Company Statement

Creative Tops Modern Slavery Act Company Statement.

 

Creative Tops recognises the part it has to play in identifying and addressing issues of slavery and human trafficking and is fully committed to ensuring no such criminal activities take place within our company, our supplier factories or their suppliers. Creative Tops adopts a zero tolerance approach where such criminal activities are encountered. It is the responsibility of the Human Resources and Quality Assurance Managers to ensure the policy is both up to date and routinely briefed out.

 

Slavery, servitude and forced labour can take many forms, including human trafficking or child labour. Creative Tops will not tolerate such activities in our operations and we take precautions to ensure compliance. Our processes include actions to safeguard against human rights abuses (as described above) in our supply chain by means of;

 

  • Our Global Terms and Conditions – Creative Tops sourcing policy requires suppliers to certify compliance with our prohibition of forced labour, child labour and physical disciplinary abuse as part of our Global Terms and Conditions that govern the purchase by Creative Tops of goods and services from suppliers. We reserve the right to terminate our relationship with a supplier if issues of noncompliance with our policies are discovered and/or noncompliance is not addressed in a timely manner.

 

  • Regular assessments - Risks related to human trafficking and forced labour associated with our supply base are reduced and mitigated through regular factory assessments. Where new factories are engaged with a Lifetime Brands full ethical audit (conducted to the Ethical Trading Initiative base code) is conducted. Where orders are placed for National Account customers then third party audits will be conducted to their instruction. Multiple audits can thus be carried out on individual suppliers and regular scrutiny exercised.

 

Where requested by customers Creative Tops maintains records sufficient to trace the supply chain of all goods and services provided by us. We operate on a basis of full transparency consistently updating records where product production has changed location or there have been significant changes in the production process. Where we, as a business, have any reason to suspect any form of abuse we will firstly address and also inform affected customers, assisting them in their questioning and investigation and ultimate reporting obligations.

 

Where issues are identified of a criminal nature any business will be suspended and withdrawn as soon as practicably possible. Where issues of child labour are found the affected individuals will be removed to a place of safety, outstanding wages settled and a review made of the suppliers procedures, practices and training. Following review new audits will be commissioned on an unannounced basis.

Creative Tops visitors to supplier factories are required as a matter of course to be vigilant and raise/report any issues they observe.