The IFG Modern Slavery Policy Modern Slavery Statement 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 the period November 2019 – November 2020. Organisational Structure Internet Fusion operates from the United Kingdom shipping to customers around the globe. Our registered office is in Louth, North Lincolnshire, main operating offices in City of London and Manchester and our distribution centre is in Kettering, Northamptonshire. We have over 250 employees across our locations with a small 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 travel to Europe is performed by our media and creative teams in order to produce video, written and photographic content. Definitions 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. Commitment 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. Supply Chains 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 centre located in Northamptonshire, UK. 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. Potential Exposure 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. Impact of COVID-19 During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for us, as it did for others across the nation. We welcome the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty. Unfortunately, due to operations during this time, we have had to delay the publication of this statement for the 2019/2020 financial year due to the impact of COVID-19. It has therefore been delayed for greater than 6 months. We conclude that the COVID-19 pandemic did adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘potential exposure’ above. During the pandemic the ability to travel internationally was greatly reduced resulting in us unable to visit our suppliers who manufacture goods directly for us. This has also impacted our third-party supplier’s audit abilities. During the pandemic, we took care of our employees who were paid enhanced sick pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking. Our employees have still had access to our grievance procedure to raise any concerns that they may have had. Steps 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 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 Policies 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 Whistleblowing Slavery Compliance Officer All concerns regarding modern slavery should be addressed to our Head of People and Culture, Laura Sayles, 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. Joe Murray CEO About Brands People Careers Sustainability News Contact 2021 © Internet Fusion Ltd. Company Registration Number 6012780 | Privacy Policy | GDPR Statement | Modern Slavery Policy | Gender Pay Gap Statement News Contact