Ethical Trading at Jack

Jack Wills is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas.

This bite-sized e-learning module provides simple-to-digest information so that you can be absolutely sure of our responsibilities and obligations when it comes to complying with the Bribery Act 2010, the Modern Slavery Act 2015 and the Equality Act 2010.

Completing this online learning annually is mandatory.  If you have any questions or concerns, please contact your People team.

Employee Details / Tell us who you are?

Before you start your learning, please provide us with your full name (First Name & Surname)?

First Name:


Which part of the business are you working in / are you joining?

  • Stores (UK & Ireland)
  • Head Office (Victoria Road)
  • DC (Sheffield)
  • International (US & Asia)

If you are joining one of our store teams, please tell us which store (location) are you joining (ie. Chichester, Trafford, Manchester, etc.)?

If you're not part of our Store Teams, please enter N/A

Ethical Trading at Jack: Doing business without slavery

Modern Slavery: The Act and the Facts

According to the International Labor Office (ILO), someone is considered "enslaved" if there is:

Debt bondage that hinders a worker from leaving employment - For example, a worker has to pay a very high recruitment fee for gaining employment and so cannot leave the workplace because of the debt.

Forced work through mental or physical threat - For example, a worker is beaten if they refuse to work or if they refuse to work overtime.

Taking off passports so worker cannot leave - For example if a worker has to give his or her ID card and fears they will not get it back if they leave the employment.

Dehumaisation, treated as a commodity or bought and sold as "property" - For example if a trafficker manages a worker's employment contract without the worker's knowledge.  The worker's employer or job may change without his or her knowledge or consent.

The UK government has enacted a new statute called the UK Modern Slavery Act 2015, which aims to tackle forced labour (modern slavery) within the UK and within global supply chains.  Under this piece of legislation, UK companies are required to annually report on how to ensure there is no forced labour or human trafficking in their supply chain or business operations.

Top facts on modern slavery

  • An estimated 36-45m people are slaves today.
  • This is more than during the Transatlantic Slave Trade from 15-19 centuries.
  • The footwear and apparel industry is the 5th highest risk industry of modern slavery.
  • Modern slaves are often migrant workers.
  • It happens everywhere, including the UK.

The main risk areas for a modern supply chain

First-tier factories, where products are assembled and labels sown on.  These have been visited by international brands and audited by independent auditors for many years.  However, this does not mean there is no risk in these factories.

Lower-tier factories are any units processing any part of the material which goes in to your product (mills, washing, dyeing, weaving, sizing, prawning, bleaching, embroidering, packaging, etc.)  These are often not audited and are often not visited by international brands or even suppliers.  They are often informal, hidden and prone to labour exploitation.  This is where the highest risks are.

Guess the facts... Drag your guess to the question.

  • What proportion of businesses do you think believe there to be a risk of slavery somewhere in their supply chain?
  • According to the Home Office, roughly how many people do you think are suspected to be trafficked every year?
  • How many people do you think the government suspects to be living in slavery in the UK?
  • How many people do you believe are estimated to be in forced labour situations globally?
    21 million

Modern Slavery:  What is our part in preventing it?

The following tables shows how an employer's actions can lead to modern slavery.

At recruitment stage During employment When/after leaving
  • The worker is charged illegal or excessive recruitment fees (joining payments)
  • The worker is uninformed or misinformed about terms of employment
  • The worker is not provided with an understandable, legally compliant written contract
  • The worker is fraudulently charged fees for travel, health checks or work documentation
  • The worker's safety or the safety of the worker's family is threatened if he/she doesn't take the job
  • The worker's documents (e.g. IDs) are falsified
  • A migrant worker is not provided with the same employment protections  as nationals
  • There are excessive or illegal wage deductions
  • There is a requirement to stay in company or broker controlled housing
  • The workers is unable to enter or leave the premises freely
  • There is forced overtime
  • Identity documents are confiscated or withheld
  • Wage deductions are used as a disciplinary measure
  • There is physical abuse or humiliating discipline and termination practices
  •  The worker’s work visa and work permit is tied to the employer
  • There are monetary penalties or withholding of wages for early contract termination
  • The worker is forced to pay for return travel to their home
  • Undocumented migrants are threatened that the authorities will be notified if they leave the employment
  • The worker is forced to pay financial deposits called  “security fees” as “runaway insurance”
  • The worker’s safety or the safety of the worker’s family is threatened if the worker leaves the job

How to avoid it:  


  • Hire local workers directly or through an approved source (check with the People team)
  • If migrant workers are needed, select a trustworthy agency
  • Check quality of ID and proof of right to work in the country of residence
  • Take copies of ID documentation e.g. passports - not originals
  • Pay the recruitment fees and associated costs
  • Investigate whether your workers ever paid any fees (such as recruitment fees or medical fees) before starting employment
  • Create a policy which prohibits any fees paid by workers before commencing employment with you.


  • Contract with people directly and not through third parties, unless approved
  • Ensure contract terms are legal
  • Ensure workers understand all the contract terms
  • Provide a copy of the contract terms to your people
  • Never change any contract terms without consent from the worker.


