Modern Slavery and Ethical Supply Chain Statement

PromoLab Merchandise Solutions Ltd is committed to conducting business ethically and responsibly.

We have a zero-tolerance approach to modern slavery, human trafficking, forced or compulsory labour, servitude, debt bondage and the exploitation of children.

We expect the organisations and individuals with whom we work to share these principles and to respect internationally recognised human and employment rights.

This is a voluntary statement describing the approach PromoLab takes to reducing the risk of modern slavery within its business and supply chain. PromoLab is not currently required to publish an annual statement under section 54 of the Modern Slavery Act 2015, but believes that transparency and responsible sourcing are important regardless of company size.

PromoLab Merchandise Solutions Ltd is a UK-based branded-merchandise company.

We help organisations create, source, manufacture, store, pack and distribute branded merchandise for uses including:

• marketing campaigns;
• events and conferences;
• employee onboarding and recognition;
• client gifting;
• branded merchandise stores; and
• ongoing merchandise programmes.

Our work involves relationships with product manufacturers, distributors, decorators, printers, packaging providers, warehouses, fulfilment partners, freight companies and couriers.

Our supply chain includes businesses based in the United Kingdom, Europe and other international markets. Some merchandise or component parts may be manufactured in countries where employment practices, regulatory enforcement and labour protections differ from those in the UK.

The directors of PromoLab have overall responsibility for this statement and for the company's approach to ethical sourcing and modern-slavery risk.

Members of the PromoLab team are expected to act with integrity, raise concerns and avoid knowingly working with organisations that use exploitative or unlawful labour practices.

Responsibility for considering supply-chain risks forms part of our wider supplier-selection, sourcing and project-management activities.

We expect suppliers, manufacturers and other business partners to:

• comply with applicable employment, labour and human-rights laws;
• ensure that work is entered into freely;
• prohibit forced, bonded, trafficked, prison or involuntary labour;
• prohibit unlawful child labour;
• provide lawful wages, working hours and employment conditions;
• provide a safe and healthy working environment;
• treat workers fairly and with dignity;
• prohibit harassment, abuse and discrimination;
• allow workers to leave employment in accordance with applicable law;
• avoid retaining identity documents or using recruitment fees to restrict workers' freedom;
• maintain appropriate controls within their own supply chains; and
• cooperate with reasonable requests for information relating to ethical sourcing and labour standards.

We recognise that different suppliers vary in size and in the formality of their compliance systems. Our focus is on whether appropriate standards are understood, applied and capable of being demonstrated.

PromoLab works with a broad network of suppliers and production partners.

When selecting or reviewing suppliers, we may consider matters such as:

• the supplier's location and the nature of the products being manufactured;
• relevant labour and human-rights risks associated with the country or sector;
• the supplier's experience, reputation and length of trading relationship;
• published ethical, social-compliance or responsible-sourcing policies;
• recognised audits, certifications or membership schemes where available;
• information supplied in customer or procurement questionnaires;
• the supplier's willingness to answer reasonable compliance questions; and
• any concerns, complaints or adverse information brought to our attention.

Where appropriate and proportionate to the project or level of risk, we may ask a supplier to provide:

• confirmation of its employment and labour standards;
• details of relevant audits or certifications;
• copies of ethical-trading or modern-slavery policies;
• information about manufacturing locations;
• details of subcontractors involved in production; or
• confirmation that it follows a recognised supplier code or compliance programme.

We do not rely solely on the existence of a policy or certificate. Such information forms part of our broader judgement about the supplier and the particular sourcing requirement.

We recognise that modern-slavery risk can arise at several stages of a merchandise supply chain, including:

• extraction and processing of raw materials;
• manufacturing and assembly;
• printing, decoration and finishing;
• packaging;
• warehousing;
• logistics and transportation; and
• the use of labour agencies or subcontractors.

Risks may be higher where:

• production takes place in jurisdictions with weaker labour protections or enforcement;
• complex subcontracting arrangements reduce visibility;
• unusually low prices or very short lead times place pressure on workers;
• labour-intensive manual processes are involved;
• temporary, migrant or agency workers are used; or
• there is limited information about the manufacturing facility.

PromoLab aims to consider these factors when choosing suppliers and recommending products, while recognising that complete visibility across every tier of a global supply chain can be difficult to achieve.

Where practical, PromoLab seeks to work with established and reputable manufacturers, distributors and production partners.

Many of our suppliers maintain their own ethical-trading standards, codes of conduct, audit programmes or recognised social-compliance certifications.

The precise evidence available varies by supplier, product and manufacturing location. We do not claim that every supplier is subject to the same audit programme or certification.

Where a client requires a particular certification, audit standard, country of origin or supply-chain assurance, this should be raised during the briefing process so that we can assess suitable sourcing options.

PromoLab will not knowingly support or continue a relationship involving modern slavery or serious labour exploitation.

If a credible concern is identified, we will assess the circumstances and take appropriate action. Depending on the nature and severity of the issue, this may include:

• requesting further information;
• requiring the supplier to investigate;
• seeking evidence of corrective action;
• suspending new orders;
• reconsidering or ending the business relationship;
• informing an affected client where appropriate; or
• reporting the matter to the relevant authority.

We recognise that immediately terminating a relationship is not always the action that best protects affected workers. Where appropriate, we will consider whether remediation or corrective action can be achieved without exposing workers to additional harm.

Nothing in this statement prevents PromoLab from ending a supplier relationship immediately where the circumstances justify doing so.

Employees, suppliers, clients and other interested parties are encouraged to report any concern relating to modern slavery, human trafficking or unethical labour practices connected with PromoLab or its supply chain.

Concerns can be raised confidentially by contacting:

Reports will be treated seriously and reviewed appropriately.

No person should suffer retaliation for raising a genuine concern in good faith.

Where there appears to be an immediate risk to an individual, or evidence of criminal activity, the matter may be referred to the appropriate authorities.

PromoLab is a small, senior team. Relevant employees are expected to understand the company's zero-tolerance position and to raise any supplier, product or production concern that may indicate exploitation or unacceptable working practices.

As the business and its sourcing activities develop, we will consider whether additional guidance or training would be beneficial.

PromoLab recognises that responsible sourcing is an ongoing process.

We aim to improve our approach by:

• maintaining awareness of supply-chain risks;
• considering ethical practices during supplier selection;
• asking for further information where risks or customer requirements warrant it;
• keeping appropriate supplier and sourcing records;
• reviewing concerns and lessons from individual projects;
• responding to changes in legislation and recognised good practice; and
• updating this statement as our business and supply chain develop.

This statement will be reviewed periodically and updated where necessary to reflect changes in PromoLab's operations, supply chain, legal responsibilities or sourcing practices.