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Modern Slavery Act

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2023

 

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

 

At Edgar Brothers we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2023.

 

Our business and supply chains

Edgar Brothers is an importer and wholesaler of firearms, ammunition and associated equipment, with our head office in Macclesfield. We supply to outdoor and shooting sports retailers and the Police and Military, along with selling a range of non-licensed products to end-users through our online shop. Our suppliers are based throughout the world.

 

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.

 

We haven't been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

 

Risk assessment

Over the next 12 month period we shall conduct a risk assessment of our supply chain taking into account:

  • The risk profile of individual countries based on the Global Slavery Index
  • The business services rendered by the suppliers
  • The presence of vulnerable demographic groups
  • A news analysis and the insights of labour and human rights groups

This assessment will determine our response and the risk controls that we implement.

 

Policies

Edgar Brothers operates the following policies for identifying and preventing slavery and human trafficking in our operations:

  • Whistleblowing Policy - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation.
  • Employee Code of Conduct - our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
  • Supplier Code of Conduct - we have updated our Supplier Code of Conduct to make explicit reference to slavery and human trafficking.

 

Supplier due diligence

Edgar Brothers conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes: 

  • Assessing risks in the provision of particular services
  • Carrying out a desktop audit of suppliers, and their health and safety standards, labour relations and employee contracts
  • Requiring improvements to substandard employment practices
  • Sanctioning suppliers that fail to improve their performance in line with our requirements

 

We require all suppliers to attest that: 

  • They don't use any form of forced, compulsory or slave labour
  • Their employees work voluntarily and are entitled to leave work
  • They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
  • They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons
  • They don't require employees to surrender their passports or work permits as a condition of employment

 

Awareness

Edgar Brothers has raised awareness of modern slavery issues by displaying posters across our offices and warehouse, and sending a companywide email that is focused specifically on modern slavery to all our staff, which explains: 

  • Our commitment in the fight against modern slavery
  • Red flags for potential cases of slavery or human trafficking
  • How employees should report suspicions of modern slavery

 

Training

In addition to the awareness programme, Edgar Brothers has rolled out a fresh e-learning course to all employees, which covers: 

  • Various forms of modern slavery in which people can be held and exploited
  • The size of the problem and the risk to our organisation
  • How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
  • How employees should respond if they suspect slavery or human trafficking
  • What external help is available for the victims of slavery
  • What steps Edgar Brothers will take if a supplier fails to implement anti-slavery policies or controls
  • An attestation from employees that they will abide by Edgar Brothers Modern slavery policy

 

Measuring how we're performing

Edgar Brothers has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:

  • How many employees have completed mandatory training?
  • How many suppliers have filled out our supplier questionnaire?
  • How many suppliers have rolled out an awareness and training programme that is equivalent to ours?
  • How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?

 

This statement covers 1 January 2023 to 31 December 2023 and has been approved by the board of Edgar Brothers at the board meeting on 31 January 2023