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Victoria Plum Limited (Trading as VictoriaPlum.com)

MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR ENDED 2019 ISSUED PURSUANT TO SECTION 54 OF THE MODERN SLAVERY ACT 2015

VictoriaPlum.com is an online specialist bathroom retailer, based in Hull and employing c. 280 staff across its head office, warehousing and regional distribution hubs. We do not operate any other business outside of this environment and we sell our products to just the UK market.

We have a supply chain which sources bathroom related product from the UK, Europe and the Far East. This encompasses approximately 70 supply partners. As part of the UK’s retail sector we have long been committed to protecting and improving the rights, working conditions and well-being of the people who work for us directly and indirectly through our supply chain. We recognise modern forms of slavery can be very difficult to detect and we must therefore be diligent in our approach to understanding where the potential risks could be present.

In line with our own values, policies and processes, we operate a zero-tolerance approach to slavery and remain committed to tackling this type of human rights abuse through the effective due diligence and risk assessment of our supply chains.

OUR POLICIES

We are absolutely committed to ensuring our supply chain is free from slavery and human trafficking and that our partners manage in a way that is compliant to all applicable human rights, employment and environmental requirements, both on a local and national basis.

We utilise the following policies through our supply chain (delivered via a Vendor Compliance Document)

  • Supplier Code of Conduct
  • Responsible Sourcing Policy
  • Environmental Policy
  • Health and Safety Policy

We have a number of internal policies to ensure we conduct business in an ethical and transparent manner. We operate robust recruitment policies, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. These requirements extend to 3rd party providers. Our internal policies include, but are not limited to:

  • Employee Code of Conduct
  • Whistleblowing Policy
  • Recruitment and Agency workers policy
  • Anti-Bribery and Corruption Policy
  • Health and Safety Policy

These policies clearly outline the expectation and potential outcomes of intervention should a policy be breached. Any reporting will be fully investigated, and appropriate remedial actions taken. This may include notifying statutory or legal entities as appropriate.

DUE DILIGENCE PROCESSES

We enjoy well-established and stable working relationships with our key suppliers in all our sourcing territories and we have achieved full support to our approach. All goods are manufactured in modern purpose-built factories with up to date approaches to corporate, social and environmental matters.

We conduct regular supplier audits to ensure alignment to local laws, standards set out by the International Labour Organisation, the Modern Slavery Act and our internal policies and standards, which include:

  • Clear obligations on suppliers to comply and implement controls to prevent Modern Slavery;
  • Ensuring all employment shall be voluntary;
  • Provision of an employment contract confirming the employee's right to leave work and the ability to terminate employment upon expiry of reasonable notice.

We may terminate a contract at any time should any instances of modern slavery come to light.

We monitor and review data published in slavery advisor resources to identify potential or increased slavery risks presented by any new region where we may look to source from. We can then tailor our audit process to increase the interrogation level around employment, slavery and general working practices.

An example of such a resource is https://www.globalslaveryindex.org.

TRAINING AND EFFECTIVENESS OF VICTORIAPLUM.COM ANTI SLAVERY MEASURES

Training has been completed by all employees in our buying department to ensure a high level of awareness and understanding of the risks of modern slavery and human trafficking in our supply chain.

We do recognise the need to continually develop additional tools to effectively engage our suppliers, particularly those in high risk countries. As this development progresses and matures we will build key performance measures to help track the effectiveness of our audit processes. We will also monitor and learn from industry best practices as they develop and consult with external stakeholders as appropriate to help strengthen our efforts.

Everyone within the business is encouraged to report any concerns regarding slavery and /or human trafficking in accordance with our whistleblowing policy.

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our anti-slavery and human trafficking statement for the financial year ending February 2019. It sets out the steps taken, and those which Victoria Plum Limited intends to take in the future to prevent modern slavery and human trafficking in our supply chains or in any part of our business.

The statement has been approved by our Board of Directors who will review and update it on an annual basis.

Paul McClenaghan
CEO
VictoriaPlum.com
March 2019

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