Modern Slavery Policy | AdGiftsOnline

This site uses cookies. Some essential cookies may have been set already.

Please click the button to accept our cookies. If you continue to use the site, we will assume you are happy to accept the cookies anyway.

Modern Slavery Policy





This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 01/04/2018.


The statement sets down the AdGiftsOnline Limited 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.  Staff are expected to report their concerns and management to act upon them.


Organisational structure and supply chains


This statement covers the business activities of AdGiftsOnline Ltd which are as follows:


The supply of branded promotional merchandise and promotional products.


The Company currently operates in the following countries:


United Kingdom.


AdGiftsOnline is an Associate Member of the British Promotional Merchandise Association and works with Accredited Supplier Members.


High Risk Activities


The company is not involved in any activities that are considered to be at high risk of modern slavery or human trafficking:


Responsibility for the Company’s anti-slavery initiatives is as follows:


  1. Policies: the HR Manager is responsible for creating and reviewing policies. The company is a member of several HR Bodies and Forums and our Operations Director is a Member of the CIPD and our policies and procedures are reviewed in accordance with their recommendations.  We are also subscribed to an Expert HR Forum with Barrister Daniel Barnett.


  1. Risk assessments: HR Manager is responsible for risk assessments in respect of human rights and modern slavery by our Induction Process with all new employees.


  1. Due diligence: Stephenie Altham is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.




To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all employees to complete an internal training session with the HR Manager and or Operations Director.




The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.


The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations [insert links to the relevant Company policy]:


  1. Whistleblowing policy - the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
  2. Employee Code of Conduct - The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.
  3. Corporate Social Responsibility (CSR) Policy - The Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.


Due Diligence Processes for Slavery and Human Trafficking


The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes e.g. building long-standing relationships with suppliers and making clear our expectations of business partners AND/OR evaluating the modern slavery and human trafficking risks of each new supplier AND/OR invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.


Performance indicators


The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including e.g. requiring all relevant staff to have completed training on modern slavery by our HR Manager or Operations Director.


This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated, as necessary. The company’s Board of Directors endorses this policy statement and is fully committed to its implementation.


This Modern Slavery and Human Trafficking Statement has been approved and authorised by:



Tony Altham



Managing Director



1st April 2018