Modern Slavery Statement

INTRODUCTION

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.

OUR BUSINESS

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.

This includes:

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:

Sales
Operations
Human Resources
Supply Chain
Buying
QA

AWARENESS TRAINING

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.

FURTHER STEPS

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.