Human Rights Statement

Our Promise

As a business operating across global supply chains, Mi Hub Ltd are committed to ensuring that the rights of workers are consistently respected. We understand that we have a responsibility to protect human rights and advocate better working practices in our own operations through our supply chains, respecting our colleagues, suppliers and the communities we operate in. We further recognise that responsible purchasing practices and transparency plays a key role in this responsibility, and as such our Human Rights Policy Statement seeks to support our commitment to human rights due diligence (HRDD) through outlining the steps we are taking as a business to address and mitigate our potential human rights impacts.

 

Our Approach

Our approach to human rights due diligence is aligned with the UN Guiding Principles on Business and Human Rights and reflects the human rights as defined in the International Bill of Human Rights. We are further aligned to the International Labour Organisation’s Core Conventions and International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work and are guided by the OECD Due Diligence Guidance for Responsible Business Conduct.

As members of the Ethical Trading Initiative (ETI), we also fully endorse and support the ETI Base Code and require our suppliers to do the same. We follow and adhere to all local laws and regulations, and where these laws and human rights standards may differ, the higher standard is followed.

Mi Hub Ltd is committed to operating a robust HRDD process to avoid potential human rights impacts which are either caused by, contributed to, or linked to our activities. In the case of any impacts which do occur, we are committed to addressing and remediating these. We also recognise that our approach will need to remain adaptable, and as such will be reviewed at least annually.

Governance and accountability structure for managing human rights in our supply chains:

 

 

Identification and Prioritisation

Our HRDD approach follows the OECD Due Diligence Guidance for Responsible Business Conduct process, and as such has been progressively developed from an initial identification of human rights risks within our own operations and supply chains.

It is key to our approach to take time to understand the specific risks to our business and supply chain. In 2023, we identified our preliminary salient issues and in 2024 we added one further salient issue to those already identified.

At the beginning of 2023, we began our saliency assessment with an analysis of industry guidance combined with a detailed collection of historic data collated from sources such as questionnaires, third-party audits and targeted projects. To gain an understanding of the current trends within our industry, a customer and industry analysis was conducted using sources such as the Sedex Radar Tool, the Global Slavery Index, ETI reports and the Business & Human Rights Resource Centre. This highlighted where the human rights focus areas were across the textile industry, and where we may need to prioritise our own research and analysis.

After gaining an understanding of the industry and origin specific risks to human rights, a full supply chain analysis was conducted across all origins of our Tier 1 and Tier 2 Goods-for-Resale (GFR). Beginning with the data available to us through Sedex SAQs, SMETA audits and worker voice programmes, risks were assessed and analysed based on stakeholder mapping, and an assessment of whether we have the potential to cause, contribute to, or be linked to specific human rights impacts. Together, these two tasks highlighted who (based on worker type and country of origin) had the highest potential to be impacted by human rights violations both internally and externally, based upon the data and resources available to us at the time.

Following this, the risks were categorised into a matrix for likelihood and severity at a more granular level to allow for prioritisation. This allowed for a more visual overview of our greatest risks to human rights, which we were able to share with senior leadership within the business. Upon review of the matrix and following stakeholder feedback, three salient issues were selected based on both risk and prevalence. Also selected were two unintended consequences which run as concurrent themes with the ability to impact upon the salient issues.

In 2024, parts of our supply chain were affected by civil unrest that spread throughout the country. It was at that point we recognised the need to clearly communicate our stance on Freedom of Association and formulate a policy on the subject. Through support given from the ETI via a freedom of association working group, we were also able to understand just how focusing on freedom of association could positively impact other ETI Base Code Clauses. From this, we recognised that freedom of association needed to be one of our salient risks.

In 2025 we have focused on our four salient risks, working on each point, and feel that these risks are still where we need to concentrate our efforts at this time. However, we have also been conducting stakeholder engagement with some workers in our factories which may impact our salient risks in the future.

The work we have carried out in relation to stakeholder engagement and with each salient risk is detailed below.

 

Our Supply Chains

The main supply route for production is from Bangladesh. As a country classed as high-risk, we have a dedicated office based in Dhaka with 25 employees, including a compliance manager, who has a constant presence in our supplier factories.

