The IFG Modern Slavery Policy

IFG - Modern Slavery Policy

IFG is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.

We want to build a solid purpose driven business that we can clearly communicate through to our brand partners, people and customers, about what we are doing in making the world better environmentally and socially.

Question is, how? Are we improving people’s lives where we live, work and play? Are we making a difference to the working conditions of the people making our clothes/products and those of the brands that we stock across the group? What about the community where the textiles are dyed? Or where they are shipped from?

We have a massive amount of people to work with and huge amount of work to make sure that we are doing the right thing. We certainly aren’t perfect, but we want to make a difference so we will.

Now here’s the essential policy stuff that needs to help us make that difference.

George Horn

Group Head of People & Culture

The Statement

This statement is made on behalf of The Internet Fusion Group relating to the section 54(1) of the Modern Slavery Action 2015 and comprises our slavery and human trafficking statement.

1. IFG is committed to ensuring that its staff and any workers it employs (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.

2. IFG provides appropriate training and awareness information for all of its staff. In particular:

• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

3. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to George Horn (Head of People & Culture).

4. Reports surrounding these issues are taken extremely seriously by the Board and Directors, who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

• Working with the appropriate organisation’s to improve standards,
• Removing that organisation from our preferred supplier list,
• Passing details to appropriate law enforcement bodies.

5. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:

• The percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements,
• The percentage of candidates supplied from audited businesses / our preferred supplier list,
• The effectiveness of enforcement against suppliers who breach policies,
• The amount of time spent on audits, re-audits, spot checks, and related due diligence, and
• The level of modern slavery training and awareness amongst our staff.

6. As part of our efforts in this area, we publish a modern slavery statement on an annual basis.

7. We would also recommend reading this in conjunction with our other policies from the IFG Handbook, including our:

• Corporate social responsibility policy
• Ethical procurement policy
• Anti-bribery / corruption policy, and
• Whistle-blowing policy

This policy was adopted on 1st January 2019 after being agreed by the Board of Directors. It is reviewed annually.

IFG - Modern Slavery Statement

This statement is made as part of IFG’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how IFG operates, the policies and processes in place to minimise the possibility of any problems; any risks we have identified and how we will monitor them; and how we train our People.

This statement is published in accordance with section 54 of the Act and relates to the financial year April 2018 to April 2019. It was approved by the CEO and Board on 01/11/18

Martin Brailsford

CEO IFG

1 Our Business

The Internet Fusion Group is a fast-growing e-commerce business that has a strong and unique growth strategy that allows for a vast scale of economy with niche online presence that are the destinations for those needing gear and lifestyle products across surf, skate, snow, equestrian, as well as premium street and outdoor fashion.

1.1 Where we work

The group has offices and warehousing based across the UK, located in the Louth, Stockport, Shoredtich, Kettering, North Devon and York.

2 Our Policies

In addition to our Modern Slavery Policy, IFG has the following policies which encompass our ethical standards expected by our People:

• Age Discrimination
• GDPR Data Protection
• Equal Opportunities
• Health & Safety
• Maternity
• Race Discrimination
• Religion & Belief
• Sexual Orientation
• Young workers

2.1 Policy development and review

IFG’s policies are established by our directors, based on advice from our People & Culture Team, industry best practice and legal advice. We look at our policies annually, or as needed to adapt to changes.

3 Our Processes for Managing Risk

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

• 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 whistle-blowing.
• We conduct audits before entering into 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 review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.
• 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.

Additionally, we have taken the following steps to minimise the possibility of any problems:

• We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
• We require the businesses we work with to abide by our code of supplier conduct.
• We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
• Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
• We ensure that all of our suppliers are members of appropriate industry bodies and working groups.
• Our staff are encouraged to bring any concerns they have to the attention of management.

4 Our Performance

Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our Directors:

• the percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements
• the percentage of workers supplied from audited businesses / our preferred supplier list
• the effectiveness of enforcement against suppliers who breach policies
• the amount of time spent on audits, re-audits, spot checks, and related due diligence
• the level of modern slavery training and awareness amongst our staff
• We [benchmark our indicators against industry best-practice, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.

5 Our Training

All of our staff receive training and support that is appropriate to their role. In particular:

• Our leaders receive training in identifying and resolving concerns around modern slavery and human trafficking.
• Our People & Culture, recruiters, and/or staff involved in our procurement and supply chains undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

As part of this, our staff are encouraged to discuss any concerns that they have.

Training is refreshed annually