Introduction

1.Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as 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.

2.Head2Toe recognises that it has a responsibility to take a robust approach to slavery and human trafficking. This statement sets out theactions and commitment to understanding potential Modern Slavery risks related to its procurement activities and to minimise the risk of slavery and human trafficking in its supply chains.

3.This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps Head2Toe has taken and will take in relation to slavery and human trafficking.Head2Toe has a zero tolerance policy in relation to modern slavery and human trafficking. We are committed to conducting all business dealings and relationships in an ethical and transparent manner, and to implementing and enforcing effective systems and checks to ensure that Head2Toe is not contributing to modern slavery in any way.

Identifying and Mitigating Potential Risk in Our Supply Chains

1.The risk of Modern Slavery in the direct and local activities that Head2Toe involved inis considered low. However, we recognise the potential risks linked to the supply chain of goods and services we buy across the world. A large portion of these goods are bought through collaborative contracts, and we work with the relevant bodies to ensure anti-corruption activities are addressed during their procurement processes as well as in our own.

2.We recognise that there are parts of the world were some of our products are produced are at a higher risk when it comes to modern slavery and human rights, We have included all of the ratings for all of the countries we buy from, we have listed them all below with their risk index taken from the globalslaveryindex.org

a) United Kingdom (B)

b) Bangladesh (B)

c) China (CCC)

d) India (B)

e) Pakistan (C)

f) Turkey (B)

3.We utilise the Government’s Sustainable Public Procurement Prioritisation Toolwhere appropriate at strategy stage of our procurements.

4.Every regulated procurement process conducted by Head2Toe requires tenderers to disclose whether the bidder or any member of their organisation with decision-making powers has been convicted in the last five years of any offence under Part 1 of the Human Trafficking and ExploitationAct 2015, or under any provision referred to in the Schedule to that Act. Tenderers that confirm such a conviction will be excluded from the process unless they can successfully demonstrate that they have self-cleansed.

Head2Toe has inserted a clause within its General Terms and Conditions in relation to Modern Slavery. This outlines the obligations of the supplier in contracting with us. It extends to due diligence procedures being in place for sub-contractors to that supplier. It references the requirement for suppliers to comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes (including the Modern Slavery Act 2015). Head2Toe reserves the right to terminate any contract where the supplier is found to be in breach of the anti-slavery policy.

 

Identifying and Mitigating Potential Risk in Our Supply Chains1.The risk of Modern Slavery in the direct and local activitiesthat Head2Toe involved inis considered low. However, we recognise the potential risks linked to the supply chain of goods and services we buy across the world. A large portion of these goods are bought through collaborative contracts, and we work with the relevant bodies to ensure anti-corruption activities are addressed during their procurement processes as well as in our own.2.We recognise that there are parts of the world were some of our products are produced are at a higher risk when it comes to modern slavery and human rights, We have included all of the ratings for all of the countries we buy from, we have listed them all below with their risk indextaken from the globalslaveryindex.orga)United Kingdom (B)b)Bangladesh (B)c)China (CCC)d)India (B)e)Pakistan (C)f)Turkey (B

Identifying and Mitigating Potential Risk in Our Supply Chains1.The risk of Modern Slavery in the direct and local activitiesthat Head2Toe involved inis considered low. However, we recognise the potential risks linked to the supply chain of goods and services we buy across the world. A large portion of these goods are bought through collaborative contracts, and we work with the relevant bodies to ensure anti-corruption activities are addressed during their procurement processes as well as in our own.2.We recognise that there are parts of the world were some of our products are produced are at a higher risk when it comes to modern slavery and human rights, We have included all of the ratings for all of the countries we buy from, we have listed them all below with their risk indextaken from the globalslaveryindex.orga)United Kingdom (B)b)Bangladesh (B)c)China (CCC)d)India (B)e)Pakistan (C)f)Turkey (B)3.We utilise the Government’s Sustainable Public Procurement Prioritisation Toolwhere appropriate at strategy stage of our procurements.4.Every regulated procurement process conducted by Head2Toerequires tenderers to disclose whether the bidder or any member of their organisation with decision-making powers has been convicted in the last five years of any offence under Part 1 of the Human Trafficking and ExploitationAct 2015, or under any provision referred to in the Schedule to that Act. Tenderers that confirm such a conviction will be excluded from the process unless they can successfully demonstrate that they have self-cleansed.Head2Toehas inserted a clause within its General Terms and Conditions in relation to Modern Slavery. This outlines the obligations of the supplier incontracting with us. It extends to due diligence procedures being in place for sub-contractors to that supplier. It references the requirement for suppliers to comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes (including the Modern Slavery Act 2015). Head2Toereserves the right to terminateany contract where the supplier is found tobe in breach of the anti-slavery policy