Global map of our Garment Manufacturers as of November 2025 -

Bangladesh and China continue to make up over half of our Tier 1 supplier sites. This prevalence brings with it an overall heightened risk in the number of workers impacted through these sites, however each of the two origins also bring their own specific risks to workers.

In Bangladesh, whilst it has one of the highest risk ratings from the Global Slavery Index for modern slavery with a prevalence score of 7.1, we have also seen huge disruptions due to unrest in the country leading us to have a particular focus on freedom of association and worker representation within the country.

Again, in China, the prevalent risks detected from a combination of the Sedex Radar tool and worker information are Forced Labour and Freedom of Association. Last year we stated that we would review the results of the modern slavery SAQ to understand in more detail the systems that our China-based sites have in place and we have done exactly that. Reported below are the risk ratings found from that piece of work where our China sites sat firmly in the middle of the risk ratings.

In our review of the modern slavery SAQ scores and in our work in looking at country risks for discrimination, we found that Madagascar came out with high-risk indicators. Therefore, Mi Hub will be entering into 2026 with a new focus on Madagascar as a high-risk country as well.

 

Salient Risks

Freedom of Association and Stakeholder Engagement

Whilst all of our suppliers are aware of our commitments to the ETI Base Code and our expectations that they share the same responsibilities towards human rights, in 2024, we felt the need to go one step further and issue a statement to our suppliers explaining further our stance on Freedom of Association after some of our suppliers were affected by civil unrest. We then decided that this statement should be a policy and this provided an opportunity improve our communication with our suppliers on this topic. We think it’s important to give our suppliers one clear message from Mi Hub on Freedom of Association and what we expect of our suppliers so there is no room for misunderstandings. When we had the opportunity to join a freedom of association working group and get support in policy development, we knew this would really help us. We have created one policy that fits both our own business and our supply chain, making a policy that we can hold ourselves accountable to as well as our suppliers.

In January 2025, we visited the ETI office in Bangladesh and spoke with the Country Manager.

The aims of the meeting were to gain feedback on one of the projects we had been involved in in relation to environmental education of workers in Bangladesh and seek the opinions of experts in Bangladesh on Human Rights and Freedom of Association.

In 2024, protests began, which resulted in widespread unrest and Government collapse.

The readymade garment sector, which accounts for more than 80 per cent of Bangladesh’s export earnings, has been hit hard, and factory closures resulted in daily losses of nearly US$150 million.  (https://www.asiapacific.ca/publication/explainer-whats-behind-bangladeshs-deadly-protests)

This was discussed with the Country Manager, along with work recently carried out by Mi Hub on Freedom of Association. It was said that the root cause of any worker unrest is wages. The frustrations that workers feel in relation to wages includes but is not limited to minimum vs living wages. Workers also face challenges with on-time payment of wages, which can also cause issues for workers that may lead to unrest.

As part of our focused work on Base Code Clause 2, Mi Hub know that ‘Freedom of Association and the right to collective bargaining are respected’ is the enabling right that could support workers to have a voice and support effective grievance mechanisms, allowing workers to effectively raise issues in the workplace that avoid extreme measures, violence and unrest.

Questions have been asked by Compliance teams in the past as to how to make positive and effective changes within global supply chains. Barriers have been faced such as language, resource and geographical locations.

One positive change, rather than reacting to one particular issue, would be to provide workers and managers with the tools to solve their issues themselves in an effective way that benefits all. Based on this concept, we decided in 2025 to focus on benchmarking the worker representation that is currently in place in factories in Bangladesh and seek advice on how to strengthen that representation if necessary.

We collected data from our partner factories and then ETI Bangladesh supported us by analyzing the information and made recommendations to us on which factories, considering what effective worker representation was already present and also factory location, would benefit from a Social Dialogue program. We then selected one factory who we wanted to work with us on the program and approached them to ask for their participation on the program. We are really pleased to say that the factory has agreed to participate in the program and we are now in the process of onboarding. The intention is for this program to start in January 2026 and run for 18 months.

 

Rightsholder Stakeholder Engagement with &Wider

In 2024, we established a target to implement a Worker Voice Program in 5 of our core group of factories within our supply chain and we decided to approach the company &Wider to assist us with this project.

&Wider use their technology to evaluate human rights risks throughout supply chains, track progress and identify areas for improvement.

For Mi Hub, the objective was to garner direct worker engagement to gain insight into working conditions and commitments to human rights at factory level.

