This is particularly in regard to conditions of employment, wages and benefits, child labour, human trafficking, as well as the sourcing of raw materials, environmental considerations and health and safety matters.

To ensure that our policies and standards are communicated as effectively as possible, we follow a dual strategy as follows:

  • The first part of our strategy is our ‘Supplier Annual Compliance Declaration’. This is applicable to all our suppliers;
  • The second part is that we have established a specific Code of Conduct. This primarily applies to the organisations that supply with the goods we sell. These suppliers are the ones that deal mainly with our Global Sourcing Operation.

This approach allows us in the first instance to set general standards across the whole of our business while at the same time enables us to require additional information from our supply chain in areas where we have assessed that there may be increased risks.

The first part of our Strategy

To implement this strategy each year, we will send out our ‘Supplier Annual Compliance Declaration’. This requires our suppliers to confirm that in respect of the legislation listed below, they have not been convicted of any offence and/or are not currently under investigation for any offence.

The applicable legislation is:

  1. The Data Protection Act 2018 (as may be amended, updated, or replaced from time to time);
    (the Bribery Act 2010 (or any other anti-bribery and corruption legislation applicable to their business);
  2. The Modern Slavery Act 2015 (or any offence involving slavery or human trafficking);
  3. The Criminal Finances Act 2017;
  4. Regulation (EU) 2017/821 (the Conflict Minerals Regulations 2017) in regard to supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold (3TG) originating from conflict-affected and high-risk areas and/or
  5. Any Sanctions Laws or Regulations;

The second part of our Strategy

To implement this part of our strategy, we carry out risk assessments of our goods for resale supply chain and thereafter implement our Code of Conduct where deemed necessary. This policy set outs our principles of trading and are based on international standards including the International Labour Organisation (ILO) conventions and recommendations, which in turn are based on the United Nations (UN) Declaration of Human Rights and Convention on Rights of the Child. This Code of Conduct considers and applies to issues relating to: age; conditions of employment; wages and benefits; health and safety; environmental policy. It requires our suppliers to provide us with information in these areas and provides a framework for us to carry out audits and factory visits to enable us to verify the information provided. Compliance with our Code of Conduct is a condition of us trading (or continuing to trade) with our suppliers of goods for resale.

Among other things our Code of Conduct states that:

  • we oppose the exploitation of workers and we will not tolerate forced labour, or labour which involves physical, verbal or psychological harassment, or intimidation of any kind. Workers must have the right to form and join organisations to facilitate freedom of association and collective bargaining and all workers must have written employment details, which must pay due regard to the welfare of individuals;
  • we support fair and reasonable rewards for workers. Wages should reflect local norms and should meet or exceed any legal minimum wage levels. Wages must be paid in cash, or by cheque or bank transfers. Workers must receive full written details of their pay. While local and cultural differences will be observed, workers must not be expected to work in excess of 60 hours per week on a regular basis, including overtime. Any overtime must be voluntary. Workers will be entitled to at least one day off in seven. Individual workers have the right to choose not to take their days off should they so wish;
  • we oppose the exploitation of children and young people and, in addition to national employment laws, we require of our suppliers that children under the age of 14 years, or those below the age for completion of compulsory schooling, must not be employed full-time;
  • we will not accept human trafficking in our business or supply chain. The recruitment, provision or importation of a person for labour services must not be undertaken through the use of force, coercion, abduction or fraud. We will not permit the exploitation of, or discrimination against, any vulnerable group;
  • we require that appropriate health and safety training, including training in fire safety, be provided for all people in all working areas. All activities must be carried out under conditions that have proper and adequate regard for the health and safety of those involved. Management arrangements must be in place to detect, avoid and respond to potential threats to health and safety; and,
  • we promote these ethical business objectives and work with the organisations in our supply chain to:
    • minimise the environmental impact of our operations;
    • prevent the use of conflict minerals particularly, tungsten, tantalum, tin, and gold (“3TG”) by manufacturers; and
    • encourage the consideration of social issues in business.


Goods Not for Re-Sale (Terms and Conditions)  PDF

Goods for Re-Sale (Terms and Conditions) PDF