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UK Modern Slavery Statement

UK Modern Slavery Act 2015 Statement 2020/2021

Founded in 2005, twelveNYC has become the trusted partner of choice for leading global brands through an integrated white glove approach. twelveNYC designs products and services to enable brands to tell their story and grow customer engagement.

The mission is to be the most trusted creative partner for both leading and emerging companies by helping them tell their stories through twelveNYC’s end-to-end solutions. The principles of constant innovation, long-term partnerships, and a broad set of capabilities are at the core of the business.

Established in Brooklyn, which serves as the company headquarters, the business has expanded over 15 years with offices now in London, Hong Kong and Paris.

twelveNYC is proudly 100% women owned and led by a dynamic global female leadership team with a 94% female make up across the globe. Current number of global employees totals 91.

This statement regarding the UK Modern Slavery Act 2015 covers the reporting period of September 2020 - September 2021.

Business Structure, Activities and Supply Chain

Products and services provided by twelveNYC are designed in house and manufactured by third party factories which are managed by our suppliers. We deliver a diverse range of products including apparel, accessories and household items to some of the biggest fashion, consumer, lifestyle, and tech brands in the world. The main sourcing regions for these items is China and USA.

Our policies

Supplier relationships and the products they provide are governed by twelveNYC’s Supplier Code of Conduct, which includes a zero-tolerance stance on forced or bonded labour. Contained within the Supplier Code of Conduct are the Ethical Trade expectations as stated in the excerpt below:

“In accordance with the Ethical Trade Initiative and ETI Base Code, twelveNYC expects its suppliers to adhere to and take steps to ensure:

i. No direct or indirect product or service is provided to twelveNYC through the means of forced, compulsory, bonded or involuntary prison labour. Workers must not be required to lodge "deposits" or their identity papers withtheir employer and are free to leave their employer after reasonable notice.

ii. No child labour shall be used in the manufacture of any products, packaging or components for twelveNYC.”

twelveNYC understands the term “Modern Slavery” as the severe exploitation of other people for personal or commercial gain. The terms and definitions below are used to define the wording used in the Ethical Trade section of the Supplier Code of Conduct.


The use of violence, threats or coercion to transport, recruit, or harbour people to exploit them for purposes such as forced prostitution, labour, criminality, marriage, or organ removal


Any work or services people are forced to do against their will under threat of punishment


When a child is exploited for someone else’s gain. This can include child trafficking, child soldiers, child marriage and child domestic slavery


People trapped in poverty borrow money and are forced to work to pay off the debt, losing control over both their employment conditions and the debt


Where people are treated as property, and their “slave” status was passed down the maternal line


When someone is married against their will and cannot leave*


The Global Compliance team is responsible for managing the supply chain. This function was created within the business with the sole intention of fulfilling twelveNYC’s commitment to ethical and safe global business practices.

twelveNYC recognises that supply chains are complex and involve several different elements to create one product. twelveNYC is committed to mapping this supply chain and has completed the first phase of this task – mapping tier one suppliers in China – and will continue to map as our supplier base expands in line with business need. (Tier one definition - main production sites).

twelveNYC has updated the sourcing policy to mandate that:

All suppliers to twelveNYC must have read the Supplier Code of Conduct and agreed to the terms and conditions prior to commencing business

Production must be carried out by suppliers who hold a third-party ethical and social audit from a reputable and accredited auditing company

Suppliers must submit their ethical and social audit data for assessment prior to the commencement of production

twelveNYC reserves the right to visit the manufacturing facility of third-party suppliers to verify the credentials they have provided

Where a manufacturing facility falls short of the required standard, twelveNYC is prepared to work with the supplier to reach the expected standard. A corrective action plan with a clearly defined time frame will be agreed. If the non-compliances cannot be resolved during the agreed time, twelveNYC reserves the right to terminate the business relationship

Due to the ongoing global pandemic of Covid-19, the review of all ethical and social audit data has been restricted to desk-based evidence only as the ability to travel has been severely impacted.

In 2020/2021, training on the importance of Ethical Sourcing has been provided for employees involved in sourcing and product development. twelveNYC does however recognise the need for a more formal and detailed training on Modern Slavery which is made available to all employees.

Our commitment

The business is committed to improving supply chain transparency year on year, work has already begun on mapping tier one suppliers outside of China. 2021/2022 will focus on building out this picture further and expanding our training programme on Modern Slavery to our global teams. twelveNYC aims to make all communication related to Modern Slavery and supply chain management available in the local languages of the countries we source from regularly.

twelveNYC acknowledges that understanding and identifying the risks in the supply chain is an ongoing process and will commit the necessary time and resources to do this. The programme will be evaluated yearly, and our statement updated accordingly.

Statement approved and signed by:

Katie Conovitz

Date: 21/11/2021