 

Through the program, we hoped to strengthen the factories’ knowledge of due diligence requirements and to develop a clear understanding of the key challenges workers face, as well as identify future strategies to improve operational standards and worker wellbeing across our supply base.

For the program, we selected suppliers that operate in the regions seen on the map below.

In 2025, the &Wider Worker Voice Program was rolled out to 5 factories in our supply chain, covering 14,288 workers, and successfully gathered their responses through an anonymous survey for which participation was voluntary. The survey was conducted in three call cycles, during which workers responded to a set of 16 questions in each cycle, selecting from three response options: negative, neutral, or positive.

Each survey cycle was assigned an overall rating of Green, Amber, or Red based on how positively or negatively workers responded to the questions. Mi Hub’s target was to complete all three call cycles across the five factories, with the goal of achieving a Green (Positive) rating for each factory.

This goal has been successfully achieved, and we are now able to share the results and begin to identify future priorities informed by the outcome of the program.

 

The Results

After completing three call cycles, the results show that all five factories received Green ratings, with scores above 7 in each cycle.

Throughout the call cycles, over 80% of workers reported having access to clean toilets and over 90% of workers have safe drinking water at their workplace. They also confirmed that they have the necessary protective gear and are physically able to evacuate in case of a fire or emergency.

Additionally, workers expressed that their employer provides support for medical treatments at work and an overall safe working environment. While these positive findings are encouraging, the most common concern raised by workers was that their wages often run out before the end of the month. We will now look to follow-up with the factories on the results received. We will also continue this project with 3 additional core factories in 2026.

 

Health and Safety

Mi Hub have been a member of Sedex, the global organisation providing a platform for companies to manage ethical compliance in their supply chains, for over 15 years.

Within Mi Hub’s Ethical Compliance Programme, we ask all Tier 1 and Tier 2 Garment Suppliers to carry out an annual 4-Pillar SMETA (Sedex Members Ethical Trade Audit that aligns to the Ethical Trading Initiative 9-point base code).

Our suppliers’ SMETA audit findings are viewed by Mi Hub on the Sedex platform. It is here that we can identify patterns from issues found and gather information on any potential risks.

When looking into the trends that appeared during these audits over the last 12 months, we began to see that Health and Safety issues represented a large proportion of the Non-Conformances found. We recognise that Health and Safety issues are frequently found in Ethical Audits and to be somewhat expected, however, as they embody a significant percentage of overall Non-Conformances, we cannot dismiss this finding.

In response to this and as part of our Human Rights Due Diligence Strategy, we completed a project to review all Non-Conformances raised within our supply chain in the previous 12 months. From this project, we discovered that 58% were related to Health and Safety.

Once the Non-Conformances were categorised into sections, we began to analyse the number of issues raised within each area of the Health and Safety sector. The most frequently found Non-Conformances related to machine safety guards, personal protective equipment (PPE), and documentation/certification for machine licenses.

Bangladesh, China and Pakistan recorded the highest number of Health and Safety Non-Conformances within our supply chain. However, it is important to note that this trend may be influenced by the number of sites located in these countries. With a greater number of facilities operating in these countries, the likelihood of finding more Health and Safety issues raises, thus increasing the overall risk.

In response to our findings, we developed the ‘Mi Hub Supplier Health and Safety Guidance’.

This guidance is aimed at supporting our suppliers with strengthening compliance in Health and Safety, providing practical checklists to assist in their audit preparation as well as placing particular importance on worker wellbeing and safety.

The guidance is currently being distributed to our Tier 1 and Tier 2 Garment Manufacturers who are preparing for their SMETA audit, accompanied by a communication outlining Mi Hub’s intention to develop a more pro-active and preventative approach to SMETA audits and Non-Conformances.

Following distribution of the guidance, we engage with suppliers to review the outcome of their SMETA audit, assess the effectiveness of the guidance and ask for their feedback to gain a clearer view into what is required to support future improvement in this area.  

 

Modern Slavery

In 2024, in partnership with the Slave Free Alliance, we sent out a Self-Assessment Questionnaire (SAQ) that was created by the Mi Hub Ethical Compliance team to suppliers using a 3^rd party platform.

Our suppliers completed the SAQ, and the results were returned via the platform.

