Modern Slavery Policy

INTRODUCTION

At Sambro International Ltd, we embrace principles supportive of equal treatment without discrimination and with the protection     of employment law for all staff. We treat all staff equally: without discrimination and with respect for their human rights and have a zero tolerance approach to slavery and human trafficking. This statement is 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.

OUR BUSINESS

Founded in Manchester in 1996 Sambro is a supplier of bespoke toys, games, soft toys and arts & craft product. Our operations are mainly with UK and EU overseas markets. Our supply chains are located predominantly in the Far East, mainly China.

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.

We are committed to preventing acts of slavery and human trafficking from occurring within both our business and supply chain.

In particular:-

·       We bear the full costs of recruitment and do not charge staff fees for hiring, placing or promoting them.

·       We provide written statements of terms and conditions of employment to all staff as required by law. These  documents explain everything in a clear and transparent way.

·       We support the right to seek, obtain and hold employment without discrimination and with complete  respect for dignity.

·       We do not coerce anyone to work for us. When you choose to work for us you do so voluntarily.

·       Employees must prove their entitlement to work in the UK. However, we do not hold or retain original      passports, identity documents or residency papers.

·       Everyone is paid regularly, in accordance with their terms and conditions. We provide a written summary of    pay and deductions (pay slip) on every occasion.

·       Everyone has the right to join or not join a trade union at their complete discretion.

·       We provide safe and decent working conditions with suitable training as necessary. Our operations comply  with or exceed statutory health and safety standards.

·       We provide formal grievance provisions through which staff are free to lodge a work related complaint or raise a matter of concern.

·     We do not impede anyone’s freedom of movement or their opportunity to seek employment elsewhere.

We have commenced:

·        Making our staff aware of the Modern Slavery Act, including definitions of slavery and human trafficking and will complete refresher staff awareness training in January 2022;

·         Informed our staff what to do if they suspect a case of slavery or human trafficking;

·         Implemented the process of notifying our supply chain of our Modern Slavery statement and the company’s zero-tolerance approach to modern slavery and human trafficking; and

·         Commenced the audit of our new suppliers to check what assurance arrangements they have in place

·         Assessment of the status of current established suppliers to establish a plan for future audits

We will introduce regular process controls to:

·         Review our procurement contracts and related documents to include prohibitions in respect of slavery and human trafficking and compliance with the legislation and

·         Review our policies to ensure compliance with legislation i.e. recruitment, whistleblowing, purchasing, and  HR policies

·         Identify and assess potential risk areas in our supply chain

·         Monitor potential risk areas in our supply chain to mitigate the risk of slavery and human trafficking  occurring

OUR ANTI-SLAVERY POLICY

Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all 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 will start the process to assess how we undertake due diligence when taking on new suppliers and review existing suppliers.

This assessment will include:

·       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 third party audit process 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 Audit and on boarding 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 by issuing our Ethical Sourcing Policy

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 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 encouraged in our agreements with suppliers.

We have a committed compliance team, which includes personnel from the following departments:

·       Ethical and Sustainability Manager

·       Q.A. Team

·       Human Resources

AWARENESS TRAINING

To ensure a level of understanding of the risks of modern slavery and human trafficking in our business we shall implement a training programme and awareness document alongside our modern slavery policy, which all employees will be required to complete.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We will use the following key performance indicators (KPIs) 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;

FURTHER STEPS

In addition to pursuing the Key Performance Indicators 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.

It is also the intention to introduce an independent audit programme in 2022.

This statement is designed to:

·         Identify and assess potential risk areas in our business and supply chains

·         Reduce the risk of slavery and human trafficking occurring in our business and supply chains

·         Monitor potential risk areas in our business and supply chains

·         Provide adequate protection for whistle blowers

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

Our Modern – Slavery and Human Trafficking policy demonstrates our commitment to acting ethically and with integrity in all 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.

Additional information is available in the Modern – Slavery and Human Trafficking policy.

This statement has been approved by the Board of Directors on 17^th May 2023 and signed off by Paul Blackaby, CEO