Modern Slavery and Human Trafficking

Company Statement

Giftworks Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015. This Statement sets out the measures we are taking to address the risk of slavery and human trafficking taking place within its own operations and supply chains.

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.

Giftworks 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 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 on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, volunteers, agents, contractors and suppliers.

Business Sector

Giftworks primary business is the importation and distribution of goods for the leisure and retail industry. Giftworks only has employees in the UK. We have a customer base and suppliers throughout the UK, Europe and the Far East.

Responsibility for the Policy

Giftworks Directors have overall responsibility for ensuring that this policy complies with our legal and ethical responsibilities and obligations. The Directors are also responsible to ensure that all those under their control comply with this policy.

In light of the Modern Slavery Act 2015, we have reviewed the content of our Corporate Policies and updated them.

Ethical Code & Training

The Giftworks ethical code of conduct is applicable to all employees and all personnel working on behalf of Giftworks Ltd. The Code states that “we expect our suppliers to meet the minimum standards set out in our Ethical Code of Conduct and we will not tolerate the use of child labour or forced labour in our worldwide operations”.

All our employees are made aware of the Ethical Code on joining the business. The code is available at all times to personnel on the staff handbook. Training has been provided to those individuals most likely to be in position to identify and address potential modern slavery risks.

If Giftworks employees identify any potential signs of; slavery, human trafficking or any other human rights abuse, they are encouraged this to report this to the Directors of Giftworks immediately for an full investigation.

To date, Giftworks have received no report of concern regarding slavery or human trafficking in our operations. In the event this may occur, a full investigation will be done under the supervision of our legal team.

Recruitment Practices

Giftworks undertakes “right to work” checks on all direct employees prior to them commencing their roles with the Company. This includes checking, where applicable, that the employee has a valid work visa/right to work and is of an appropriate age to work and is in possession of their own legal and identity documents.

Our Risks Within Giftworks Own Operations

We have undertaken an assessment of slavery and human trafficking risks within Giftworks own operations. We considered the location of our operations; roles being performed; recruitment processes; and absence to date of reports of concerns regarding slavery and human trafficking.

As well as direct employees, Giftworks has agency and contract staff working at our sites.

Based on our risk assessments, we deem the risk of slavery or human trafficking occurring within the Giftworks direct employee population and agency population to be nil.

Assessment of Risks In Our Supply Chains

We have undertaken an exercise to assess slavery and human trafficking within our supply chains. We have evaluated our suppliers by considering the countries where our suppliers are based, products and services being supplied and the volume of spend. From our assessment to date, considering the type of commodity or service being provided and the country in which the suppliers are based we consider suppliers in China, Taiwan and India may potentially represent a slightly elevated risk of slavery or human trafficking. We seek assurances from these suppliers that they have effective procedures to protect their staff from slavery and human trafficking risks and are not aware of any current issues. We also obtain recognised audits for factories such as BSCI & ICTI. We actively manage our relationship with our suppliers.

Expectations Of Our Suppliers

If we become aware of slavery or human trafficking concerns within our supply chain we would seek to work with the relevant suppliers to improve conditions. We will deselect suppliers if they fail to comply. To date, Giftworks is not aware of any reports of slavery or human trafficking within the supply chain.

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.

APPROVED BY THE DIRECTORS OF GIFTWORKS LTD

FOR FINANCIAL YEAR ENDING 2024