Identifying and Mitigating Potential Risk in Our Supply Chains1.The risk of Modern Slavery in the direct and local activitiesthat Head2Toe involved inis considered low. However, we recognise the potential risks linked to the supply chain of goods and services we buy across the world. A large portion of these goods are bought through collaborative contracts, and we work with the relevant bodies to ensure anti-corruption activities are addressed during their procurement processes as well as in our own.2.We recognise that there are parts of the world were some of our products are produced are at a higher risk when it comes to modern slavery and human rights, We have included all of the ratings for all of the countries we buy from, we have listed them all below with their risk indextaken from the globalslaveryindex.orga)United Kingdom (B)b)Bangladesh (B)c)China (CCC)d)India (B)e)Pakistan (C)f)Turkey (B)3.We utilise the Government’s Sustainable Public Procurement Prioritisation Toolwhere appropriate at strategy stage of our procurements.4.Every regulated procurement process conducted by Head2Toerequires tenderers to disclose whether the bidder or any member of their organisation with decision-making powers has been convicted in the last five years of any offence under Part 1 of the Human Trafficking and ExploitationAct 2015, or under any provision referred to in the Schedule to that Act. Tenderers that confirm such a conviction will be excluded from the process unless they can successfully demonstrate that they have self-cleansed.Head2Toehas inserted a clause within its General Terms and Conditions in relation to Modern Slavery. This outlines the obligations of the supplier incontracting with us. It extends to due diligence procedures being in place for sub-contractors to that supplier. It references the requirement for suppliers to comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes (including the Modern Slavery Act 2015). Head2Toereserves the right to terminateany contract where the supplier is found tobe in breach of the anti-slavery policy

