Introduction

This statement sets out Cocoon Collection Limited's actions 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 1 March 2018 to 28 February 2019.

The company recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Cocoon Collection Limited:

A retail and wholesale gift and hamper supplier, involved in sourcing, packing and supplying gifts throughout the UK. The company’s supply chain is wholly based within the EU, and products purchased include food, drink (including alcohol) and packaging materials.

Countries of operation and supply

The organisation currently operates in the UK.

Responsibility

Amanda McManus, Operations Director, is responsible for the organisation's anti-slavery initiatives including policy implementation and review, risk assessments and due diligence.

Our Policies on Slavery and Human Trafficking

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. Our Anti-Slavery Policy reflects 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.

Due Diligence Process for Slavery and Human Trafficking

As part of our initiative to identify and mitigate the company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier by creating an annual risk profile for each supplier;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship;
  • where possible we build long standing relationships with suppliers and make clear our expectations of business behaviour;
  • with regards to national or international supply chains, our point contact is preferably with a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes.
  • we have in place systems to encourage the reporting of concerns and the protection of whistle blowers. The company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form.

 

Employee Code of Conduct

The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.

Supplier Adherence to our Values

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors comply with our values. The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.

The Operations Director is responsible for ensuring and monitoring compliance in the company and the supply chain.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors have been briefed on the subject.

The organisation's modern slavery training covers:

  • our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • what external help is available, for example through the Modern Slavery Helpline, Gang masters and Labour Abuse Authority and "Stronger together" initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.

 

Our Effectiveness

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • completion and regular review of Supplier Questionnaires;
  • use of labour monitoring and payroll systems
  • requiring all Directors to have completed training on modern slavery;
  • developing a system for supply chain verification (expected to be in place by November 2017), whereby the organisation evaluates potential suppliers before they enter the supply chain; and
  • reviewing its existing supply chains (expected to be in place by November 2017), whereby the organisation evaluates all existing suppliers.

 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company’s slavery and human trafficking statement for the current financial year

Board Approval

This statement has been approved by the company’s board of directors, who will review and update it as required annually.

Date issued: 27/04/2018

Issued by: Amanda McManus

Next review date: 27/04/2019

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