Modern Slavery and Human Trafficking Policy 2023/24

Introduction  

This statement outlines the actions undertaken by The Cheeky Panda Limited to understand the risks presented by our business activities in relation to the issues of modern slavery. This policy also provides illustration of the steps we have put in place to ensure that our supply chain, and other aspects of our business are free of slavery and human trafficking.  

Here at The Cheeky Panda Limited we wholeheartedly condemn all such practices associated with modern slavery, human trafficking, and exploitation of persons. This comes not least from the perspective of a company with aims of contributing to social and environmental good, but simply from our position as decent citizens with morals, values, and basic human empathy.  

As our business grows, as does our commitment and responsibility to ensure modern slavery does not exist amongst our supply chain. It is the responsibility of both The Cheeky Panda and other companies in our sector, as well as society has a whole to take a robust approach to human trafficking and modern slavery.  

Policy Statement  

This policy applies to all parties working on behalf of The Cheeky Panda Limited, including employees, directors, consultants, volunteers, and other representatives, as well as other relevant stakeholders, such as suppliers and partners.  

The Cheeky Panda Limited will not tolerate any form of slave labour or human trafficking in any part of our business. This is set out in our Code of Conduct which expresses our ethics as a company. The Cheeky Panda Limited will terminate contacts and negotiations, as per the Ethical Trading Initiative (ETI), where the behaviour of other parties violates this policy, and where there is seemingly no willingness or desire to address such behaviour, or the incident from which the behaviour arises.  

Accountability for this policy lies with the Directors of The Cheeky Panda Limited, as does responsibility for its implementation. All allegations of modern slavery or human trafficking will be listened to, heard, and ultimately dealt with in a robust and timely manner.   

Purpose of this Policy  

This statement relates to actions and activities during November 2023 and October 2024.  

The Cheeky Panda Limited is a sustainable organisation aiming to do good and be good, not just environmentally but socially too. Our operations span multiple continents, the purpose of this policy is to set out our approach to preventing modern slavery, human trafficking, and exploitation, in our own operations as well as the partners that assist the implementation of such operations in our supply chain. All staff we will made aware of this policy and will stand as a key feature within our Sustainability Report.  

Scope of this Policy 

This policy applies where The Cheeky Panda Limited operates. The Cheeky Panda expects all partners and supplier to abide by, and work towards this policy. We ask suppliers to meet sustainability requirements for example confirming their sustainability performance and meeting anti-corruption requirements. We see a low risk of corruption, but we know that transparency can be a challenge. We will hereby take appropriate steps to address the risk of partners and suppliers not meeting this policy, and to fully address any complaints of non-compliant behaviour against these parties. We will act in response to these claims, with the course of action dependant on the associated issues and capacity of The Cheeky Panda to address them. 

Supply chain overview 

The Cheeky Panda Limited currently operates in the following countries:  

  • United Kingdom (Head Office) 
  • USA (American Subsidiary) 
  • Ireland (European Subsidiary) 
  • China (Chinese Subsidiary, source of materials and manufacture location) 

The Cheeky Panda branded goods are further supplied in approximately 30 countries.  

Risk Assessment  

The Cheeky Panda Limited identified manufacture in China as an activity of potential risk in relation to modern slavey and human trafficking, stemming from concerns regarding implementation of both human and workers’ rights laws in the country.  

The Cheeky Panda Limited, its suppliers, and partners are expected to comply with all applicable international human rights standards, national legislation, statutory requirements, and the FSC core labour requirements. The following steps were taken to ensure that the operations of The Cheeky Panda Limited, as well as those of our manufacturing partners, respected such compliance and aligned with our belief that everyone has the right to freedom from exploitation: 

  • Employee Legislation – active communication with company lawyers and consultants to ensure compliance with government legislation.  
  • Health and Safety – ensuring our factories are certified to ISO 45001 and a self-selected staff monitoring committee, providing adequate health and safety management. 
  • Workers’ Rights – ensuring that all workers have individually written employment contracts explicitly specifying their employment terms. 
  • Workplace Complaints – existence of internal HR department with capacity for unresolved issues to be escalated to the Ministry of Human Resources and Social Security. 
  • Lowest Hourly Wage – £13.15 in the UK and Chinese Yuan equivalent of £2.63 with national minimum wage standing at Chinese Yuan equivalent of £1.76. 
  • Benefits – Contributory pension scheme, healthcare, life insurance.  
  • Working Week – 40 hours with two days of holiday per week, plus opportunity for paid overtime. 
  • Minimum Working Age – 18, in accordance with government legislation. 
  • Age Compliance Checks – Checking of legal documentation, Work Visa Certificates, and dates of birth. 

Standards 

In addition to legal compliance, The Cheeky Panda Limited expects all staff, partners, and suppliers to demonstrate commitment to meeting the following standards: 

  • Zero tolerance to inaction on exploitation  
  • Fair payment  
  • Upholding individual freedoms 
  • Both freedom from, for instance, coercion 
  • And freedom to – enter and leave employment, voluntarily and freely, etcetera 
  • Maintenance of satisfactory and working conditions 
  • Fostering supportive culture and transparency  

Commitments  

The Cheeky Panda Limited will ensure that: 

  1. All staff, volunteers, partners, and relevant stakeholders will be able to access information relating to risk identification, as well as the ability to report concerns and make allegations of modern slavery and human trafficking.  
  1. All those parties listed above will have access to, and be aware of, this policy. 
  1. Those staff who will henceforth have specific responsibilities in relation to this policy will receive adequate and appropriate training  
  1. All suppliers and relevant third-party partners have demonstrated they have equally sufficient checks and processes in place, ensuring compliance and alignment with this policy – in the case of policy breach, action will be taken, the content of which will be dependent on circumstantial factors, whilst also placing upmost importance on the effects of such actions upon those individuals impacted by the breach.  
  1. Allegations of modern slavery, human trafficking and associated activities will be taken seriously, investigated, and appropriately acted on. 

Core Labour Requirements 

As part of our commitment to the Forest Stewardship Council (FSC®) we strictly adhere to the Core Labour Requirements. As an organisation, we strictly adhere to the following:  

  • No use of child labour. 
  • No forced and compulsory labour. 
  • No discrimination in employment and occupation. 
  • Respect freedom of association and the effective right to collective bargaining 

The Cheeky Panda FSC License Code: C171628  

Key Data 

Title of Policy  

Modern Slavery and Human Trafficking  

Author  

Eleanor Turner, Sustainability Executive  

Area of Governance  

Corporate Responsibility  

Effective Date 

November 2023 

Date for Review 

October 2024 

Approved by  

Julie Chen, CEO 

Chris Forbes, Director 

Status 

Public