ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

PURPOSE

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, agents, contractors and suppliers. Sportsshoes.com strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation.

KEY PRINCIPLES

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

COMMITMENTS:

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.

The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationship and implementing and enforcing effective systems and controls to prevent slavery and human trafficking.

• Build long-standing relationships with local suppliers and make clear our expectations of business behaviour;

• Have a policy of “knowing our customer” to ensure that we are contracting with appropriate businesses.

• Adopt robust recruitment processes in line with UK employment laws, including: ‘right to work’ document checks; contracts of employment and checks to ensure everyone employed is 16 and above.

• Pay and reward our staff in accordance with legal requirements and reviewed annually and benchmarked.

• Monitor and manage areas of potential risk in our business and supply chains.

• Adopt a zero tolerance approach to slavery and human trafficking throughout the organisation and our supply chains.

• Scrutinise any identified areas of risk within our business and supply chains.

RESPONSIBILITIES

• The Company, our managers and our colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.

• Everyone must observe this Policy and be aware that ‘turning a blind eye’ is unacceptable and simply not an option.

THE COMPANY WILL:

1. (a) Maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation.
2. (b) Be clear about our recruitment.
3. (c) Examine our supply chains and be clear with key suppliers our expectations regarding the Act.
4. (d) Lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc to ensure we know who is working for us.
5. (e) Ensure we have in place an open and transparent grievance process for all staff.
6. (f) Seek to raise awareness so that our colleagues know what we are doing to promote their welfare.
7. (g) Make a clear statement that we take our responsibilities to our employees and our clients seriously.

DECLARATION

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Slavery and Human Trafficking policy.