Modern Slavery Policy

Introduction

This statement sets out Moore Large's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial 1st February 2021 to 31st January 2022.

As part of our supply and distribution, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic.

Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Moore Large:

Moore Large is one of the UK’s largest family-owned suppliers and distributors of bicycles and bicycle accessories.

• Moore Large is a British Multichannel distributor employing 100 team members
• Sourcing and selling over 30,000 product lines
• 2000 retail customers
• 8,000 Moore Large product lines
• Produced in 36 countries.

Countries of operation and supply

We currently operate in the following countries:

Austria, Bangladesh, Belgium, Switzerland, China, Curacao, Czechia, Germany, Denmark, Spain, France, Hungary, Indonesia, Israel, India, Italy, Cambodia, South Korea, Sri Lanka, Macao, Malaysia, Netherlands, Philippines, Pakistan, Poland, Portugal, Romania, Thailand, Tunisia, Turkey, Taiwan, United Kingdom, United States, Vietnam, South Africa.

High-risk activities

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply we shall

• Establish and assess areas of potential risk in our business and supply chains
• Monitor potential risk areas in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

• Policies: The board of directors are responsible for putting in place and reviewing policies and the process by which they were developed
• Risk assessments: Risk assessments that are continuously reviewed
• Training: Senior managers within the business and anyone involved in out supply chain are required to complete training on Modern Slavery and Human Trafficking. Managers that deal with external suppliers participate in own-label training provided by our customers where necessary. 

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations :

• Whistleblowing policy: We encourage all our workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. 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 workers to make disclosures, without fear of retaliation. Employees, customers, or others who have concerns can [use our confidential helpline/complete our confidential disclosure form].
• Employee code of conduct: Our code makes clear to employees the actions and behaviour expected of them when representing our organisation and their conduct within the workplace. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• The Moore Large supplier manual: Has our values at its heart and draws on the International Labour Organization (ILO) Convention, the Ethical Trade Initiative (ETI) Base Code and the United Nations Global Compact, to make sure it’s in line with internationally accepted principles and guidelines. It includes Critical Failure Points that will NOT be tolerated. These include the use of slavery in any form, the use of indentured labour, the use or threat of intimidation, harassment or abuse, and the use of child labour. We have modern slavery compliance clauses in all our Standard Terms & Conditions of Purchase, which are used with the majority of suppliers. Where Standard Terms are not used, we endeavour to build appropriate provisions into those bespoke contracts.

Due diligence

We undertake due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Our due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments through the organisation's own staff and third-party auditor such as, SGS, TÜV, Intertek & Bureau Veritas which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• key suppliers are audited annually as a minimum. But the whole Due Diligence process is risk-based and the primary determinant for risk is the country / area in which goods are produced.
• all production facilities located in high risk countries (as per amfori BSCI countries risk classification (amfori - 26.11 - Country Risk Classification 2022_0.pdf)), must be certified to an approved Ethical & Social standard: BSCI, Sedex, SA8000 or ICTI.

Moore Large is committed to the principle of continuous improvement. Any systems in place must be regularly evaluated and assessed on the basis of measurable effectiveness, in accordance with changing environments, and be adapted or expanded as required. Moore Large will review and update the policies and procedures on which this statement depends at regular intervals.

Board approval

This statement was approved on 26/05/2022 by our board of directors, who review and update it annually.

Director's name: Andrew Walker

Date: 26th May 2022