Modern Slavery Statement
This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes CoinMineShop fourth statement setting out the work undertaken during the financial year ended 30 June 2020 to further identify, prevent and address modern slavery across our organisations and supply chains.
CoinMineShop exists to maximizes returns by providing efficient products and after sales support to our customers through our professional and experienced approach.
We have a diverse team of professionals from different racial and ethnic background. We are committed to working to ensure everyone who works for and with us is treated fairly, is able to work safely and has their human rights protected and respected. We have a responsibility to work to ensure modern slavery is not present in any form across the charity and within our supply chains and we are committed to ensuring our practices support this.
2. Aproach To Tackling Modern Slavery
We have adopted a targeted approach to identifying and tackling ethical issues, including modern slavery, in our organisation and supply chain. This approach has become more focused and strategic this year. We will continue to keep our approach under review.
In line with our programme we have structured governance and management arrangements focused on the issue of modern slavery
- Our work to tackle modern slavery is overseen by internal stakeholders from key business areas. It drives our programme and facilitates collaboration across the organisation.
- We are part of the ILO Global Business Network on Forced Labour which further facilitates collaboration across the members. ILO Global Business Network on Forced Labour is also supported by internal subject matter experts, and external specialists, where beneficial.
- Our Trustees receive an annual update on our activities in relation to tackling modern slavery.
- Our Ethical Policy and programme are overseen by our Executive Team.
We have continued to ensure our people and suppliers are aware of our policies which highlight our ethical requirements
- Our policies and guidelines across the organisation and the BBC group set out our expectations of our people, stakeholders and suppliers. All staff involved in sourcing or licensing of products are also expected to follow the requirements of our ethical trading programme.
- Our Ethical Policy sets out our expectations of our suppliers. It is in line with the Ethical Trading Initiative Base Code and reflects the International Labour Organisations Conventions and Recommendations including clauses covering forced labour. This policy forms part of our standard Supplier Terms of Trade, Freelance Terms and our agreements with corporate partners and licensees, except in cases where licensees’ own policies are deemed to set a higher standard than or equivalent to ours. The policy sets out our requirements on labour standards and is prefaced by a list of minimum standards that partners must meet before we are able to work with them. It is issued at the point of engagement with the individual or supplier and is reviewed periodically. A copy of our Ethical Policy is available on request.
- We continued to communicate the Modern Slavery Code of Conduct internally to all members of the organisation. The Code sets our expectations of ethical conduct, fair, respectful treatment, and also highlights how our employees and others engaged on CoinMineShop business may raise concerns.
Risk assessment remained a crucial step in helping determine where people are most at risk across our organisation and supply chain.
- We conducted our annual risk assessment with input from relevant internal teams to help identify where greater ethical risk exists to help target our activity. We considered where workers are more likely to be at risk of ethical issues, including modern slavery, based on the type of product or service being provided, their geographic location and any known previous issues. For our suppliers, we also considered their relationship with us in terms of scale and type. These factors affect our ability to influence and impact change.
- From this risk assessment, we identified that our risk continues to be greatest in our supply chain categories of official merchandise, branded product for promotional use and licensed product. Our due diligence measures therefore continued to focus on these areas.
Our due diligence processes were embedded and strengthened during the year to help identify and monitor issues
- We have continued to focus on fully embedding our due diligence processes on an operational level through the consistent review of appropriate documentation, with a specific focus on our high risk areas.
- For a risk based selection of our suppliers:.
- we reviewed ethical trade questionnaires or audit reports for our core product and introduced more thorough due diligence into our licensed product approval process;.
- in addition to carrying out our own risk assessments and monitoring, we sought support from internal specialists within the BBC to conduct a second verification of our due diligence process and evaluations for key merchandise suppliers; and.
- we also further reviewed some of our key incumbent suppliers’ ethical trade practices in other areas of the organisation..
We continue to build awareness across key internal and external stakeholders.
- Mandatory training on ethical and fair trading remains part of our awareness approach for relevant members of staff, along with regular knowledge sharing..
- Detailed one to one guidance on our ethical programme and requirements is provided by senior trading staff to those in sourcing, trading and licensing roles to ensure consistent and effective implementation.
- We also provide guidance documentation to product manufacturers and licensees on how to follow our ethical trading programme, underlining that minimum standards on forced labour and other serious issues must be met before a factory can be approved for production.
- Our whistleblowing policy includes human rights issues, such as modern slavery. This policy continued to be available for our staff to use if they become concerned. There were no issues relating to modern slavery raised over the last year.
- We have continued to work with the BBC to develop online guidance this year with the hope of rolling this out in the following year.
3. Future Plans And Priorities
We appreciate the significance of our role in helping to identify, prevent and help eradicate modern slavery. We are committed to continuously improving and evolving our practices in relation to operating a responsible organisation, sourcing products and services ethically, and helping to raise standards across the industry.
In line with our programme, during the next year we will:
- continue to manage our activity internally via our key stakeholders and in collaboration with the BBC Group via our participation in the Working Group;
- take a risk based approach and revisit our ethical risk assessment annually;
- review our Ethical Policy to ensure alignment with good practice and ease of use;
- review the ethical trading guidance that we provide to our licensees and suppliers ensuring it reflects good practice on principles of remedy (among other topics);
- further strengthen the ethical trade requirements within our on-boarding and tender processes for key suppliers and licensees and provide further guidance to our teams to continue driving consistency in evaluating potential partners’ ethical trade processes and controls;
- develop and start to implement measures to help us monitor the effectiveness of our programme and to assess its results;
- focus communications and awareness-raising activity on key risk areas.
This Statement was approved by the Board of Trustees on 18th December 2020 and signed by Rosie Millard, Chairman