MODERN SLAVERY ACT STATEMENT
Tangle Teezer Limited
07 December 2023
Tangle Teezer is a brand that cares about its customers, hair, and the planet. Our mission is to revolutionise haircare and build a sustainable future. We are committed to conducting our business ethically and responsibly, and we understand the global challenge of modern slavery and human trafficking. This statement outlines our efforts to identify and eliminate any form of slavery or human trafficking within our operations and supply chains.
This statement is made in accordance with section 54 of the Modern Slavery Act 2015. It sets out the actions we have taken to address the risk of modern slavery in our operations and supply chains during the financial year ending 31 December 2022. We are committed to transparency and accountability in our approach to tackling modern slavery.
BUSINESS STRUCTURE AND SUPPLY CHAINS
Tangle Teezer is a global manufacturer of detangling, blow-drying, and styling hairbrushes and combs as well as detangling sprays. Our brushes are predominantly manufactured in the UK, but we have additional strategic manufacturing sites in other countries to support our logistics and sustainability objectives. We continually review and assess our manufacturing partners and sites to ensure compliance with our values. We are members of Supplier Ethical Data Exchange (Sedex), which promotes ethical and responsible practices in global supply chains. To support the monitoring of our suppliers, we ensure that our key suppliers undertake Sedex Members Ethical Trade Audit (SMETA) Pillar 4 audits, conducted by industry-leading audit partners, to ensure safe, inclusive, and respectful workplaces within our supply chains, and which includes monitoring on International Labour Organisation (ILO) compliance.
POLICIES AND PROCEDURES
In Q4 of 2022, we launched a Colleague Handbook that includes company policies and procedures and supports our commitment to complying with our Modern Slavery
responsibilities. This handbook includes an Anti-Discrimination Policy, a Speak Up Policy, and an Anti-Bribery and Corruption and Gifts and Hospitality Policy. We have also published our Corporate Social Responsibility Statement on our webpage, which outlines our support for our Planet, our People and our Community. We encourage employees to give back by providing paid Volunteer Days to all members of Tangle Teezer.
We have a Supplier Manual in place that covers our values, corporate social responsibility, the environment, work ethics, and appropriate procedures. The manual is provided to our suppliers and vendors to help mitigate the risk of slavery and human trafficking in our supply chain and partners. We have plans to go further than this and work with our suppliers through a dedicated onboarding framework to ensure all our material suppliers are assessed on various factors that are crucial to underpinning the values that Tangle Teezer ascribes to in relation to the prevention of forced labour and modern slavery practices.
In Q4 of 2022, we provided company-wide training in Modern Slavery, Anti-Bribery and Corruption, Gifts and Hospitality, and Whistleblowing (Speak Up) to all our employees and we continue to do so for all new starters to the business. We monitor this training program to ensure compliance and have an in-house training portal to provide annual updated and refresher training.
RISK MANAGEMENT AND DUE DILIGENCE
We will continue to work on the following steps to identify and manage risk during 2023 and into 2024:
- Proactively review our policies, processes, and planning based on a risk mitigation approach.
- Train our employees to increase awareness and identify potential cases of slavery and human trafficking in both their professional and personal environments, including how to Speak Up when they see something that isn’t right.
- Continue our plans to roll out a supplier onboarding framework via a dedicated portal to assess, manage, and evaluate risk in our supply chains.
- Use our Sedex membership and continue to conduct SMETA audits on our key suppliers to ensure compliance.
Our Head of Operations shall take responsibility for implementing the objectives considered in this statement.
Our Chief Financial Officer will monitor progress of our efforts in this area and issues (should they arise) and report back to our Board directly.
Our People Director will ensure regular training is provided to educate our employees on the importance of implementing and enforcing effective checks and steps to ensure slavery and human trafficking is not taking place in our supply chain. This will also form part of a wider programme of compliance training for all employees and Directors, which will take place on a regular basis and will form part of a package of mandatory onboarding training for new employees
MONITORING AND REPORTING
If issues are identified in relation to modern slavery or human trafficking, these must be immediately reported to our People Director using our Speak-Up policy or by the “Your Voice” feature on our internal HR system which allows questions or concerns to be raised by employees anonymously.
Should we become concerned, or aware, of any breaches of human rights within our supply chain, the Head of Operations will immediately share this with the Chief Financial Officer and Senior Leadership Team, where necessary action can be collectively agreed and implemented.
More general issues in relation to the running of this policy will be reported back to the Board when required and on a regular basis.
This statement will be reviewed annually and published on our website www.tangleteezer.com.
The Board approved this statement on 04th December 2023.
Signed by James Vowles, Chief Executive Officer, on behalf of Tangle Teezer Limited
Date: 07th December 2023