Identifying and Mitigating Potential Risk in Our Supply Chains1.The risk of Modern Slavery in the direct and local activitiesthat Head2Toe involved inis considered low. However, we recognise the potential risks linked to the supply chain of goods and services we buy across the world. A large portion of these goods are bought through collaborative contracts, and we work with the relevant bodies to ensure anti-corruption activities are addressed during their procurement processes as well as in our own.2.We recognise that there are parts of the world were some of our products are produced are at a higher risk when it comes to modern slavery and human rights, We have included all of the ratings for all of the countries we buy from, we have listed them all below with their risk indextaken from the globalslaveryindex.orga)United Kingdom (B)b)Bangladesh (B)c)China (CCC)d)India (B)e)Pakistan (C)f)Turkey (B)3.We utilise the Government’s Sustainable Public Procurement Prioritisation Toolwhere appropriate at strategy stage of our procurements.4.Every regulated procurement process conducted by Head2Toerequires tenderers to disclose whether the bidder or any member of their organisation with decision-making powers has been convicted in the last five years of any offence under Part 1 of the Human Trafficking and ExploitationAct 2015, or under any provision referred to in the Schedule to that Act. Tenderers that confirm such a conviction will be excluded from the process unless they can successfully demonstrate that they have self-cleansed.Head2Toehas inserted a clause within its General Terms and Identifying and Mitigating Potential Risk in Our Supply Chains1.The risk of Modern Slavery in the direct and local activitiesthat Head2Toe involved inis considered low. However, we recognise the potential risks linked to the supply chain of goods and services we buy across the world. A large portion of these goods are bought through collaborative contracts, and we work with the relevant bodies to ensure anti-corruption activities are addressed during their procurement processes as well as in our own.2.We recognise that there are parts of the world were some of our products are produced are at a higher risk when it comes to modern slavery and human rights, We have included all of the ratings for all of the countries we buy from, we have listed them all below with their risk indextaken from the globalslaveryindex.orga)United Kingdom (B)b)Bangladesh (B)c)China (CCC)d)India (B)e)Pakistan (C)f)Turkey (B)3.We utilise the Government’s Sustainable Public Procurement Prioritisation Toolwhere appropriate at strategy stage of our procurements.4.Every regulated procurement process conducted by Head2Toerequires tenderers to disclose whether the bidder or any member of their organisation with decision-making powers has been convicted in the last five years of any offence under Part 1 of the Human Trafficking and ExploitationAct 2015, or under any provision referred to in the Schedule to that Act. Tenderers that confirm such a conviction will be excluded from the process unless they can successfully demonstrate that they have self-cleansed.Head2Toehas inserted a clause within its General Terms and Conditions in relation to Modern Slavery. This outlines the obligations of the supplier incontracting with us. It extends to due diligence procedures being in place for sub-contractors to that supplier. It references the requirement for suppliers to comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes (including the Modern Slavery Act 2015). Head2Toereserves the right to terminateany contract where the supplier is found tobe in breach of the anti-slavery policyConditions in relation to Modern Slavery. This outlines the obligations of the supplier incontracting with us. It extends to due diligence procedures being in place for sub-contractors to that supplier. It references the requirement for suppliers to comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes (including the Modern Slavery Act 2015). Head2Toereserves the right to terminateany contract where the supplier is found tobe in breach of the anti-slavery polic

 

 

Statement and Commitment

1.Head2Toe is committed to ensuring that modern slavery and human trafficking is not taking place in any part of itsoperation within the companyand its supply chain. We are committed to protecting and respecting human rights across all ouractivities, and will take reasonable and appropriate steps to influence others to ensure slavery and human trafficking is not taking place, where it is possible to do so.

Procurement Support for the Modern Slavery Act 2015

1.We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

2.In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free, we have embedded our obligations under the Modern Slavery Act 2015 in our Supply Chain Code of Conduct, which underpins all tendering activity. The Code of Conduct demonstrates our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Training and awareness

1.Head2Toe’s procurement function commits to undertaking all relevant e-learning training and awareness sessions, including the Sustainable procurement training.

2. All of our staff take an e-learning module every 12 months on HR which includes modern slavery so that awareness is kept high.

 

We have attached the Impact report “Tackling modern slavery in PPE supply chains” This publication has been commissioned by the UK Home Office and has been produced by Impactt Limited, a business and human rights consultancy in the UK.

This guidance should be taken as a source of information, guidance, analysis, and best practice examples, to be applied and implemented by businesses at their own discretion and in accordance with their own policies, which may or may not require all or any of the described practices to apply to its own operations and supply chains. The information and opinions within this document are not intended to constitute legal or other professional advice and should not be relied on or treated as a substitute for specific advice relevant to particular circumstances.

The Home Office and Impactt Limited (or their respective employees or representatives), will not accept responsibility for any errors, omissions or misleading statements in this document, or for any loss, cost, damage or liability which may arise from reliance on materials contained in this document.

Certain parts of this document may link to external internet sites, and other external internet sites may link to this report. Impactt Limited have drawn on other existing government-funded reports and publications in the development of this

guidance and are not responsible for the content of any external references.

Supplier’s Declaration

All of our suppliers are required to complete the following statement as part of our trading relationship

I /we hereby confirm that to the best of my/our knowledge and belief, I/we have complied with all statutory requirements of the Modern Slavery and Human Trafficking Act 2015 to the date of this certificate and recognise and accept the obligation to continue to comply with these statutory requirements for the duration of the Contract entered into.

Signed By: Neil Bayley

Position: Commercial Director

Signature: