Modern Slavery and Human Trafficking Statement
Introduction
This statement applies to PenCarrie Limited and PenCarrie Holdings Limited (referred to in this statement as PenCarrie) and sets out the actions undertaken to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 31 December 2022 to 29 December 2023.
Our organisation
We, PenCarrie Limited, the trading business and wholly owned subsidiary of PenCarrie Holdings Limited (which does not trade), are a leading B2B wholesale clothing and accessory distributor for decoration and resale.
We currently operate at the following location:
PenCarrie House
South View Estate
Willand
Devon
EX15 2QW
Phone: 01884 829610
Freephone: 0800 252248
ROI Freephone: 1-800-771-625
Email: [email protected]
Website: www.pencarrie.com
Our supply chain
Our supply chain includes a number of brand suppliers who manage the sourcing and manufacture of promotional and corporate clothing and accessory products. PenCarrie’s purchases from brand suppliers based in the UK, mainland Europe, and the USA incorporate the vast majority of our supply chain. All product items purchased by PenCarrie are for distribution to garment decorators and other on-sellers, primarily in the UK.
We expect our entire supply chain to have a zero-tolerance approach to slavery and human trafficking. Our product suppliers have to demonstrate that they use labour ethically and within the law. Where they cannot demonstrate this standard, we will look to end the business relationship.
The CEO, Mark Campbell, and Executive Chair, Nicci Gratwicke, are ultimately responsible for compliance in our company departments and for the supplier relationships.
You can access the Ethical Trading Policies for the brands that have shared them with us in the Brand Library in our Resources section here.
Our policies and procedures
We have the following policies and procedures in place to identify modern slavery risks and prevent slavery and human trafficking in our operations:
- Modern Slavery Policy: This policy defines our approach to preventing modern slavery and human trafficking in our business and its associated supply chains. It applies to all team members engaged by PenCarrie including temporary and agency workers as well as suppliers, contractors and business partners. Training is provided to all relevant team members to raise awareness and ensure compliance.
- Whistleblowing Policy: We encourage all of our workers, customers and other business partners to report any concerns they have about our activities and supply chains. This includes anything that may increase the risk of slavery or human trafficking. Our Whistleblowing Policy is designed to make it easy for individuals to make disclosures without fear of reprisal. Training is provided to all relevant team members.
Our due diligence
We have the following due diligence processes in place to help make sure we are tackling slavery and human trafficking risks in our business and supply chains:
- We always make written enquiries when considering new apparel product suppliers. We also regularly review our existing product suppliers’ policies on modern slavery and other areas of their operations.
- We place particular reliance on the certifications and trade bodies such as SEDEX, WRAP and Fair Wear Foundation of which the brands we represent are members. They are responsible for auditing the brands’ supply chains.
- Each of our brands supplies us with an official Ethical Trading Statement, which can be found on the individual brand pages on our website. • Where possible, we build long-standing relationships with our suppliers, and we make clear our expectations of business behaviour.
- We expect each supplier in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. Unfortunately, it’s not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain.
- We conduct reviews with direct product suppliers to understand the level of communication and personal contact with the next link in the supply chain. We assess their understanding of, and compliance with, our expectations of business behaviour.
- We have a policy and processes in place to encourage people to report any concerns and to protect whistle-blowers.
- We regularly review recruitment and payroll systems to ensure our recruitment and employment practices remain legally compliant, including the processing for agency and contract staff.
Our monitoring
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and within our business, we provide regular training to relevant team members within our organisation. All Directors have been fully briefed on the subject.
In the last year, we have not received any specific complaints about our supply chain with regards to Modern Slavery and Ethical Sourcing.
However, we continue to regularly liaise with our key suppliers, in particular the brands who are responsible for the manufacture and supply of garments, on relevant topics and areas of potential concern. In the last 12 months, we have specifically addressed:
- the sourcing of cotton produced in the Xinjiang region of China.
- the production of garments where human rights of the workforce in particular Uyghur Muslims are not maintained or respected.
In respect of the above, we obtained confirmation from our clothing suppliers that their supply chains were not dependent on, or involving, any products, raw materials or labour from this region.
Plans for progress
Over the coming year, we intend to:
- Continue and extend our regular training programme.
- Develop our Modern Slavery risk assessment processes further to incorporate:
- Relevant risk assessments / areas where the business may be potentially exposed.
- Scheduling an action plan based on risk prioritisation and forming a working group to enable the Company to instigate targeted actions.
- Extending the due diligence across our wider supply chain.
- Formalise our collection of relevant information from our supply chain to reinforce the ‘one-up’ due diligence.
Board approval
This statement has been approved by our Board of Directors in September 2024, who will review and update it annually.
CEO's signature:
Mark Campbell
September 2024
