Modern Day Slavery


Warren James has always believed in treating people with dignity and respect.  Since our incorporation in 1979, doing business the “right” way has been a cornerstone of our family business and we have always strived to pursue our business activities in a responsible and ethical manner.
We have a zero tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operations and supply chain.  We support the government’s objectives to eradicate modern slavery and human trafficking.

Our business and supply chains

Warren James is the UK’s largest independently owned jewellery chain with over 200 shops across the country.

Most of our employees are employed on permanent contracts although we also have seasonal temporary workers to accommodate the increased demand in the run up to Christmas. During the last year our shops have frequently been closed as a result of legislation enacted due to the pandemic and many staff placed on furlough. We took swift and essential steps to ensure our staff took all precautions when working either in shops or at head office. 

Our products are sourced from all over the world.  We enjoy, and put trust in, long standing relationships with many of our suppliers.

During the financial year ending 31 March 2021, we experienced a huge impact on our business as a result of the global Covid-19 pandemic. As anticipated, the pandemic had a significant influence on our supply chain during the 2020-21 financial year and we will keep this under review during the year ahead. 



We have in place a variety of policies for identifying and preventing slavery and human trafficking in our operations and to protect worker rights and to promote a safe and fair supply chain:

  • Recruitment policy – we have a robust recruitment policy which includes conducting checks that employees are eligible to work in the UK to safeguard against human trafficking or individuals being forced to work against their will.  We endeavor to ensure that employees making recruitment and selection decisions do not discriminate and all applicants will receive fair treatment;
  • Equal opportunities policy – we are committed to preventing discrimination and encouraging diversity amongst our workforce.  We are opposed to all forms of unlawful and unfair discrimination;
  • Whistleblowing policy – we operate a whistleblower disclosure system available to all members of staff so that employees can raise concerns about how their colleagues are being treated or practices within our business or supply chain without fear of reprisal;
  • Supplier Code of Practice - which stipulates our requirements, including the obligation for our suppliers to operate in a responsible and ethical manner, the prohibition of child labour and forced labour, appropriate health and safety standards and procedures and compliance with local laws in respect of working hours, minimum wages, overtime and employee benefits;
  • Warren James’ Terms and Conditions of trade that all our suppliers must sign up to and adhere to.  These specifically require all suppliers to adhere to universally acceptable standards of business practice and must not engage in unethical, immoral or commercially unacceptable business activities. Our suppliers must adopt our social, ethical and environmental principles.
  • We require all our suppliers to adhere to the Kimberley Process which seeks to tackle the trade in conflict diamonds around the world.  We further require all our suppliers to commit to the ‘Golden Rules’ of the ‘No Dirty Gold’ campaign which we have espoused since 2006.

We are looking at the benefit of putting in place an overarching Modern Slavery policy for the business. 


Due Diligence

As part of our initiative to identify and mitigate risk, we conduct due diligence on all new suppliers both at the outset of any relationship and on an ongoing basis.

We seek to:

  • Identify and assess potential risk areas in our supply chain;
  • Mitigate the risk of human slavery and trafficking occurring in our supply chains;
  • Monitor potential risk areas in our supply chain;
  • Protect whistleblowers.

We have reviewed the Global Slavery Index in assessing the likely risks associate with countries where we have business interests and relationships.

Our buying team is small and closely involved in the process, with a close working knowledge of suppliers. 


Training and awareness

All members of staff undergo a full induction process on joining the company.  This includes training on all relevant policies and procedures of Warren James.

Members of the company involved in supply chain and HR are reminded to be constantly mindful of the risks of slavery and human trafficking in our business. 

Staff have received training and guidance on the measures the business is taking to protect our people and our customers. These measures were kept under review and updated in accordance with the frequently changing government advice. 


Risk of slavery and human trafficking in our business

We will continue to work with our suppliers to ensure that to the best of our and their knowledge, our supply chain is free from abuse by slavery and human trafficking.
We will keep under review the steps we are taking, and any we need to take to ensure that there is no slavery or human trafficking in our supply chain.  We acknowledge that it is not practical for us to have a direct relationship with all links in the supply chain, as this would ultimately be to the mine, utility generator etc. We expect our suppliers and those we work with to adhere to the Ethical Trading Initiatives Base Code.

We find that preparing our annual statement is a useful and thought provoking process. Modern slavery is a complex issue and can be difficult to identify. The ongoing review process is important for maintaining diligence on this issue. We are fortunate that we have not found any cases within the company, nor become aware of any within the supply chain. However, we will not be complacent an will remain thorough in our response to this risk. We continue to rely on our personal knowledge of those with whom we do business and the trust we have in those relationships. We recognise the need to keep our policies and processes under review. 

This last year we have noticed that many of our national and overseas contacts have had different working patterns with many working from home and working in a different way. we are pleased that we were able to ensure people felt safe in the ways they were working and will be monitoring this during the year ahead as working patterns evolve and develop.   

This is our fourth Statement published in accordance with section 54 of the Modern Slavery Act 2015 and relates to the financial year ended 31 March 2021.  It has been approved by the board of Warren James (Jewellers) Limited.  It sets out the steps taken by Warren James (Jewellers) Limited and other relevant group companies, including Warren James Holdings Limited to identify and prevent modern slavery and human trafficking in its business and supply chains.


John Coulter,

Founder and Managing Director

10th May 2021