The Modern Slavery Act (2015)

In accordance with the terms of the UK Modern Slavery Act, which was passed in March 2015, the below statement sets out Whispering Smith's policy against slavery and human trafficking.

1. Purpose

Whispering Smith is committed to a work environment that is free from forced labour and unlawful child labour, i.e. human trafficking and slavery. We strongly believe that we are responsible for promoting ethical and lawful employment and these practises are also required to be followed by our suppliers worldwide.

2. Scope

This policy covers all employees of Whispering Smith and all of its suppliers. In the event that anything in this policy may conflict with local law, local law enforcement will control the interpretation and application of this policy.

3. Definitions

Human Trafficking: the recruitment, transportation, transferral, harbouring or receipt of persons, by means of threat, force or any other forms of coercion, of abduction or fraud, or deception, of the abuse of power or of a position of vulnerability, or the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

Forced labour: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.

Harmful Child labour: consistent employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

4. Rationale

Whispering Smith will not tolerate the use of unlawful child labour or forced labour in the manufacture of the products it sells, nor does it intend to accept products from suppliers that employ or utilise child labour or are forced in any manner. Human trafficking and slavery are crimes under state, federal and international law. These crimes exist in countries throughout the world. This policy is to define how Whispering Smith will make efforts to eradicate human trafficking and slavery from not only within its organisation, but also from its supply chains.

5. Requirements

Whispering Smith expects its suppliers to conduct business with honesty and integrity, and to adhere to the following standards. All Whispering Smith suppliers:

5.1. Will not use forced or compulsory labour, i.e. any work or service that a worker performs involuntarily, under the threat of penalty

5.2. Will ensure that the overall terms of employment are voluntary

5.3. Will comply with the minimum age requirements prescribed by applicable laws, unless a specific contract contains stricter age requirements

5.4. Will compensate their workers with wages and benefits that meet, or exceed, the legally required minimum, and will comply with overtime pay requirements

5.5. Will abide by applicable law concerning the maximum hours of daily labour

5.6. Will provide a safe and healthy working environment, including any company-provided living quarters

5.7. Will respect employees’ right to freedom of association, consistent with local laws

5.8. Will encourage diversity and provide a workplace that is free from discrimination, harassment or any other form of abuse

6. Certification

By their acceptance of any order for Whispering Smith, suppliers thereby acknowledge and certify their compliance with the principles and requirements set out in this policy.

7. Audits

Suppliers must be able to demonstrate compliance with this policy at the request and satisfaction of Whispering Smith. Whispering Smith will evaluate by carrying out third party and internal audits regarding this policy to ensure compliance. Suppliers shall identify and comply with applicable laws, regulations, standards and relevant customers.