terms, the personnel department manages and supervises the Group’s human resources activities. Personnel management in operations in the business units and departments is the responsibility of each supervisor. They work with the personnel department to define target agreements, promotion opportunities and areas of activity for employees and support implementation. In 2017, a performance management tool was developed and introduced for systematically, transparently and efficiently conducting annual discussions and target agreements between employees and managers. The human resources department also advises and supports managers during strategic change processes to protect employee interests and best deploy staff according to their strengths.
The workforce was distributed as follows as at 31 December 2017:
Number of employees on 31 December
Core markets outside Germany
Of the total of 6,071 employees, 3,022 worked at TOM TAILOR and 3,049 at BONITA. TOM TAILOR Holding SE also had three Management Board members at the end of 2017 (2016: three Management Board members and three employees).
The TOM TAILOR GROUP considers it very important to substantively include all employees in the decision-making process at the Company and to ensure active representation of their interests. TOM TAILOR and BONITA each have their own works councils. TOM TAILOR’s Works Council consists of 11 members, nine of whom are women. BONITA’s Works Council has nine members, of whom four are women. A further works council at BONITA Retail has 11 members, all of whom are women. In addition TOM TAILOR Holding SE also has a works council with a total of 16 members from 12 different countries. That committee has 11 women.
Thanks to flat hierarchies and an open, collaborative corporate culture, younger employees can take positions of responsibility early on and develop their own ideas. Direct communication with executives ensures short communication chains and quick decisions. During the reorganisation of TOM TAILOR Holding AG as a Societas Europaea (SE) in 2017, the Supervisory Board was composed of equal numbers of representatives on the investor and employee sides. This significantly expanded the opportunity for codetermination by employees in the reporting period.
Training and Continuing Education
The TOM TAILOR GROUP strongly emphasises focused training and promotion of emerging talent in order to proactively address the shortage of skilled professionals. In conjunction with the Management Board, the requirement for emerging talent is determined based on specified criteria one year before vocational training begins. The Company’s training plan ranges from conventional professional training options for the head office and the selling spaces alike through internships to trainee programmes for university graduates. These programmes are continually updated. When applying for a vocational training spot, potential new trainees must participate in an assessment centre. During training, all vocational trainees work in various areas of the relevant business in accordance with a schedule set up by the HR department along with executives. In the 2017 reporting period, 29 vocational trainees in five categories of professions such as industry, retail, computer science and warehouse logistics worked at the TOM TAILOR GROUP. Out of the vocational trainees who finished their training in 2017, 70% were hired on permanently. In addition, 12 interns were able to gain extensive experience in various departments throughout the Company.
In a constantly changing work environment, it is essential that employees continue their professional development. In order for the TOM TAILOR GROUP to continue preserving its innovative capability, remain attractive for new employees and retain employees for the long term, the Company has created a wide range of continuing education options for its employees. This programme is revised on an ongoing basis and adapted to meet new requirements. In annual performance reviews, the Company determines employees’ training requirements and wishes. The options include both professional classes (e.g. textile training) and skills-based development opportunities, such as intercultural competency and soft skills. Moreover, the Company regularly invites external speakers on topics such as motivation and leadership. The TOM TAILOR GROUP’s internal Retail Academy also enhances the skills of its workforce, including executives. This programme consists of four modules, including sales, visual merchandise and management training as well as resource-oriented HR development.
In 2017, a total of 30 trainings were held across Germany attended by around 220 participants. The Retail Academy trained 23 employees from across the Company. The “Leadership Lab” (participants in 2017: 35; in 2016: 34) is aimed at executives in particular and is a multi-module executive development programme for both new and experienced managers. Internal Company events for the entire staff are also regularly held on a variety of topics. A particularly popular format is the lunchtime "brown bag" sessions at which employees in key positions or people responsible for new functions introduce themselves to the staff. Eight of these sessions were held in the reporting period (2016: nine).
