Introduction
This voluntary statement provides information on Source Lab Limited’s standards and policies which seek to prevent modern slavery and human trafficking in all its business operations and is made in accordance with Section 54 of the Modern Slavery Act 2015.

The Company
Source Lab Limited (“The Company”) is a sports and lifestyle apparel design, sourcing and distribution company based in Cheadle Hulme, Cheshire, with production and innovation centres in China, Turkey, India, Bangladesh and Indonesia.

Source Lab Limited does not own, operate, or manage any manufacturing facilities. More than 90% of globally supplied products are manufactured across four factory sites, two in the UK and two in Asia, with whom it has longstanding supply agreements.

Policies
The Company has an Ethical Trading Policy, a copy of which can be found here. (Hyperlink to Ethical Trading Policy)

The Company’s Ethical Trading Policy establishes a procedure for protecting workers and providing assurance that all products are manufactured within safe and fair conditions. The Code of Practice applies to everything The Company does and the people working for its suppliers are to be treated with respect, and their health and safety and basic human rights must be protected and promoted.

The Company recognises that human rights are a fundamental principle which allow an individual to lead a dignified and independent life, free from abuse and violations. The Company will not tolerate, nor will it condone, abuse of human rights within any part of the business or supply chain. Any allegations that human rights are not respected will be taken very seriously.

The Company is committed to complying with the applicable laws and regulations in all countries in which it operates. The Company conducts its business with professionalism, honesty, and integrity whilst working with its suppliers and third parties to ensure its high ethical standards are maintained.

The Company is also committed to ensuring that its suppliers are responsible for ensuring that every site producing products meets or exceeds minimum labour standards and adheres to the local laws and its Code of Practice. This Code of Practice is set to core principles that suppliers must commit to meeting as a condition of doing business with The Company. The code is based upon international best practice, including the principles of the International Labour Organisation (ILO) and the Fair Labour Association Standard (FLA).

Employment Relationship –Rules and conditions of employment that respect workers and as a minimum, safeguard their rights under national and international labour and social security laws and regulations shall be adopted and adhered to.

Non-Discrimination – No person shall be subject to discrimination in employment, including hiring, compensation, advancement, discipline, termination, or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group, or ethnic origin.

Harassment or Abuse – Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological, or verbal harassment or abuse.

Forced Labour – There shall be no use of forced labour, including prison labour, indentured labour, bonded labour, or other forms of forced labour.

Child Labour – No person shall be employed under the age of 15, or under the age for completion of compulsory education, whichever is higher.

Freedom of Association and Collective Bargaining – Recognise and respect the right of employees to freedom of association and collective bargaining.

Health, Safety and Environment – Provide a safe and healthy workplace setting to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of facilities. Responsible measures should be adopted to mitigate negative impacts that the workplace has on the environment.

Hours of Work – Not require workers to work more than the regular and overtime hours allowed by the law of the country where the workers are employed. The regular work shall not exceed 48 hours and 24 consecutive hours of rest shall be allowed in every seven-day period. All overtime shall be consensual and not requested on a regular basis, all overtime work shall be compensated at a premium rate. Other than in exceptional circumstances, the sum of regular and overtime hours in a week shall not exceed 60 hours.

Compensation – Every worker has a right to compensation for a regular work week that is sufficient to meet the workers basic needs and provide some discretionary income. The minimum wage, or appropriate prevailing wage, shall be paid, whichever is higher and all legal requirements on wages, including the provision of fringe benefits required by law or contract, shall be complied with.

It is important that all workers, in The Company’s business and supply chains, understand the Code of Practice as it sets out their rights in the workplace.

Due Diligence
The Company recognises that the highest risk of modern slavery exists within the supply chain and undertakes a range of annual audits and assessments to check conditions within these factories, alongside annual visits by the Sourcing Manager. All suppliers are subject to these third-party audits which include modern slavery indicators, as well as site safety and document inspections, worker interviews, off site assessments, accommodation checks and general due diligence.

The Company review its audit methodology periodically, and accepts the following audit formats:

Sedex members Ethical Trade Audit (SMETA)
Business Social Compliance Initiative (BSCI)
Worldwide Responsible Accredited Production (WRAP)

Any factory directly, or indirectly offering, paying, soliciting, or accepting bribes or kickbacks including facilitation payments is strictly prohibited.

Risk Management
Upon receipt of an audit and following The Company’s own site visit and risk assessment, each factory is graded using a traffic light system and only factories with a green or amber grade may be utilised.

Risk Assessment completed and in date  Audit.
Risk Assessment completed and Audit expired.
No Risk Assessment and Audit Expired.

Based on minor, major or critical non-compliances highlighted at audit, the factory is then further graded, Green A, B or C. In the event of a critical non-compliance the factory will be graded green C, and the critical noncompliance must be resolved before the factory can be regraded and reinstated. Evidence of the measures taken must be provided by verifiable desktop evidence or re audit.

Major and minor non-compliances will be graded green B & A respectively meaning these factories can continue to be used, providing the supplier commits to resolve the non-compliances within an agreed timescale.

Regular reviews are undertaken to ensure the process remains current and fit for purpose.

Training
All staff are given training that provides a basic level of understanding of the issue of modern slavery and The Company’s policy in respect of modern slavery.

Those staff members who are directly involved in procurement and overseas procurement are trained specifically to their role. This includes undertaking annual CPD Accredited eLearning in addition to externally hosted training courses.

This policy has been approved by the board for the financial year to the end of January 2027 and will be reviewed annually.

Andrew Ronnie
Managing Director