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Modern Slavery Statement

Modern Slavery & Human Trafficking Statement

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Introduction

This statement sets out APC Workwear Limited’s (hereby referred to as ‘Organisation’) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business, its suppliers and its chosen brand supply chains.

This statement and policy is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 ('The Act’) and sets out our organisation's actions to understand all modern slavery and human trafficking risks related to our business, to what extent measures already exist and what further measures may be required to prevent slavery and human trafficking taking place in any part of our business, our suppliers and our chosen brand supply chains. This statement explains what steps our organisation takes to understand, reduce and remove the risk. Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its suppliers and chosen supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of APC Workwear Limited:

• Organisation:

Our organisation operates from our main office, based at APC House, 41-43 Bedminster Down Road, Bristol BS13 7AB in the South West of England, UK.

• Our Supply Chain:

Our organisation's supply chain includes a number of vetted suppliers offering international brands operating mainly within Asia, Central America, Europe and China. These products are shipped into our supplier warehouses for distribution directly to our organisation. We request details from each of our suppliers in relation to theirs and the chosen brand supply chain's ethical use of labour and to determine that they operate on that basis within the law. These are reviewed on a regular basis. Our organisation's suppliers also display Ethical Trading Statements on their own websites. Our organisation expects our suppliers and the chosen brand supply chains to have a zero tolerance to slavery and human trafficking.

Our Policies and Procedures

Our organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its own and supplier operations:

• Whistleblowing policy

Our organisation encourages all our colleagues, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our organisation's whistleblowing procedure is designed to make it easy for our colleagues to make disclosures, without fear of retaliation

• Employee code of conduct

Our organisation's code makes clear to colleagues the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain

• Supplier code of conduct

Our organisation is committed to ensuring that our suppliers and chosen brand supply chains adhere to the highest standards of ethics. Suppliers and their supply chains are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, act ethically and within the law in their use of labour. We work with suppliers to ensure that they and the chosen brand supply chains meet the standards of the code and improve their worker’s working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship

• Recruitment

All of our organisation's employees are employed directly through our own HR Department and Hiring Managers. All interviewing, screening and assessing is carried out internally. Our organisation carries out its own checks to ensure that all potential employees have the legal right to work in the UK and that we adhere to all relevant employment legislation

Due Diligence Process

Our organisation undertakes due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence process and reviews include mapping suppliers and chosen brand supply chains broadly to assess particular product or geographical risks of modern slavery and human trafficking:

• Our organisation undertakes vetting of suppliers and chosen brand supply chains, which includes compliance in general, but evaluating modern slavery and human trafficking in particular

• Our organisation places particular reliance on the certifications and trade bodies such as SEDEX, WRAP, Fairwear Foundation and Fair Labor Association of which the represented brand supply chains of our suppliers are members, reviewing on an annual basis all aspects of the afore-mentioned supply chains

• Our organisation asks each of our suppliers to provide us with an Ethical Trading Statement for each chosen brand supply chain

• Our organisation encourages our suppliers to take steps to improve substandard chosen brand supply chain practices. This includes requiring them to implement action plans focused on human rights in general, and slavery and human trafficking in particular

• Our organisation invokes sanctions against suppliers and chosen brand supply chains that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business
relationship if deemed necessary

• Our organisation has systems in place to encourage people to report any concerns and to protect whistleblowers

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Performance indicators

Our organisation has reviewed our key performance indicators (KPls). As a result, we are continuing to review our existing supply chains.

Training

Our organisation encourages all supplier colleagues working within supply chain management and relevant roles to undertake training on how to assess the risk of slavery and human trafficking and what should be done if this activity is suspected.

Monitoring

As well as training our colleagues, our organisaion has raised awareness of modern slavery issues by putting up posters across our premises on notice boards that are accessible to all. The posters explain to colleagues:

• The basic principles of the Modern Slavery Act 2015

• How employees can identify and prevent slavery and human trafficking

• What colleagues can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation

In the last year, our organisation has not received any specific complaints about our suppliers or chosen brand supply chains with regard to Modern Slavery and Ethical Sourcing. Individuals are encouraged to raise concerns internally to their Line Manager or HR.