ML Accessories Limited
Modern Slavery Statement

Introduction

This statement sets out our actions to understand modern slavery risks related to our business and put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business and supply chains.

Organisation and Company Structure

We are lighting distributors operating in the retail sector. We are part of the SLV Group, and our ultimate parent company is SLV GmbH. SLV GmbH has its head office in Germany. We have 100 employees and currently operate in the UK, in Dunstable, Bedfordshire.

Supply Chains

Our products are imported from China and the Far East and are sold to electrical wholesalers, online retailers, and other distribution outlets in the UK.

We have close connections with suppliers in China and Hong Kong.

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 policies reflect 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.

We operate the following policies to identify modern slavery risks and take steps to prevent slavery and human trafficking in our operations:

• Whistleblowing policy

  We encourage all employees, customers and business partners to report any concerns related to our direct activities or supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for everyone to make disclosures.

• Employee code of conduct

  Our Code of Conduct and Staff Handbook make clear to employees the actions and behaviour expected of them when representing us, including ethical behaviour when operating abroad and managing our supply chain.

• Supplier/Procurement code of conduct

  We are committed to ensuring our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour.

• Recruitment/Agency workers policy

  We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency.

• Anti-Bribery Policy and Ethical Trading Policy

  The companies have other relevant policies in place, which can be provided on request.

Due diligence processes for slavery and human trafficking

We undertake due diligence when taking on new suppliers, and regularly review our existing suppliers. Our directors, led by the Product Development Director:

• take responsibility for evaluating the modern slavery and human trafficking risks of each new supplier.
• monitor risks via the Supplier Audit Report questionnaire which covers ethical, social and governance requirements.
• ensure compliance with minimum working age prevailing standards via the Supplier Audit Report questionnaire; and
• ensure we have a system to measure the hours worked by employees to ensure conformance with applicable wage and hour labour laws, via the Supplier Audit Report questionnaire.

Supplier adherence to our values

• Policies:

  Our CEO is responsible for ensuring policies are in place.

• Risk assessments:

  Our CEO is responsible for ensuring that there is a process and that the Senior Management Team demonstrate responsibility for human rights and modern slavery risk analysis.

• Investigations/due diligence:

  Our Product Development Director carries out due diligence.

• Awareness:

  All Heads of Department will be issued this Modern Slavery Statement and will be asked to confirm that it has been read and understood.

Our effectiveness in combating slavery and human trafficking

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:

• All Heads of Department have completed training on modern slavery.
• All staff must be made aware of our Modern Slavery Statement. We will achieve this by circulating it to Heads of Department, briefing new starters as part of induction process, and making it available to all staff via the General Company Information folder.
• The Product Development Director must oversee the development of a system for supply chain verification, whereby we, in combination with SLV China, evaluate potential suppliers before they enter the supply chain.
• The Product Development Director must review our existing supply chains annually by 31st August of each year.

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 staff.

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2024.

It was approved by the board of ML Accessories Limited on the 12th March 2024, who will review it annually.

Catherine Connolly, CEO

12th March 2024