Modern Slavery and Human Trafficking Statement

1. Structure, Business and Supply Chain

Chinawand Managed Sourcing Co., Ltd. specialises in Product Sourcing and Supply Chain Management.  Our we provide a world leading managed sourcing service with particular focus on the professional and DIY Hand Tool sectors.

Our brand identity is very important to us and so is our commitment to corporate social responsibility. We believe transparency is important across all of society and in our business, not least when discussing our ethical position. In that spirit, we have published our annual statement for slavery and human trafficking, made in compliance with section 54 of the Modern Slavery Act 2015. We explain how slavery and human trafficking can affect our business and the steps we are taking in the fight against it. This statement is intended to fulfil the legal requirement for a slavery and human trafficking statement.

Chinawand Managed Sourcing Co., Ltd. is headquartered in Shanghai, China and sells its products and services worldwide.  All our products are manufactured in China and are made to exacting specifications developed in collaboration with our clients, which are approved via a sampling system.  Where possible, we work with suppliers who have transparent and traceable supply chains so that we can accurately monitor and improve our supplier network and improve consistency in ethical practices throughout.

Building on our existing CSR Policy and our commitment to the Ethical Trading Initiative, we embraced the requirement to publish an annual slavery and human trafficking statement. This will allow us to share our efforts against slavery and human trafficking and improve and measure our success each financial year. This past financial year ending 31 March 2019, we took the following key steps to ensure slavery and human trafficking did not occur within our organisation or supply chain.

2. Slavery and human trafficking policies

Notably, we developed our Slavery and Human Trafficking Policy, which can be found on our website. Our slavery and human trafficking objectives are planned around the following themes:

• Relationships: Strengthening our supplier engagement process,

• Feedback: Establishing grievance mechanisms and channels for individual worker feedback,

• Knowledge: Improving our knowledge base by collecting relevant data and improving product traceability,

• Supplier collaboration: Encouraging suppliers to collaborate in addressing slavery and human trafficking concerns,

• Accountability: Establishing a framework for organisation accountability to allow for raising issues, making suggestions, voicing grievances and reporting slavery and human trafficking.

3. Due diligence procedures

We understand that our biggest exposure to Modern Slavery could present itself in our product supply chains, where we have undertaken activities to minimise the risk of Modern Slavery. Within these areas, new suppliers and factories/sites are subject to due diligence checks in the form of ethical/compliance audits. Such audits are also regularly conducted for existing suppliers and factories/sites. These audits are intended to identify any Modern Slavery practices, amongst other things.  If issues are identified, appropriate investigative and remedial actions will be taken.

4. Identifying, assessing and managing risk

We set out to identify the extent of any slavery and human trafficking in our supply chains by:

• Conducting frequent on-site spot-checks at our factories and manufacturing partner facilities, observing the working conditions, worker activities/movements and social interactions,

• Interviewing workers to discuss their conditions, work routines and their rights.

5. Key performance indicators

In order to assess the effectiveness of our modern slavery measures we will be reviewing the following key performance indicators:

• Staff training levels

• Number of slavery incidents reported in the supply chain.

Cherry Quan

General Manager

Issue No: 1

Issue Date:  March 2019