Whispering Smith Ltd is a leading fashion group, importer, wholesaler and distributor of innovative fashion for our primary brand Brave Soul. We market and sell clothing, swimwear, lounge wear, footwear, hats and accessories.

We supply many major high street stores and e-tailers and have a global presence with showrooms located in Manchester, London, New York, Dusseldorf, Madrid and Hong Kong among them. Products are designed, sourced, and subsequently distributed globally from warehousing in the North of England.

  1. Purpose

Whispering Smith is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (“human trafficking and slavery”). We strongly believe that we are responsible for promoting ethical and lawful employment practices. These practises are also required to be followed by our (suppliers) worldwide.

  1. Scope

This policy covers all employees of Whispering Smith and all of its suppliers. In the event anything in this policy may conflict with local law, local law will control the interpretation and application of this policy.

  1. Definitions

Human Trafficking: the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or force or any other forms of coercion, of abduction or fraud, or deception, of the abuse of power or of a position of vulnerability or giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation. Forced labour: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.

Harmful Child labour: consist of employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child`s education, or to be harmful to the child`s health, or physical, mental, spiritual, moral, or social development.

  1. Rationale

Whispering Smith will not tolerate the use of unlawful child labour or forced labour in the manufacture of products it sells and does not intend to accept products from suppliers that employ or utilize child labour or forced in any manner. Human trafficking and slavery are crimes under state, federal and international law. These crimes exist in countries throughout the world. This policy is to define how Whispering Smith will make efforts to eradicate human trafficking and slavery from not only within its organization, but also from its supply chains.

  1. Requirements

Whispering Smith expects its suppliers to conduct business with honesty, integrity, and to adhere to the following standards.

5.1 Will not use forced or compulsory labour, i.e., any work or service that a worker preforms involuntarily, under threat of penalty.

5.2 Will ensure that the overall terms of employment are voluntary.

5.3 Will comply with the minimum age requirements prescribed by applicable laws unless a specific contract contains stricter are requirements.

5.4 Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements.

5.5 Will abide by applicable law concerning the maximum hours of daily labour.

5.6 Will provide a safe and healthy working environment, including for any company-provided living quarters.

5.7 Will respect employee’s right to freedom of association, consistent with local laws.

5.8 Will encourage diverse workplace and provide a workplace that is free from discrimination, harassment and or any other form of abuse.



Whispering Smith Ltd recognises that the fashion industry continues to face challenges in maintaining compliance standards and that there is a risk of modern slavery and human trafficking occurring in fashion supply chains. 

We are working to implement systems and controls to safeguard against any form of modern slavery across our supply chain, supported by our Merchandising Team and in-house Sourcing and Compliance team who are responsible for ensuring suppliers are compliant with current laws and regulations.


Our key staff in the UK will under go training via workshops, training will cover our code of conduct requirements and in Modern Slavery.

Communication has been sent to our suppliers to raise awareness of the Modern Slavery Act, this will encourage suppliers to establish their own risk assessment and informs them that we will continue to work with them to ensure they follow our compliance standards



We work to ensure that our supply base in China, Bangladesh, Turkey, India and Pakistan are fully compliant.

We have a demanding set of procedures and policies in place to which our suppliers must adhere. Whispering Smith are SEDEX members and its suppliers are required to undertake a SMETA audit (SEDEX Members Ethical Trade Audit) to assess the quality of their operations. This is supplemented by regular, unannounced and semi announced audits by a 3rd party.

Where the audit process identifies that improvements can be made to the quality of the supplier’s operations the issues, together with the proposed improvements, are recorded in a Corrective Action Plan Report (CAPR). Once the CAPR has been filed, we work with the supplier to provide support to make the required improvements recorded in the CAPR. Before the CAPR can be closed, the supplier is required to submit supporting evidence to the Sourcing and Compliance team. We do work to verify this through unannounced audits. Working with our suppliers to help them address issues within their operations is important to us. With our guidance, our suppliers can implement gradual and sustainable change. This aims to improve operations for the industry as a whole. ­­




  • Improved traceability beyond the first tier of the supply chain and devoted significant internal resource to strengthen our work in this area.
  • Our own supplier auditing system, including unannounced visits, to ensure first and second tier suppliers are following regulations and acting in accordance with our code of conduct.
  • All suppliers are periodically asked to confirm the source of their materials and to verify this.
  • Working with suppliers to ensure minimum wage compliance and transparency, this is an ongoing process.
  • Reducing the number of key suppliers in our supply base to allow greater focus on our key supplier relationships.


At Whispering Smith we remain committed and continue with improvement of standards within our business and supply chain.

We ensure our policies relating to modern slavery reflect challenges within the industry.

We will provide guidance to our staff and suppliers

We recognise that some issues cannot be resolved immediately, but believe that this can be achieved though gradual, sustainable change.

Whispering Smith Modern Slavery Statement was approved on behalf of the Senior Leadership Team on 27.11.20 and signed by Diane Heslop, Financial Director.