This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 by Flavour Warehouse Holdings Limited.
It aims to set out the 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 own business and our supply chains. This statement relates to actions and activities during the financial year 30 November 2019.
As a leading international e-liquid company, we distribute our own range of e-liquids. We also offer an OEM service for many well-known brands and sell our products through our own retail outlets, online through our own websites and through a chain of resellers, distributors, partners and independent retail stores. Located in the UK, we operate internationally across over 80 countries.
We are 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. We are committed to taking a robust approach that will evolve as our business grows in complexity and size.
The directors of the Company and the HR department are responsible for putting in place and monitoring appropriate policies and procedures to support our commitment and we investigate all known or suspected instances of slavery or human trafficking.
We currently have the following policies to support our approach and commitment to the identification of modern slavery risk:
Employee Statement – our internal statement makes clear to all employees, including officers, agency workers, contractors and consultants, our commitment and the actions and behaviour expected of them to support the prevention, detection and reporting of modern slavery in any part of our business or supply chains.
Whistleblowing policy – we encourage all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns should refer to the Employee Handbook in the first instance.
Recruitment – The Company conducts employment checks on all new employees, including right to work in the UK.
Agency Workers – we use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency.
Due Diligence – when taking on new suppliers, we undertake checks to evaluate modern slavery and human trafficking risks for each new supplier. This will include:
A general review of the supplier and location to assess geographical and product risk of modern slavery or human trafficking.
Understanding the supply chain and its complexity.
Where possible, using tools to check labour standards, general compliance etc for new suppliers.
Reviewing existing suppliers and imposing sanctions or restrictions where we believe there is a high risk of violation.
We are currently increasing internal awareness across relevant departments of the requirements of the Modern Slavery Act to ensure that we continue to improve our efforts in preventing the occurrence of modern slavery or human trafficking in our operations and supply chain.
This statement is approved by our Board of Directors and will be reviewed annually.