Ethical Sourcing, Anti-Slavery and Human Trafficking Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Toiletry Express Ltd has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in its own business or in any of its supply chains.

Toiletry Express Ltd is a UK-based wholesale supplier of toiletries, hygiene kits and personal care products to organisations including NHS Trusts, local authorities, charities, food banks, hospitality businesses and resellers, in the United Kingdom and overseas. Our annual turnover is below the threshold at which section 54 of the Modern Slavery Act 2015 requires a published statement. We publish this policy voluntarily, because our customers are entitled to know where our products come from and the standards under which they are made.

We expect the same high standards from all of our suppliers, contractors and other business partners. As part of our supplier relationships we require confirmation that no forced, compulsory or trafficked labour, and no person held in slavery or servitude, whether adult or child, is used in the manufacture of the goods we buy, and we expect our suppliers to hold their own suppliers to the same standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, the Director, agency and temporary workers, packing staff, contractors, agents and business partners. It applies equally to every supplier from whom Toiletry Express Ltd purchases goods or services. This policy does not form part of any employee's contract of employment and we may amend it at any time.

Toiletry Express Ltd holds its own stock at its premises in Sutton, Surrey. Hygiene kits and patient packs are packed on those premises by our own team. Our supply chain has three principal elements:

In addition to the prohibition of modern slavery, Toiletry Express Ltd applies the following ethical standards to the products it supplies:

• We do not supply any products tested on animals. All products we supply are cruelty-free.
• Our ranges are vegan-friendly.
• Our own-brand products are manufactured to EU and UK quality standards and comply with UK cosmetics safety and labelling requirements.
• Ethical and environmental claims for any product are checked against manufacturer documentation before they are published. We do not make claims we cannot evidence.

We require every supplier of goods to Toiletry Express Ltd to uphold recognised international labour standards, including:

• No forced, bonded, compulsory or involuntary labour of any kind.
• No child labour.
• No recruitment fees charged to workers, no retention of identity documents, and freedom for workers to leave their employment with reasonable notice.
• Wages, working hours and health and safety that comply, as a minimum, with the law of the country of manufacture.
• Freedom of movement and association.
• No discrimination, harassment or inhumane treatment of workers.
• Transparency regarding their own sub-suppliers where we request it.

We recognise that the manufacture of consumer goods is an area of scrutiny for modern slavery risk. Our due diligence is proportionate to the size of our business and the nature of our supply chain, and consists of the following:

The Director has overall responsibility for ensuring that this policy complies with our legal and ethical obligations and that all those under our control comply with it. The Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and reviewing internal controls to ensure they are effective in countering modern slavery. Comments, suggestions and queries about this policy are encouraged and should be addressed to the Director.

Everyone working for Toiletry Express Ltd must read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Any person who believes or suspects that a breach of this policy has occurred, or may occur, must notify the Director as soon as possible.

We aim to encourage openness and will support anyone who raises a concern in good faith under this policy, even if they turn out to be mistaken. No one will suffer any detrimental treatment as a result of reporting in good faith a suspicion that modern slavery of any form is or may be taking place in any part of our business or supply chains.

This policy is published on our websites and forms part of the induction of all staff who work for us, including packing staff. Our zero-tolerance approach to modern slavery is communicated to all suppliers at the outset of our business relationship with them and reinforced as appropriate thereafter.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with any supplier, contractor or other organisation working on our behalf if they breach this policy, and a confirmed instance of modern slavery in a supplier's operations will end our relationship with that supplier.

This policy is reviewed annually by the Director, or sooner if there is a material change to our business or supply chain.