Paladone Modern Slavery & Human Trafficking Statement 2022\/23<\/p>\n
This statement sets out Paladone Group Holdings Ltd actions to understand and identify all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking within Paladone\u2019s own business or its supply chains. It also explains the relevant policies Paladone has adopted and highlights future objectives, targets, training, and actions taken by Paladone to mitigate the risks of Modern Slavery.<\/p>\n
The statement has been produced in accordance with the Modern Slavery Act 2015 and takes into consideration the guidance provided by the UN Guiding Principles on Business and Human Rights as endorsed by the UN Human Rights Council and the Ethical Trade Initiative (ETI) Base Code, supporting good international labour practice and the principles and guidance in the Act. It also considers all customer requirements including customer specific codes of conduct.<\/p>\n
This is Paladone\u2019s latest Modern Slavery statement and relates to actions and activities during the financial year 1 July 2022 to June 2023.<\/p>\n
We recognise that we have a responsibility to take a robust approach to slavery and human trafficking and Paladone is absolutely committed to preventing slavery and human trafficking in its corporate activities.<\/p>\n
This statement has been approved by the Executive Team of Paladone Group Holdings Ltd.<\/p>\n
Paladone designs unique gift products for its retail customers globally, with an annual turnover more than \u00a370 million. In addition to our UK and USA offices we have an office in Hong Kong with dedicated ethical and quality compliance staff. We work with several factories across a large spectrum of product which are predominantly based in China.<\/p>\n
As well as our own distribution centre in Shoreham, we work with 1 third party logistics facility in the UK, and 1 in Germany and 2 the US.<\/p>\n
At the outset of the financial year Paladone had a global staff head count of 155 people across 3 International offices. The headquarters based in Shoreham by Sea in the UK are accountable for 107 staff with a further 29 people in HK and China and the remaining 10 in the US. We also have 9 sales and sales support staff working in France, Spain, Germany, Canada and Australia to support our global operations. Paladone continues to see growth in the global wholesale consumer goods sector. Whilst every effort is made to drive ethical practice in its supply chains, Paladone looks to go beyond audit and to work with its supply chain to do the same and raise its awareness to issues like Modern Slavery that touches every corner of the globe.<\/p>\n
Responsibility for our anti-slavery initiatives is as follows:<\/p>\n
The term Modern Slavery is used to encapsulate slavery, child labour (as defined by the International Labour Organisation) and forced or compulsory labour, as well as human trafficking. Paladone prohibits the use of forced, debt bonded, involuntary prison labour, slavery or human trafficking in its business or supply chain which is enforced through our Supplier Code of Conduct (COC).<\/p>\n
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations.<\/p>\n
We undertake risk assessment and due diligence when considering onboarding new suppliers and conduct regularly reviews on our existing suppliers. Our due diligence and reviews include conducting supplier audits or assessments through our own- and third-party auditors, which have a greater degree of focus on slavery and human trafficking where general risks are identified.<\/p>\n
Risk Assessment<\/u>\u00a0– High Risk Areas Identified<\/p>\n
Paladone\u2019s Compliance and HR teams have conducted a risk assessment to identify high risk areas of the business and have identified the factories we work with in the Far East and temporary warehouse workers in the UK and USA as the highest risk of modern slavery.<\/p>\n
We have identified that recruitment of temporary and migrant workers at peak times (June September) are exposed to the highest risk of exploitation. We have also mapped the locations of the factories we work with against the number and nature of non-compliances found on audits to identify the factories and areas to focus on as a priority. Through training we are aware that non-compliances such as the below can all be potential red flags of risks of modern slavery:<\/p>\n
We track the factories we work with through a database of detailed information from third party and Paladone audits. We have developed a grading system which enables us to rate factories based on their audit standard and work closely with them to rectify any issues found and drive continuous improvement. Our preferred audit standards are SEDEX Members Ethical Trade Audit (SMETA) and Amfori BSCI. SMETA audit framework is built around the ETI Base Code and is widely recognised by the industry. Its audit format covers Modern Slavery and Human Trafficking dedicated sections in its latest audit format SMETA 6.1 which includes:<\/p>\n
SMETA audits can be announced or semi-announced and we build relationships to encourage factories to work towards semi-announced & unannounced audits as it demonstrates a higher level of compliance.<\/p>\n
Amfori BSCI offers a code of conduct that contains a set of values and principles which help members enhance their own policies and practices. The UN Guiding Principle on Business and Human Rights, the International Labour Organization, the Organization for Economic Co-operations and Development, and other international rules are all in compliance with these principles.<\/p>\n
Our main Paladone UK warehouse, employs agency workers at busy periods. We are aware is another high-risk area; as we have less control over how agencies have recruited the staff, whether they have taken illegal deductions or deposits and whether they have carried out checks to ensure workers are not victims of human trafficking or forced labour. To minimise this risk Paladone\u2019s HR department conducts interviews with any new agency and uses only specified, reputable employment companies to source labour, always verifying their practices before accepting workers. An audit is carried out annually to ensure that standards are being maintained and worker interviews are carried out to ensure they understand their rights and to check they are being treated in accordance with the ethical standards agreed. We have issued all temporary workers with a handbook which covers their rights and useful helplines and an introduction to modern slavery, which is issued prior to them commencing work.<\/p>\n
We require compliance teams who deal with due diligence, quality management and compliance within our supply chain as well as HR teams and key warehouse personnel within our company to complete training on modern slavery. In addition to this, all new starters to our business are made aware of modern slavery within their induction, which includes what it is, how to spot the signs and how to report a suspected incident.<\/p>\n
Our modern slavery training covers:<\/p>\n
As well as training staff, we have raised awareness of modern slavery issues by putting up posters across our premises.<\/p>\n
The posters explain to staff:<\/p>\n
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