Anti-Slavery and Human Trafficking Statement
This statement sets out Internet Fusion’s action to understand all potential modern slavery risks in relation to its business and to put in place steps aimed at ensuring that there is no slavery or human trafficking in its business and supply chains. The information included in the statement refers to our modern day slavery commitments for the period February 2023-February 2024.
Internet Fusion operates from the United Kingdom shipping to customers around the globe. Our registered office is in London, United Kingdom, with our main operating offices in City of London and Manchester and our distribution centres are in Kettering, Northamptonshire and Venlo, Netherlands. We have over 250 employees across our locations with a proportion who work from their homes in the UK and are classed as remote workers.
The main activity carried out by Internet Fusion is the sale of clothing, footwear and niche sports equipment. We sell goods via our multiple websites and third-party sites. Demand for our products is high throughout the year with a seasonal uplift between October and December.
The majority of our operations are carried out in the United Kingdom in the regions listed above. A small amount of operations are carried out in Europe, at our Venlo based warehouse.
We consider that modern slavery encompasses:
- human trafficking
- forced work, through mental or physical threat
- being owned or controlled by an employer through mental or physical abuse of the threat of abuse
- being dehumanised, treated as a commodity or being bought or sold as property
- being physically constrained or to have restriction placed on freedom of movement.
We acknowledge our responsibilities in relation to tackling modern slavery and commit to complying with the provisions in the Modern Slavery Act 2015. We understand that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.
Internet Fusion does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. No labour provided to Internet Fusion for our own operations has been obtained by means of slavery or human trafficking. We pride ourselves as being a great place to work and, in many cases, exceed the minimum standards required under relevant employment legislation in the United Kingdom.
To fulfil our activities, the main supply chains of our organisation are:
- The purchase of clothing, footwear, and equipment from our trusted, third-party suppliers from various locations around the world
- The in-direct manufacture and supply of our own branded goods from China
- The receiving, storage, and shipping of goods from our own distribution centres located in Northamptonshire, UK and Venlo, Netherlands.
- Essential services provided by third parties such as shipping/courier providers, seasonal workers, offshore technology contractors, facilities management (e.g. cleaning, security)
We understand that some of our first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.
We consider our main exposure to the risk of slavery and human trafficking to exist within the supply chains of our third-party suppliers as they involve the provision of labour in a country where protection against breaches of human rights may be limited and we have no direct control of the audit of these operations. However, the majority of our suppliers are trusted, household brands who take great care in protecting their organisation and those that work directly or indirectly for them.
In general, we consider our exposure to slavery/human trafficking to be medium-high. We have taken steps to ensure that such practices do not take place in our business nor the business of any organisation that supplies goods and/or services to us and commit to continually educate our employees and strengthen our own internal processes.
Internet Fusion carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in our organisation or supply chains, including conducting a review of the controls we have with our suppliers. We have not, to our knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, we have taken the following steps to ensure that modern slavery is not taking place:
- When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistleblowing.
- We conduct audits before entering a commercial relationship with any business where there is the potential for risk. These audited businesses form the basis of our preferred supplier list. We reserve the right to conduct spot-checks of the businesses who supply us to investigate any complaints.
- We require the businesses we work with to abide by our code of supplier conduct and collaborate with our suppliers to improve standards and transparency across our supply chain.
- Our staff are encouraged to bring any concerns they have to the attention of management.
- After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.
We believe in continual improvement of our practices and therefore in the following financial year we commit to taking the following additional steps:
- Driving a culture of ownership of our commitments within the business by setting up committees who will connect throughout the year
- Refresh training throughout the business annually
- Employ the services of an external whistleblowing hotline
Key Performance Indicators
Based on the potential risks we have identified; we have set the following key performance indicators to measure our effectiveness in ensuring modern slavery is not taking place at Internet Fusion or in our supply chains:
- the percentage of suppliers who sign up to our supplier code
- the percentage of workers supplied from audited businesses / our preferred supplier list
- the effectiveness of enforcement against suppliers who breach policies
- the level of modern slavery training and awareness amongst our staff
Internet Fusion has the following policies which further define our stance on modern slavery and our ethical commitments to people directly and indirectly employed by us:
- Slavery and Human Trafficking Statement
- Harassment and Bullying Policy
- Equal Opportunities and Diversity
- Company Conduct and Standards
- Anti-Bribery & Corruption
All concerns regarding modern slavery should be addressed to our Operations Director, Dudley Rogers, who will then undertake relevant actions.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.