The health and satisfaction of employees is important to the TOM TAILOR GROUP. These factors help retain staff for the long term and create an attractive work environment for potential new employees. Twice a year, the TOM TAILOR GROUP’s personnel management team reviews and adds to the variety of health-promoting measures the Company offers and puts into place attractive conditions for balancing work and family life.
This is why the Group launched its “TOM TAILOR goes balance” initiative providing external counselling to employees and also offering a large number of seminars on topics such as stress prevention, health in the workplace and coping with change. Moreover, the TOM TAILOR GROUP provides financial support to employees for exercise programs such as yoga classes and fitness studio memberships.
Since 2012, employees have also been able to contact an external coaching institute for free, anonymous advice and support on questions or problems related to their job, private lives or families. By introducing this service, the Company supports its employees in overcoming challenging and stressful life situations and so help maintain their health over the long term. With 120 participations in 2017 (2016: 135), this offer again was very popular.
An attractive and flexible working environment is an important factor for successfully attracting and retaining of skilled staff. A good balance between work and family life is a major concern for most of the Group’s employees. The TOM TAILOR GROUP’s flexitime, part-time and home office options enable employees to be flexible and customise their work to suit themselves to a large degree. A total of 64% of the TOM TAILOR GROUP’s staff worked part time in 2017 (2016: 65%). At TOM TAILOR this figure was 37% (2016: 35%) and at BONITA 91% (2016: 91%). The "TOM TAILOR goes Family” initiative enables employees to make use of a wide range of free services, including finding emergency childcare and providing counselling through PME Familienservice.
RESPONSIBLE ACTION IN THE SUPPLY CHAIN
Organisation and Concept
The TOM TAILOR GROUP’s collections are mainly manufactured in Asia, where the majority of global textile production takes place. The diversified supplier structures in the textile industry require great commitment in order to guarantee decent, safe and fair working conditions at the Asian suppliers. The Company has implemented a system for minimising supply chain risks. This concept rests on supplier certification, the stipulation of standards as well as controls and support for local partners. The Group’s Procurement unit is responsible for implementing this concept and controlling its implementation.
The Company has maintained purchasing offices in Asia’s most important procurement markets since 2011 via the joint venture TOM TAILOR Sourcing Ltd. to ensure direct contact with its suppliers, regularly monitor these itself based on internally defined schedules and assist them. Bangladesh is the Company’s most important procurement market. In 2014, the TOM TAILOR GROUP opened its own purchasing office in Bangladesh to better control and safeguard local standards. The purchasing office in Dhaka has around 100 employees working for the TOM TAILOR GROUP, most of whom visit the factories on a daily basis.
In terms of supply chain and suppliers, the TOM TAILOR GROUP’s high external and internal standards, such as amfori BSCI, REACH and mandatory requirements for business partners as well as the strict controls applied ensure that risks are minimised locally. The Company’s orders support capacity utilisation at suppliers and create jobs. As a result, the local community receives taxes and contributions.
Principles, Standards and Control
With regard to its production process, the TOM TAILOR GROUP voluntarily adheres to the principles of the amfori BSCI, which includes all key standards of the International Labour Organisation (ILO) for the protection of employee rights, the UN Global Compact and the UN Declaration of Human Rights. Further elements are the OECD Guidelines for Multinational Enterprises and other internationally recognised treaties. These include a ban on child labour, safe and decent working conditions, fair pay, regulated working times, adherence to local laws, no discrimination and workers’ freedom of association to form unions and freely negotiate rates.
Before the TOM TAILOR GROUP starts working with a new supplier, auditors from the purchasing company TOM TAILOR Sourcing perform in-depth checks of this supplier (Initial Factory Assessment). These inspections are based on the amfori BSCI standards and standards defined by the Company. If the inspection is successful, the TOM TAILOR GROUP enters into an agreement with the supplier concerned in which the supplier undertakes to adhere to the purchasing guidelines of the TOM TAILOR GROUP. These include restrictions or complete bans on the use of animal hair, certain types of down and feathers, real fur, leather and skins, shells, silk from India, cotton from Uzbekistan, mulesing of sheep and the application of sandblasting in the production process.
