MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT
Nov 1, 2023 – Oct 31, 2024
INTRODUCTION
This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1st Nov 2023 to 31st October 2024.
The statement illustrates Bensussen Deutsch & Associates LLC and all subsidiaries (BDA) commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. The staff are expected to report their concerns and management to act upon them.
BDA does not tolerate modern slavery or human trafficking in its organization or in its supply chain, and this
Statement, made pursuant to Section 54 of the Modern Slavery Act 2015, addresses the steps that we have
taken to eliminate the risk of modern slavery and human trafficking.
ORGANIZATIONAL STRUCTURE & SUPPLY CHAINS
Statement covers the business activities of BDA which are as follows:
A product distributor in the promotional products industry. The supply chains that serve our industry are global and BDA sources from companies which manufacture or source throughout the world.
BDA currently operates in the following countries:
United States – Headquarters
China – Supplier Services
United Kingdom – Client Services
France – Client Services
Philippines – Support Center
BDA worked with local staffing agencies when acquiring and onboarding these new locations to ensure compliance with local laws including the prevention of withholding government issued identification.
RISK ASSESSMENTS & MANAGMENT
We have reviewed the risks of slavery and trafficking in our own operations and do not consider any
roles to be high risk. The majority of employees are office-based and hired directly through our robust
internal hiring processes. A small percentage of employees are recruited through agencies and used on a temporary basis. We vet the agencies we use to ensure they have suitable due diligence processes and recruitment protocols.
We have a factory audit programme across our supply chain to mitigate business ethics risks in our
supply chain. We conducted a risk assessment of our supply chain in 2023 to review potential human
rights abuses in the different countries from which we source products. According to the International
Trade Union Confederation Global Rights Index, the highest risk countries from which we source products are Bangladesh, Turkey, China, Pakistan, UAE and Egypt. We will be reviewing our factory audit programme in these countries to consider the effectiveness of our approach to mitigate slavery risks.
TRAINING
Employees are provided annually with training on modern slavery and business ethics to help them spot signs
of corruption, and how to report any suspicious actions. Our Procurement team has received training from the Chartered Institute of Procurement & Supply (CIPS) on business ethics which includes slavery and human trafficking.
POLICIES
BDA is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. The Directors are responsible for creating and reviewing policies. The process by which policies are developed is looking at best practice and adapting to the needs of BDA. This Statement affirms its intention to act ethically in our business relationships. The following policies exemplifies our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
Modern Slavery Policy – We maintain a policy that requires our suppliers, contractors, partners, and
subcontractors to comply with all applicable laws of the Act.
Human Rights Policy – This policy covers how we treat our own employees and how we expect them
to treat their colleagues.
Human Rights and Forced Labor Statement – Due to recent reports regarding the use of forced
labor and other human rights violations in the Xinjiang region of China, we have further emphasized
Manufacturer Code of Conduct requiring suppliers to evaluate their own facilities and those of their
contractors to ensure adherence to international labor standards.
Whistleblowing Policy – BDA encourages all its workers, customers, and other business partners to
report any concerns related to its direct activities or its supply chains.
Employee Code of Conduct – The Code of Conduct demonstrates the specific actions and
behavior expected of employees when representing BDA.
DUE DILIGENCE PROCESSES FOR SLAVERY & HUMAN TRAFFICKING
The Directors are responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking. BDA undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. BDA’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners.
We conduct audits of suppliers to help safeguard against social compliance issues such as human trafficking and individuals being forced to work against their will. We follow up outstanding issues from corrective action plans to improve conditions for workers.
KEY PERFORMANCE INDICATORS
Results of our KPI’s for the period 1st Nov. 2023 to 31st Oct. 2024
- Number of incidents of slavery found in the supply chain 0
- Number of ethics concerns raised through our whistleblower process 0
- Number of employees trained on slavery and ethics issues (EMEA) 29
- Number of ethical factory audits conducted 13
- Number of rejected suppliers following negative ethical audit findings 2
- Percentage of suppliers that have signed the BDA Code of Conduct 100%