  • Have effective grievance procedures in place so workers can make their opinion heard
  • Track overtime approvals.


  • Ensure workers may leave the factory at any time
  • If workers stay in company owned accommodation, ensure they can come and go as they please.

As a business, next year we will be required by law to publish a statement about our own practices.  This is something we are taking very seriously and are working on with a number of key advisors.  We will publish this on our website in 2017.

Quick check:  What is one simple way we can play our part in preventing slavery?

  • Not trusting recruitment agencies
  • Check quality of ID and proof of right to work in the country of residence

Ethical Trading at Jack: A diverse and equal team

What is equality and diversity?

Diversity is about embracing individual differences.  For example:

  • Race
  • Religion/philosophical belief
  • Gender
  • Sexual Orientation
  • Age
  • Values
  • Family planning and marital status
  • Physical or mental ability


At Jack we value individuality.  This is what makes us and our culture so great.  Jack is a contemporary business with an amazing brand, all because of the diversity of the people who work here.


Equality is about making Jack a fair workplace regardless of individual differences; everyone has an equal opportunity to succeed at Jack.  We have and apply our equal opportunities policy in the way we recruit and manage our people.

What are our legal obligations?

Companies in the UK are required to follow a set of principles to ensure discrimination and harassment/bullying are eradicated, and expectations of equality are met in the workplace.

These laws ensure that the best individuals from the widest possible pool of potential employees are chosen.  Under these laws, there are nine "protected characteristics":

  • Age
  • Sex
  • Race
  • Sexual Orientation
  • Religion or Belief
  • Gender Reassignment
  • Marriage and civil partnership
  • Pregnancy and maternity
  • Disability.


The purpose of the Act is to make it more difficult for employers and other organisations to discriminate on a number of different grounds.

Our aim is to advance equality of opportunity, and foster great relationships in our team.

Which of the following are considered "protected characteristics"?

  • Age
  • Sex
  • Race
  • Being Single
  • Marriage and civil partnership

How does the law prevent inequality?

Through anti-Discrimination laws

Discrimination is prejudices put into action, where because of our prejudice or bias someone is treated less favourably.  For example, if Billy identifies more as Bella, and tells us of their intentions for gender reassignment.  Their line manager feels uncomfortable with this and unconsciously starts to treat them differently.  The law would suggest that the line manager is discriminating against Bella.

It's a little more complex in legal terms, though.

Direct Discrimination - This is obvious or blatant discrimination that stares you in the face, like above.

Indirect Discrimination - This is a lot less obvious and can easily be unintentional.  And it can actually sometimes be justified depending on the circumstances.  This is when we there is a "custom, criterion or practice" employed that inadvertently disadvantages people with one or more protected characteristics.  

Example:  Pritee is 4'11" but the minimum height requirements for her job state that candidates should be no shorter than 5'8".    This would put people of certain racial backgrounds at a distinct disadvantage because they are characteristically shorter.  If there was a health and safety reason then this may well have been justified.  But if it was a sales assistant role, it would be difficult to justify this discrimination.

Positive Discrimination - This is when you favour one group over another group.  For example, hiring a new person from a minority group because they are from a minority group.

Through anti-Harassment laws

Harassment is unwanted conduct or attention.  The unwanted conduct could have anything to do with any of the protected characteristics mentioned before.  It can happen once or all the time.  Harassment can start with "banter" as harassment is in the eye of the victim, not the perpetrator.  An example might be if Tobias, a Sales Assistant, has a learning disability and another employee (Marcus) refers to him as a "retard" it might be considered by Tobias as Harassment.

Which of the following would be considered indirect discrimination?

  • Stating that a requirement of a model role is that applicants are female.
  • Promoting an individual based on their gender.

Ethical Trading at Jack: Doing business without bribery

Bribery Act made simple... An overview


Bribery is defined as giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.

Simply put, it would be making a payment to someone in customs to get our products past them quicker.


Generally speaking, taking clients out - for example to a big rugby game at Twickers - to present products or build relationships, is fine.  It is, after all, an established way of doing business.  But we also have to be mindful that hospitality and promotional, or other expenditure like it, can be used as bribes.  So it's usually best to check with your manager or someone in the People team before you RSVP an invitation somewhere!


Yes, but as we are a UK company we will still be in trouble if we go along with these practices anywhere else in the world.


For individuals, up to 10 years in prison and an unlimited fine.  Companies face unlimited fines.


We will reduce or remove any liability as long as we have tried our very best to prevent bribery (by implementing this learning to make sure everyone understands it, for example.)

But we also need strong systems and practices in place, discouraging behaviour that might be construed as bribery.  At Jack, these include providing anti-bribery training, carrying out risk assessments for certain markets, and checking some peoples' and suppliers' backgrounds.


As with everything, it isn't always straightforward.  The use of contractor and subcontracts is cloudy; the Ministry of Justice have guidance that says we only have to perform due diligence on those who actually supply goods or services to us - but what if there are implications between them and another client of theirs?  We need to be mindful and diligent, is the message.  Another point for debate at the moment is the question of liability between a parent company and a subsidiary, or even a partner - Alshaya, for example - if a bribe has been paid by a subsidiary or partner, and the benefit is solely to that party, then we are not necessarily liable - but we can't always be sure.  Whilst this is yet to be worked out, we will do everything we can to avoid such situations.