Depending on the result of the amfori BSCI audit, employees from the TOM TAILOR purchasing offices and agencies accredited by the amfori BSCI will perform regular announced and unannounced supplier audits and checks over the course of the cooperation. If any deviations from the specified standards arise, the supplier will be sanctioned or the employees of the TOM TAILOR purchasing company will draft suitable measures and development plans with the supplier so that the standards are continually improved and complied with again. There were 91 BSCI full audits and 71 BSCI follow-up audits in financial year 2017. In the production markets, 88 regular audits (2016: 116) and 65 unannounced audits (2016: 40) were carried out. All suppliers essentially met the requirements of the TOM TAILOR GROUP.
In India, the TOM TAILOR GROUP has been a member of the Tamil Nadu Multi-Stakeholder Group (TNMS Group) since 2012, an association combining individual BSCI members and the Ethical Trading Initiative (ETI). The group is taking a determined stand against Sumangali in southern India. Sumangali is a widespread form of employment in this region, in which young women undertake to work in factories for several years but do not receive the majority of their wages until the end of their multi-year employment. The idea is that the girls save for a dowry, which is a prerequisite for getting married. This widespread practice frequently results in a number of types of forced labour of young women. The TNMS Group is conducting systematic educational campaigns on the ground, including training suppliers, holding discussions with local legislators, NGOs and associations or setting up local community and training centres.
Commitment to Fur-Free Collections/Animal Welfare
The TOM TAILOR GROUP is committed to fur-free collections. This is why the Company has been a member of the FUR FREE RETAILER PROGRAMME (FFRP) since 1 December 2015. The FFRP is an international initiative of leading animal and environmental protection organisations. The programme designates retailers, labels and designers who have made a written commitment not to use fur in their product ranges and helps consumers to find guaranteed fur-free fashion. The programme’s German representative is the animal welfare organisation VIER PFOTEN – Stiftung für Tierschutz. When developing new products, the TOM TAILOR GROUP prohibits the use of fur materials. In the reporting period, the TOM TAILOR GROUP was therefore able to ensure that no fur was used in its products.
Environmental Issues in the Supply Chain
Environmental protection and good stewardship of resources are important issues for the TOM TAILOR GROUP. As a textile and apparel company, the Company focuses its environmental activities on its products and the supply chain, because this is where significant risks arise. At the same time, the TOM TAILOR GROUP can exert a positive influence. Key factors here are the use of chemicals by our suppliers in providing services and manufacturing products, the use of sustainable materials, the durability of our products and compliance with local laws.
Strict Thresholds for the Use of Chemicals
As early as 2015, the TOM TAILOR GROUP launched its own DETOX initiative to eliminate chemicals that are harmful to the environment from production and gradually replace them with more ecologically sustainable alternatives. This is an issue that is relevant to the entire textile industry. Over the years, the TOM TAILOR GROUP has developed and introduced various guidelines of its own for the use of chemicals by suppliers. The rules for the use for certain substances in end products were tightened by the TOM TAILOR GROUP. In some cases, the permitted thresholds are even lower than those permitted by strict European statutory requirements. Moreover, the Company analyses numerous random samples both in its own and in third-party laboratories to ensure compliance with these regulations. In 2017, 30% of orders were spot checked for compliance across all supplier companies. In addition, suppliers are prohibited from using PFCs (perfluorinated compounds) and APEOs (alkylphenol ethoxylates)/NPEOs (nonylphenol ethoxylates). Compliance is ensured by spot checking.
In the interest of furthering the goal of chemicals management, the TOM TAILOR GROUP plans to take other steps in 2018 such as the introduction of a chemical handbook and arranging supplier training in chemicals management with an internationally known laboratory.