The Slave Free Alliance then extracted those results and collated them so that analysis could begin on our areas of greatest risk.

There were lots of takeaways that we got from the information that was received from the Slave-Free Alliance, including what strengths and weaknesses our factories had in relation to modern slavery and also the strengths and weaknesses of our own SAQ, the questions that were asked and how they were interpreted by people who’s first language is not English.

Below is top line information on how our suppliers ranked in terms of risk:

Supplier Name	Supplier Location	Total Risk Score Rating
Factory 1	Bangladesh	157
Factory 2	Bangladesh	113
Factory 3	Bangladesh	135
Factory 4	United Kingdom	115
Factory 5	China	117
Factory 6	Indonesia	124
Factory 7	United Kingdom	117
Factory 8	Madagascar	196
Factory 9	China	126
Factory 10	Vietnam	147
Factory 11	Sri Lanka	142
Factory 12	China	122
Factory 13	United Kingdom	118
Factory 14	Indonesia	140
Factory 15	Egypt	127

 

Total risk score = 251

The scores are made from a combination of question rating and response rating, meaning that some questions were given a higher weighting than others and the responses to those questions were also given a weighting. Those two elements were added up to provide a total score for the question. All the total scores for each individual question were then added up to produce a total risk score (maximum risk score being 251).

From the table above, we can conclude that Madagascar has the highest risk score, followed by Bangladesh, Vietnam and Sri Lanka. When we look at our other salient risks as part of a bigger picture, there is a link between our country risks in relation to both modern slavery and discrimination.

 

Discrimination

Human Development Index (HDI)

The Human Development Index (HDI) is a statistic used to rank countries, by average, using three fundamental measurements of human development: a long and healthy life, knowledge, and a decent standard of living. The HDI combines these measurements to produce a score per country between 0 and 1. The higher the score indicates more advanced human development

Mi Hub Sourcing Countries

Sourcing Country	Human Development Index (HDI) Tier (2023)	HDI 2023 (0 - 1.0)	HDI World Ranking 2023 Out of 193
United Kingdom	Very High	0.946	13
USA	Very High	0.938	17
Italy	Very High	0.915	29
Romania	Very High	0.845	55
Albania	Very High	0.810	71
China	High	0.797	78
Mexico	High	0.789	81
Sri Lanka	High	0.776	89
Vietnam	High	0.766	93
Egypt	High	0.754	100
Tunisia	High	0.746	105
Indonesia	High	0.728	113
Philippines	High	0.720	117
Bangladesh	Medium	0.685	130
India	Medium	0.685	130
Pakistan	Low	0.544	168
Madagascar	Low	0.487	183

Source - https://worldpopulationreview.com/country-rankings/hdi-by-country

 

Key
Tier 1	Very high human development (0.8-1.0)
Tier 2	High human development (0.7-0.79)
Tier 3	Medium human development (0.55-.70)
Tier 4	Low human development (below 0.55)

 

Gender Inequality Index (GII)

The following data is taken from the United Nations Gender Inequality Index, published on 6^th May 2025. We have filtered the data to show our sourcing countries and how they rank using the GII, which is described by the UN as a composite metric of gender inequality using the 3 dimensions of reproductive health, empowerment and the labour market.

 

Findings in relation to gender equality

We have focussed our research on only Mi Hub’s sourcing countries and based on the above information we can see from the Human Development Index, that Madagascar is the lowest ranked country with the lowest Human Development grade.

Currently, the lowest Human Development World ranking is 193, Madagascar scores 183 and has the lowest HDI score of 0.487 out of Mi Hub’s sourcing countries.

Likewise, when looking at the Gender Inequality Index data, Madagascar is ranked the lowest for Gender Inequality, Maternal Mortality Ratio, Adolescent Birth Rate, Share of Seats in Parliament, Population with some Secondary Education and Labour Force Participation Rate.

Therefore, this information allows us to conclude that Madagascar should be our starting point when looking at Discrimination in Mi Hub’s supply chain.

 

Conclusion

The main deductions from our work completed in 2025 is that Madagascar should be considered a high-risk country based on our findings in relation to Modern Slavery and Discrimination.

Also, from our stakeholder engagement both with work completed with &Wider and ETI Bangladesh, we can see that wages is a concern for workers.

These findings will be the foundations of our strategy for 2026.