1. POLICY STATEMENT
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
2. RESPONSIBILITY FOR THE POLICY
The Sambro International board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Operations Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Operations Director.
3. COMPLIANCE WITH THE POLICY
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify either your manager, the Operations Director or the confidential helpline (+44 161 765 3767) as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or the Operations Director. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the Operations Director or through the confidential helpline (+44 161 765 3767).
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Operations Director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found as part of our Employment terms and conditions.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
5. BREACHES OF THIS POLICY
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
This is our first statement and has been published in accordance with the Modern Slavery Act 2015. It sets out our actions to understand all potential modern slavery risks related to our business, and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business and supply chains.
This statement relates to our actions and activities during the financial year 01/04/2018 – to 31/03/2019.
We recognise that we have a responsibility to take a robust approach to slavery and human trafficking. We are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.
Sambro International Ltd started trading in 1996, and we have constantly developed and refined our product portfolio to meet the demands of the toy industry with our licensors and also through our own-label product range.
Our management team have been instrumental in driving change and improvements through innovative product development.
We have strived to do more for our customers than simply keep pace with the industry and have become a global leader in licensed products.
OUR SUPPLY CHAIN
Sambro International Ltd is committed to procuring goods and services from suppliers who demonstrate ethical principles in the way they conduct their business, and we engage with suppliers on standards of quality, safety, environmental responsibility and human rights.
We require our suppliers to have fair working conditions; these include:
Forced, bonded or compulsory labour must not be used. Employees should be free to leave employment at any time after reasonable notice. Employees should not be required to lodge identity papers or other valuable items with their employer, on an indefinite basis.
No person shall be employed who is under the age for completing compulsory education, or under minimum wage for employment in the country, whichever is greatest. Young people under the age of 18 shall not be employed in hazardous conditions without appropriate supervision or complete work that could affect their personal development.
Employees’ employment conditions should be clearly communicated to them. Employees should be fairly and reasonably paid in line with applicable wage laws relating to minimum wages, overtime hours and legal mandated benefits.
There shall be no harsh or inhumane treatment of workers such as verbal or physical abuse.
OUR ANTI-SLAVERY POLICY
Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all of our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk, we undertake due diligence when taking on new suppliers and regularly review existing suppliers.
mapping the supply chain to assess particular product or geographical risks of modern slavery and human trafficking;
evaluating the modern slavery and human trafficking risks of each new supplier via a prequalification questionnaire, and reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
ensuring that all internal processes are being adhered to for example ensuring that personnel provided by agencies or recruited directly by us have a Right to Work in the UK.
We have in place systems to:
identify and assess potential risk areas in our supply chains;
mitigate the risk of slavery and human trafficking occurring in our supply chains;
monitor potential risk areas in our supply chains, and protect whistle blowers;
ensure supplier adherence to our values.
We have a zero tolerance approach to slavery and human trafficking. To ensure that all those in our supply chain comply with our values, we have implemented processes to:
clearly communicate our expectations to our supply chain in respect of sustainability, anticorruption and bribery, and ethical procurement;
encourage our suppliers to cascade a similar process and expectation within their own business and supply chain;
ensure adherence to our policies at supplier selection, on-boarding, risk analysis, performance measurement and continual assessment; and ensure that adherence to our policies is a contractual obligation in our agreements with suppliers.
We have a committed compliance team, which includes personnel from the following departments:
To ensure a level of understanding of the risks of modern slavery and human trafficking in our business we shall implement an awareness document alongside our modern slavery policy, which all employees will be required to read and sign.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We will use the following key performance indicators (KPls) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
We shall ensure that 100% of all new employees are inducted on our Anti-Slavery policy and that they sign an acknowledgement in respect of this;
We shall complete a comprehensive review of our existing supply chain;
We shall request from 100% of existing and new suppliers, with a turnover above £36m, a copy of their Modern Slavery and Human Trafficking Statement.
In addition to pursuing the KPIs above, we intend to develop and deliver a Modern Slavery training and awareness programme to our existing staff, as a further step to combat slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015, and constitutes our slavery and human trafficking statement for the financial year ending.
This statement has been approved by the board of Directors on 29/03/2019 and signed off by Collette O’Kane, COO.