So what does it really mean, and what happens if we do it?

It really comes down to the following:

  • Bribing another person - you offer a potential supplier tickets to a major sporting event but only if they agree to reduce their costs.
  • Being bribed - a supplier gives your sister money towards a mortgage or rent, and expects you to use your influence in our business to ensure we continue to do business with them.
  • Bribing of foreign officials - you arrange for the business to pay an additional payment to a foreign official to speed up an administrative process (such as clearing our goods through customs.)
  • Failure to prevent bribery - you not completing your e-learning, us not chasing you to complete it, those in supplier management roles not making sure the suppliers are not bribing them.

Liabilities and Penalties

The penalties apply to UK companies, partnerships and individuals. Non-UK citizens and residents can also be prosecuted if they undertake business in the UK. Failure to comply with the Bribery Act could result in an unlimited fine for individuals and companies, and up to 10 years’ imprisonment for individuals.

And what happens if we break the law, intentionally or otherwise?

  • An unlimited fine for individuals and companies, and up to 10 years’ imprisonment for individuals.
  • An unlimited fine.
  • 10 years' imprisonment.

What does this mean for me?  E.g. what do I need to do?

So that we are able to protect each other and Jack Wills, we ask that all Jack Wills people take particular care in making sure that we keep careful records of all company records of contracts or business activities, financial invoices and payment transactions with clients/suppliers/public officials.  

Before entering any contract, arrangement or relationship with a potential supplier, our Legal Advisor or any other person our Finance team might suggest should at the very least review it with you.


Any payment you decide or you are asked to make on behalf of Jack Wills should be approved by your immediate leader and the budget holder.  In most cases, payments will need to be approved by Finance.

We permit corporate entertainment, gifts, hospitality and promotional expenditure that is undertaken:

  • For the purpose of building good business relationships;
  • To improve the image and reputation of Jack Wills; or,
  • To present our products effectively.

The entertainment/gift/hospitality/promotional expenditure must be arranged in good faith, and not be offered, promised or accepted to secure an advantage for Jack Wills or any of its employees/associated persons or to influence the impartiality of the recipient.  We will authorise only reasonable, appropriate promotional expenditure.

Before entering any contract, arrangement or relationship with a potential supplier, what do you need to do?

  • Ask our Legal Advisor(s) or any other person our Finance team might suggest to review it with you, and seek approval from your immediate leader and budget holder.
  • Ask Finance and our Legal Advisor(s) to review it with you before you agree to anything, and seek approval from your OpsBoard leader.
  • Ask your immediate leader and budget holder permission, and ask Finance for the money before signing anything.

Is there a procedure I should follow?

We need you to keep accurate, detailed and up-to-date records of all corporate hospitality, entertainment or gifts accepted and offered.  To do this, you can complete the simple Gifts and Hospitality Declaration Form which is available on the shared drive in Everyone > Templates > HR > Forms > Gifts and Hospitality Declaration.

We won't unreasonably refuse to approve business entertainment, but we generally suggest that entertainment is only provided if it demonstrates a clear business objective and is appropriate for the nature of our business relationship.  We will not approve business entertainment if we consider it to present a potential conflict of interest or where it might be perceived that undue influence or a particular business benefit is being sought.  

If we approve, you will need to make sure that you act and spend in accordance with our Expenses Policy.

We also ask that gifts, rewards or entertainment received or offered are reported immediately to a senior member of your team, who may deem it necessary to assess any risks with our Asset Management or People teams.  (But as a general rule, you can keep small tokens of appreciation such as flowers or a bottle of wine.)

If we approve corporate entertainment, what should you act in accordance with?

  • People Guide.
  • Expenses policy.
  • Doing Business without Bribery policy.
  • Bribery & Anti-corruption policy.

Reporting Suspected Bribery

Please report any concerns that you may have to our Finance Director and People Director.  Issues that you need report would be:

  • Any suspected or actual attempts at bribery;
  • Concerns that other employees or friends of Jack Wills may be being bribed;
  • Concerns that other employees or friends of Jack Wills may be bribing third parties, such as clients or government officials.

Reports will be thoroughly and promptly investigated in the strictest confidence.  To report any concerns, please contact your Finance or People teams.  Action by the company against any wrongdoing may include disciplinary action; but don't worry, if you are reporting in good faith you will have Jack Wills' full support.

Who should you report concerns to?

  • CEO.
  • Finance Director.
  • Chief Finance Officer.
  • People Director and Chief Finance Officer.
  • People Director and Finance Director.

What do you need to complete with your expenses when you are paying for gifts or corporate hospitality? (Blank responses are case-sensitive!)

 and  Declaration Form

Course Complete!

Congratulations.  You have successfully completed the relevant learning about our approach to ethical trading at Jack Wills.  If you have any questions or concerns, please contact the People Experience team in person or by emailing

Thank you.