1. Introduction

Ulster Weavers Home Limited is committed to preventing modern slavery and human trafficking in all aspects of its operations and supply chains. We recognise our responsibility to uphold ethical standards and ensure that our business practices support human rights and fair treatment for all individuals.

This policy outlines the steps we take to mitigate risks of modern slavery and human trafficking and to promote transparency and accountability in compliance with the Modern Slavery Act and other relevant legislation.

2. Policy Statement

We have a zero-tolerance approach to modern slavery, forced labour, bonded labour, and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in our own business or in our supply chains.

3. Scope

This policy applies to:

• All employees, directors, and officers of Ulster Weavers Home Limited
• Suppliers, subcontractors, and business partners globally
• All business operations and supply chains

4. Supply Chains

4.1 Sourcing Regions
We currently source products from Pakistan, China, India, Bangladesh and the UK. Prior to placing orders, a company representative visits each factory to assess working conditions and ethical practices.

4.2 Supplier Standards
All suppliers must:

• Comply with Ulster Weavers Home Limited ’s Anti-Bribery and Corruption Policy and Ethical Trading Policy
• Adhere to the Ethical Trading Initiative (ETI) Base Code
• Demonstrate a commitment to improving employee working conditions

Violations of our ethical standards will result in corrective actions and may lead to termination of the business relationship.

5. Due Diligence

We conduct rigorous due diligence before engaging new suppliers and routinely review existing suppliers. Measures include:

• Supply Chain Mapping: Identifying geographical and product-specific risks of modern slavery
• SMETA Audits: Conducting Sedex Members Ethical Trade Audits for all new and existing suppliers
• Annual Supplier Assessments: Evaluating risks around forced labour and workers’ rights
• Non-Compliance Reports: Issuing reports with risk profiles and required action plans
• Continuous Improvement: Supporting suppliers in correcting deficiencies and improving labour standards

6. Risk Assessment

We maintain an annual risk profile for each supplier, based on audits, location-specific risk, industry norms, and historical compliance. High-risk suppliers are subject to increased monitoring and support.

7. Training and Awareness

All our staff involved in procurement, supply chain management, and factory oversight receive annual training on:

• Identifying signs of modern slavery and trafficking
• Reporting mechanisms and responsibilities
• ETI Code of Conduct

We also remain engaged with external initiatives such as Stronger Together and updates to SMETA guidelines to stay informed on best practices.

8. Reporting and Grievance Mechanisms

Employees and third parties can confidentially report concerns of modern slavery via our whistleblower channel or directly to HR or the Compliance Officer. All concerns will be investigated promptly and fairly, without fear of retaliation.

9. Enforcement and Non-Compliance

Suppliers who fail to meet our modern slavery standards may face:

• Development of a corrective action plan
• Temporary suspension of orders
• Termination of the supplier relationship in cases of severe or repeated violations

10. Governance and Review

This policy is overseen by the CEO, CCO, CFO, SMT and Compliance Manager and is reviewed annually in September to ensure relevance for the financial year starting in October. Updates are communicated to all stakeholders.

11. Effectiveness and KPIs

To assess the effectiveness of our efforts to prevent modern slavery and human trafficking, Ulster Weavers Home Limited has adopted a set of measurable Key Performance Indicators (KPIs). These indicators are monitored and reviewed annually as part of our continuous improvement process. The following KPIs reflect our commitment to transparency, ethical sourcing, and supplier accountability:

• Percentage of Tier 1 suppliers audited annually – Target: 100%
• Percentage of new suppliers screened for modern slavery risks before onboarding – Target 100%
• Percentage of suppliers with non-compliance issues addressed through corrective action plans – Target 100%
• All high-risk suppliers monitored, we work closely with the suppliers on email and on teams meeting to ensure the corrective action is uploaded to Optimus within the agreed time frame.
• Percentage of relevant staff trained annually on modern slavery awareness – Target: 100%
• Number of modern slavery concerns reported via whistleblowing or grievance mechanisms
• Percentage of reported incidents resolved within 30 days
• Participation in external ethical trade programs (e.g., Sedex, Stronger Together)
• Annual review and update of this policy and associated procedures.

 

12. Approval and review

This Modern Slavery and Human Trafficking Statement has been approved by the Board of Directors of Ulster Weavers Home Limited in accordance with the requirements of Section 54(1) of the UK Modern Slavery Act 2015. It represents the company's statement for the financial year ending 30 September 2025.

Approved by the Board of Directors on: 21 July 2025