Modern Slavery Statement
SMARTBOX GROUP UK LTD - MODERN SLAVERY STATEMENT (FYE APRIL 2019)
Smartbox Group UK Ltd – Our Business
Smartbox Group UK Ltd is UK’s leading provider of experience days and gift experiences in the ecommerce gift experience sector. Smartbox Group UK Ltd (“Buyagift”) issues gift vouchers to its customers via its website. Smartbox Group UK Ltd, has its head office at Hertfordshire, United Kingdom employing over 120 employees and operate in the United Kingdom.
We are a part of the Smartbox Group, the European No 1 in experience gifts and has its head office in Dublin, Ireland. Smartbox operates in 10 European countries (France, Spain, Italy, Belgium, Denmark, Netherlands, Sweden, Switzerland, UK and Ireland).
Our Statement on modern slavery and human trafficking
Smartbox Group UK Ltd is opposed to slavery, servitude, compulsory or forced labour and human trafficking (together, "Modern Slavery"). Smartbox Group UK Ltd is committed to ensuring that no Modern Slavery takes place in any part of the business which Smartbox Group UK Ltd controls, or within its supply chain.
Modern Slavery risk in the context of Smartbox Group UK Ltd's business
- In all jurisdictions in which Smartbox Group UK Ltd operates, its corporate activities are concerned with the provision of online experiences to customers and ancillary or related services. Smartbox Group UK Ltd typically provides those services via locally incorporated and managed companies. None of the jurisdictions in which Smartbox Group UK Ltd provides its services ranks highly on the Global Slavery Index www.globalslaveryindex.org/findings/.
- Smartbox Group UK Ltd does not employ significant numbers of agency workers or contractors except for peak trading periods during Christmas for example. The agency and contract workers are treated equally as our full time and permanent employees.
- All employees, contractors and agency workers are required to adhere to the Policy (defined below). We aim to provide our employees with guidance and actively encourage them on how to report slavery concerns using our Code of Conduct and Whistleblowing Policy.
Modern Slavery risk in the context of Smartbox Group UK Ltd's supply chain
- Smartbox Group UK Ltd is committed to ensure ethical compliance, to act with integrity in all our business relationships and to eradicate forced labour and human trafficking from within its supply chain
- Our supply chain includes suppliers providing experience days in relation to the products on our website, professional service providers, consultants in the areas of legal, finance and marketing, utility providers, cleaning and waste management, IT equipment, office stationery supply companies, food and beverage for the consumption of employee’s and guests. We take care to ensure that our suppliers do not fall under the high-ranking slavery index.
Response to Modern Slavery risks
- Smartbox Group UK Ltd has no cause to suspect that Modern Slavery is currently present within its business or supply chain, nor any evidence that it has been present in the past.
- Smartbox Group UK Ltd:
- has in place a Code of Conduct and whistleblowing policy which obliges employees and contractors to report illegal or unethical behaviour;
- has adopted a straightforward Anti-Modern Slavery Policy (the "Policy"), which is primarily focused on obliging employees and contractors to report Modern Slavery, ensuring that all existing and newly inducted employees and contractors are made aware of the signs of Modern Slavery and what to do if it is detected in Smartbox Group UK Ltd's business or supply chain. Smartbox Group UK Ltd will keep this policy under review and update it periodically in line with UK Home Office guidance;
- will ensure that responsibility for continuing compliance with the Policy rests with a senior employee of Smartbox Group UK Ltd;
- engages in regular dialogue with suppliers of services, and in particular those involving any element of outsourced labour, and will adopt a risk-based approach to evaluating the risk of Modern Slavery with regard to existing suppliers and supply chains; and
- requires material suppliers of goods and services to undertake to comply with applicable laws, and where appropriate will include contractual clauses aimed at ensuring suppliers are prohibited from encouraging or engaging in Modern Slavery. Smartbox Group UK Ltd will require new suppliers (or, where agreements are being renewed, existing suppliers) to adhere to them, and will conduct supply chain audits and ethical due diligence on new suppliers where any material risk of Modern Slavery has been identified.
Responsibility and Due Diligence
- The Board and senior management of Smartbox Group UK Ltd will take responsibility for implementing this statement and provide adequate resources and investment to ensure that Modern Slavery is not taking place within the business or its supply chains. We have developed a Code of Conduct through which we aim to achieve best practice. We will aim for all our supply chain to adhere to our Code of Conduct in future years.
- We will take steps to ensure due diligence
- If we find a supplier is non-compliant with our policies or code of conduct or provides inadequate information, we will work with them to improve their performance. In cases of persistent non-compliance, we may consider terminating the business relationship as soon as possible.
- Employees who do not follow the policy will be given the opportunity to receive additional training, if their behaviour does not improve, they may face disciplinary action.
- We aim to take steps to track and report in future statements on key performance indicators to ensure that our suppliers are compliant, training our employees who will be involved in procurement process and will include results of our risk analysis exercise.
Approval & publication
- This statement has been approved by the Board in accordance with the requirements of section 54(1) of the Modern Slavery Act 2015, which applies to Smartbox Group UK Ltd for the financial year ending 30 April 2019.
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