INTRODUCTION

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 (“the Act”) and sets out the steps that we, Speciality Drinks Group Limited (“the Organisation”), have taken and are taking to ensure that slavery and human trafficking is not taking place in our supply chain, or in any part of our business.

OUR COMMITMENT

As part of the EMD industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking. We have a zero tolerance approach to modern slavery. Our anti-slavery policy reflects our commitment to acting ethically, 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 within our supply chain.

OUR BUSINESS AND SUPPLY CHAIN

This statement covers the activities of the HKEMD, a Hong Kong based national wholesaler and retailer:

• Is committed to supplying high-quality products that are sourced and manufactured in a fair, ethical and environmentally-responsible way;
• Has a zero-tolerance approach towards modern slavery and human trafficking within its operations and supply chain;
• Encourages its staff and those it works with to report any concerns they may have, in order to enable its management to act promptly on any concerns.

HIGH-RISK ACTIVITIES

HKEMD regularly analyses its business activities and has not identified any high risks in its operations to date.

• Is committed to supplying high-quality products that are sourced and manufactured in a fair, ethical and environmentally-responsible way;
• Has a zero-tolerance approach towards modern slavery and human trafficking within its operations and supply chain;
• Encourages its staff and those it works with to report any concerns they may have, in order to enable its management to act promptly on any concerns.

RESPONSIBILITIES FOR THE POLICY

As part of our initiative to identify and mitigate risk, we have in place systems to assess potential risk areas in our supply chain, which include, but are not limited to:

• The Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it;
• The HR Manager has the responsibility for implementing this policy, monitoring its use, effectiveness, answering any queries in relation to it, and managing its regular review;
• Our staff, suppliers, and all those involved in our operations are also encouraged to notify us, by way of confidential ‘whistleblowing’ at the earliest possible stage, any concerns about slavery or human trafficking taking place, and to avoid any activity that might lead to, or suggest, a breach of this policy. Failure to do so may result in disciplinary action being taken internally, and/or the termination of any supplier relationship.

RELEVANT POLICIES

The following policies outline HKEMD’ approach to the identification of modern slavery risks, and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing Policy: The organisation encourages its staff, customers and other business partners to report any concerns related to both the direct activities and supply chains of the organisation. 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 staff to make disclosures, without fear of retaliation.
• Employee Code of Conduct: The organisation's induction programme makes clear to staff 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 within the UK and internationally.
• Recruitment Agency Policy: The organisation uses only specified, reputable employment agencies to source from the labour market, and always verifies the practices of any new agency prior to working with them. We conduct robust checks on any new employee, including eligibility to work in the UK, to safeguard against human trafficking or individuals being forced to work against their will.

DUE DILIGENCE

The organisation undertakes due diligence when considering new suppliers, and regularly reviews its existing suppliers. This includes:

• Reviewing on a regular basis all aspects of the supply chain, based on the supply chain mapping;
• Conducting supplier assessments through the organisation's own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• Formulation of a stringent set of protocols to be adopted if we were to uncover any supplier failings. This includes the use of sanctions against suppliers that fail to improve their performance in line with an action plan, or in a worst-case scenario, this may lead to the termination of the business relationship.
• Maintaining the appropriate registrations in the UK for our business activities, regularly conducting independent audits of our suppliers to ensure they are also fulfilling their regulatory responsibilities.

FURTHER STEPS TO BE TAKEN AND AWARENESS-RAISING PROGRAMME

The organisation will raise awareness of modern slavery by circulating a series of emails to staff. The emails will explain the following:

• The basic principles of the Modern Slavery Act 2015;
• How employers can identify and prevent slavery and human trafficking;
• What our staff can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• What external help is available, for example through the Modern Slavery Helpline.

We will seek to ensure that the importance of ethical trading, and the risks of modern slavery and human trafficking, remain at the forefront of our staff minds when they carry out business activities.

APPROVAL OF STATEMENT

This statement has been approved by the organisation’s Directors for the financial year ending 30th June 2022. This statement will be reviewed on an annual basis and will be updated if necessary.