MODERN SLAVERY POLICY
Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This statement relates to actions and activities during the year 2023 to 2024.
EIC Direct ltd takes a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all of our business dealings and relationships. As a result, EIC Direct ltd has committed to our Modern Slavery Act Statement. This reflects our commitment to ensuring transparency in our own operations and in our approach to combating modern slavery throughout our supply chains, in accordance with our disclosure obligations under the Modern Slavery Act.
We expect the same high standards from all of our contractors, suppliers, and other business partners, and we will continue to include specific prohibitions against the use of forced, compulsory, or trafficked labour, as well as anyone held in slavery or servitude, whether adults or children, in our contracting processes, and we expect our suppliers to hold their own suppliers to the same high standards.
This statement applies to all individuals who work for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
Our business and structure
EIC Direct ltd is a distribution business in the wholesale of goods in the rewards and incentives market.
EIC Direct ltd has legal presence and operates in the following countries:
- United Kingdom
- Ireland
- EU
Commitment
EIC Direct ltd acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. We understand that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
EIC Direct ltd does not enter into business with any other organization, in the United Kingdom or abroad, that knowingly supports or is found to involve itself in slavery, servitude, and forced or compulsory labour.
Our supply chains
EIC Direct ltd works with companies and institutions we trust to help us achieve our goals. We’ve spent years building a network of suppliers, clients, and programs that share our views and practices. What underpins it is our shared values, ways of working, and commitment to our clients and colleagues.
Our supply chain operates across a variety of industries and jurisdictions. We are acutely aware that our supply chain covers multiple countries and suppliers, and we have developed the approach outlined in “Risk assessment and due diligence processes” in response to that.
Policies in relation to slavery and human trafficking
We are a values-led organization with a suite of internal and external policies that set out our expectations and requirements. We monitor performance and take appropriate action where we believe suppliers, partners, or colleagues do not meet our high standards.
Our Code of Conduct
This provides clarity on the high standards we expect from everyone who works at, or with, EIC Direct ltd. It provides a framework to ensure we do the right thing; our commitments include respecting human rights and requiring everyone we work with to operate responsibly. It serves as a guide to help us make good decisions that will ultimately demonstrate that we are trusted partners, to each other and to our customers because we do these things fairly, legally, and with integrity.
Failure to comply with this Code, and the associated policies, can result in disciplinary action, including termination, depending on the severity and impact of the action.
Each country we operate in has its own laws and regulations in relation to these topics. We abide by these (including compliance with minimum earning and employee rights legislation) when reviewing and acting on any breaches or potential breaches of this code.
EIC Direct ltd core values
EIC Direct ltd’s core values make clear to employees the actions and behaviours expected of them when working for EIC Direct ltd. Our values were developed through conversations with our people and are lived in everything we do through
We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain.
Whistleblowing Policy
EIC Direct ltd encourages open communication, feedback and discussion about any matter of importance. EIC Direct ltd asks all of its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of EIC Direct ltd. This would include any circumstances that may give rise to an enhanced risk of slavery or human trafficking. EIC Direct ltd’s whistleblowing procedure is designed to make it easy for workers to make confidential disclosures, without fear of retaliation.
Risk assessment and due diligence processes
EIC Direct ltd is committed to ensuring that we and our supply chains are free from slavery and human trafficking and that the necessary due diligence is undertaken to provide assurance of this. The Company Directors have overall responsibility for this area of compliance.
Although our analysis of how modern slavery and human trafficking affect our organization has concluded that this remains a low risk, we are acutely aware that this is an important area that should always be considered as we run our business.
We set out below the due diligence processes EIC Direct ltd has put in place to prevent the organization from being involved with modern slavery in any way.
EIC Direct ltd partners
We work with companies and institutions we trust to help our clients achieve their goals. We’ve spent years building an ecosystem of technology, knowledge, business, and talent partners. What underpins it is our shared values and ways of working. We build long-standing relationships with local suppliers and make clear our expectations of business behaviour.
Part of our commitment to continual improvement includes working with partners and suppliers, to drive their compliance with the Act through our Code of Conduct.
Procurement
EIC Direct ltd’s procurement practices incorporate processes to identify and mitigate the risk of our major suppliers’ non-compliance with the requirements of the Modern Slavery Act 2015.
Invitations to tender require suppliers to confirm their compliance with the Act and to provide a formal statement to this effect. If it is considered necessary, they will be asked to provide further assurances.
Depending on the type of goods and services being provided and the origin of the supply chains involved, further due diligence may be undertaken if necessary.
Effectiveness and assurance
EIC Direct ltd does not tolerate slavery and human trafficking in our supply chains and will terminate our relationship with any partners or suppliers where there was evidence of their failure to comply with the Modern Slavery Act 2015.
EIC Direct ltd is committed to a plan of continual improvement during 2023. There has been no evidence of any previous connection with modern slavery or human trafficking, either within the organization or through any of our partners, suppliers, or sub-contractors.
Although it is important to undertake due diligence with our partners and suppliers, we do not consider it necessary to set any performance indicators for this area. We have so far not needed to take any action against a partner or supplier. We will, however, continue to keep this under review.
Training on modern slavery and trafficking
Our people play a key role in mitigating risk within our business and supply chains, and we recognize that appropriate and targeted training is essential. Staff who work in the areas likely to be affected by modern slavery will have access to training in our procedures for ensuring that EIC Direct ltd and its supply chains remain free of slavery and human trafficking.
This statement has been approved by the Operations Manager and Company Director : Jan 2023