Modern Slavery Act 2015 Statement
This statement sets out the steps that The Festive Decorators UK have taken to ensure that slavery and human trafficking is not taking place in any of our supply chains or part of our business.
Slavery and human trafficking are abuses of a person’s freedoms and rights. We are totally opposed to such abuses in our direct operations, our indirect operations and our supply chain as a whole. We are proud of the many steps we have taken, and will continue to take, to ensure that slavery and human trafficking do not take place in any part of our business or our supply chains.
Meaning of slavery and human trafficking
Our understanding of slavery and human trafficking is based on the definitions set out in the Modern Slavery Act 2015 and is guided by the UN Universal Declaration of Human Rights and the conventions of the International Labour Organisation (ILO) particularly relating to forced or compulsory labour.
We recognise that forced labour as a form of slavery includes debt bondage and the restriction of a person’s freedom of movement whether that be physical, non-physical or, for example, by the withholding of a worker’s identity papers proving eligibility to work within the UK.
Our business and its supply chain
Our core business is the manufacture and installation of Festive lighting and decorations.
With our Corporate Centre located in Liverpool, United Kingdom, and in Dubai. Our operations are predominately office based, some of which include warehousing. We employ 11 full time people year-round at our Liverpool headquarters. We have 5 manufacturing suppliers. These are based in the UK, Spain, Poland, Germany and Taiwan.
In keeping with our commitment to act with integrity in all our business dealings, many of our existing policies are relevant to ensure that there is no slavery or human trafficking in any part of our business or our supply chains.
Our relevant policies include:
- Code of Conduct;
- Global Procurement Policy;
- Fairness at Work Policy;
- Employment Policy;
- Health Protection and Wellbeing Policy;
- Supply Chain Policy
- Product Supply Compliance Policy.
In our Code of Conduct, relevant sections cover ‘Discrimination and Harassment’, ‘Human Rights’ ‘Responsible Procurement and Supplier Partnerships’ and ‘Anti-Illicit Trade’.
Our Code of Conduct sets out the behaviours we expect from employees in their dealings with colleagues, customers, consumers, suppliers, agents, intermediaries, advisers, governments and competitors. All employees and suppliers are expected to act with integrity in accordance with the standards of behaviour set out in the Code of Conduct.
We provide guidance and initial and ongoing training to support employee understanding of expected behaviour, particularly in respect of their business decisions and the Code of Conduct. We encourage employees to raise concerns and we have a Public Interest Disclosure Policy.
We believe in the business benefits brought about by diversity and equal opportunity. We therefore support collective bargaining for our own employees and through our supplier standards.
We actively support employee engagement, representation, dialogue and the ability of an employee to raise potential concerns or grievances. Freedom of association and the right to collective bargaining is a core labour standard that we respect as guided by the International Labour Organization (ILO). We apply our employment practices in line with, and in certain aspects exceeding the requirements of, local legislation in all countries we operate in.
We recognise that we trade and manufacture in a number of countries where human rights are an issue of particular concern. Following periods of new supply chains we always visit and carry out a full audit of this new business. We follow the principles of SA8000 standard to cover a variety of potential issues including child labour, forced labour, health and safety, freedom of association, the right to collective bargaining, discrimination, disciplinary practices, working hours, remuneration, and management systems.
Risk assessment and due diligence
The risk of slavery and human trafficking within our own organisation is substantially avoided and mitigated as a result of strict policies and procedures as well as the oversight built into our business operations and the knowledge and skills of our staff.
We consider that the greatest risk of slavery and human trafficking is in our supply chain where we undertake procurement activities and where operations and managerial oversight are out of our direct control. For the manufacture of our products we procure from factories that manufacture LED Christmas lights, Garlands, Wreaths, Trees, Baubles and ribbon. In addition to the training and awareness provided by our Code of Conduct, we also have supplier standards and specific supplier audits carried out by our head office team in Liverpool during on-site visits.
Our supplier standards address a broad spectrum of working conditions including fair remuneration, working hours, no child labour, respect, non-discrimination and health and safety, as well as freedom from forced labour.
To encourage the flow down of due diligence processes throughout the wider supply chain, we ask our suppliers if they evaluate their suppliers and sub-contractors against our requirements and standards. Answers to these questions are the subject of the annual audits during our site visits as discussed above. This enables us to have greater knowledge of our business partners and leverage to ensure enhanced supplier standards.
We also recognise that there could be a small risk of human trafficking in the distribution and logistics activities that are connected with our business which are out of our control but we are aware they have in fact adopted a policy similar to ours, which is public record.
Effectiveness and performance review
In relation to our own employment practices in the western world, we monitor and review our manufacturing facilities based on the following criteria:-
- Rates of pay are in guidelines locally and meet all legislation in that specific country
- Working hours are adhered to in line with local laws
- Rest breaks and facilities are in line with local laws and meet our expectations of what is acceptable
- Work facilities are clean, well-lit and of good a comfortable working temperature.
- Workers are of a happy demeanour and are fairly treated by management.
- Workers have the right to air their grievances without detrimental consequences.
We take pride in the fact that we are indeed the only company of our kind in the UK that takes such measures to ensure we work in line with The Modern Day Slavery Act and are proactive in not only working within, but surpassing its expectations.