Modern Slavery Statement

Organisation

This statement applies to all companies within and associated to Paragon Microfibre Ltd (referred to in this statement as ‘The Company’). The information included in the statement refers to the financial year 2019 – 2020.

Organisational structure

The Company operates from its UK site in Wells, Somerset with control coming from a Board of Directors.

The main activities of The Company relate to the design and manufacture of microfibre cloths, towels and associated products. As demand for The Company’s services are consistently high throughout the year staff are employed on a permanent basis and are therefore not seasonal.

The labour supplied by The Company in pursuance of its operation is carried out in the UK.

Definitions

The Company considers 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

The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Company understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Company 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 The Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, and in many cases exceeds those minimums in relation to its employees.

Supply chains

In order to fulfil its activities, The Company’s main supply chains include those related to fabrics of varying types. We understand that The Company’s first-tier suppliers are intermediary traders and therefore have further contracted relationships with lower-tier suppliers.

Potential exposure

The Company considers its main exposure to the risk of slavery and human trafficking to exist in the fabric manufacture and supply chain where their production may involve the provision of labour in a country where protection against breaches of human rights may be limited.

In general, the Company considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Steps

The Company carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Company has not, to its 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, the Company has taken the following steps to ensure that modern slavery is not taking place:

Reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
reviewing supplier policies to ensure that they are up to date and relevant;
ensuring staff are aware of The Company’s zero tolerance policy toward modern slavery.

In the event that modern slavery is exhibited or suspected by The Company originating from a supplier:

The supplier is to be immediately suspended as an approved supplier;
Further checks made with the supplier to confirm or deny any suspicions;
If suspicions are founded, then the supplier is to be removed from our approved supplier list;
In addition, any customer or supplier found to be in breach of the Modern Slavery Act 2015, may have contracts which exist between The Company and the supplier cancelled.

Key performance indicators

The Company has not, to its 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, the Company has taken the following steps to ensure that modern slavery is not taking place:

Reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
reviewing supplier policies to ensure that they are up to date and relevant;
ensuring staff are aware of The Company’s zero tolerance policy toward modern slavery.

In the event that modern slavery is exhibited or suspected by The Company originating from a supplier:

The supplier is to be immediately suspended as an approved supplier;
Further checks made with the supplier to confirm or deny any suspicions;
If suspicions are founded, then the supplier is to be removed from our approved supplier list;
In addition, any customer or supplier found to be in breach of the Modern Slavery Act 2015, may have contracts which exist between The Company and the supplier cancelled.

Policies

The Company has the following policies which further define its stance on modern slavery:
[no further policies]

Training

The Company provides the following training to staff to effectively implement its stance on modern slavery:

Training on induction to The Company covering all our internal policies including modern slavery;
Training on induction to The Company to explain what we are looking for when considering a new supplier to add to the approved supplier list;
An annual refresher for all staff to review and sign off that they have read and understood all sections of the staff and company manuals.

Slavery compliance officer

The Company has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to The Company obligations in this regard.

Date of approval: 1st June 2020
Signed: Stephen Duffell (Slavery Compliance Officer and Managing Director)
Date: 1st October 2020