This statement applies to The B.ICONIC Group and all of its subsidiary companies (referred to in this statement as ‘The Group’ and all subsidiaries of B.ICONIC Limited (as per Appendix 1) and sets out the Group’s actions to understand all potential slavery risks related to its businesses and to put in place steps that are aimed at ensuring that there is no modern slavery or human trafficking in its own businesses and its supply chains. The information included in the statement refers to the financial year 2018/2019.
B) ORGANISATIONAL STRUCTURE
The Group has business locations in London and the greater London area, Milton Keynes and a number of business premises across the Republic of Ireland and is controlled by an advisory board and the CEO of the group.
The main activities of the group are the sale of high technology products and accessories. The goods are sold in stores, on-line and to other business customers and companies, educational establishments and the public sector. Demand for our products is consistently high throughout the year and is therefore not seasonal.
The labour supplied to the Group in pursuance of its operation is carried out in the UK and the Republic of Ireland.
The Group considers that modern slavery encompasses:
- Human trafficking;
- Forced work, through mental or physical threat;
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
- Being dehumanised, treated as a commodity or being bought or sold as property;
- Being physically constrained or to have restriction placed on freedom of movement.
The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and Republic of Ireland and in many cases exceeds these.
E) SUPPLY CHAINS
In order to fulfil its activities, the Group’s main supply chains include those related to supply of high end technological products and accessories from various suppliers in the UK, USA, EU and China. We understand that the Group’s first tier suppliers are intermediary traders and therefore have further contractual relationships with lower tier suppliers.
F) POTENTIAL EXPOSURE
The Group considers its main exposure to the risk of slavery and human trafficking to exist in its technology and accessory supply chains because they involve the provision of labour in a country where protection against breaches of human rights may be limited.
In general, the Group considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
We require all suppliers to sign up to ethical standards and confirm that no person under the age of 15 years has been or will be involved in any capacity (whether paid or unpaid) in the creation, manufacture, packaging, distribution or supply of the Goods unless an International Labour Organisation (ILO) Exemption applies. In the event that local labour laws or the age for compulsory education is greater than 15, this minimum age shall apply instead. All our suppliers also confirm that no person under the age of 18 have been involved at night or in any hazardous conditions in any capacity (whether paid or unpaid) in the creation, manufacture, packaging, distribution or supply of the Goods and where any individuals (over 18) are involved in any such hazardous conditions, appropriate safety procedures are in place.
We also require suppliers to confirm that they comply with:
- All applicable legislation relating to its treatment of all individuals involved in any capacity (whether paid or unpaid) in the creation, manufacture, distribution or supply of the Goods, including, without limitation the Modern Slavery Act 2015 and
- B.ICONIC’s Code of Conduct as updated from time to time and available on all our websites under “Ethical Requirements”. We reserve the right to inspect the Goods and on reasonable notice inspect our suppliers’ premises and those of any approved manufacturer of the Goods in order to inspect and test any of the Goods and the methods of manufacture, packaging and compliance with the Ethical Requirements.
The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
The Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Group has taken the following steps to ensure that modern slavery is not taking place:
Employee Code of Conduct
This code of conduct makes it clear to employees the actions and behaviours expected of them when representing the Group. The Group strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
We have a robust recruitment policy which includes “eligibility to work in Ireland, the UK and the EU’ checks to safeguard against Human Trafficking or individuals being forced to work against their will.
We are in the process of reviewing all supplier contracts to include termination powers in the event that the supplier is, or is suspected of being, involved in modern slavery or unethical trading. The deadline for completion of this is September 2019.
The Group will be introducing new measures to assess and manage the risk across
our supply chain on an on-going basis.
Any actions taken will demonstrate that a zero tolerance policy towards modern slavery is embedded in our culture.
H) KEY PERFORMANCE INDICATORS
The Group will set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Group or its supply chains.
- Regular site visits to suppliers
- Completion of questionnaires by suppliers
We aim to have this in place by September 2018.
The Group has the following policies which further define its stance on Modern Slavery and Ethical Trading (see point G above)
- Recruitment policy
- Employee Code of Conduct
The Group provides the following training to staff to effectively implement its stance on
Modern Slavery and Ethical Trading:
All our policies (code of conduct, Modern Slavery Statement and Ethical Trading) are
currently made available through our Employee Handbooks and on-line in Bizimply and
on Teams. We will be providing further education to inform and educate our employees
about Modern Slavery, Human Trafficking and Ethical Trading on an on-going basis.
K) COMPLIANCE OFFICER
The Group has a People Operations Manager, to whom all concerns regarding modern
slavery or unethical trading should be addressed, and who will then undertake relevant
action with regards to the Group’s obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015
will be reviewed for each financial year.
L) BOARD APPROVAL
This statement has been approved by the Group’s advisory Board and its CEO on 04/06/2019 and will be reviewed and updated on an annual basis.
Ciaran McCormack, CEO, B.ICONIC Group