Modern Slavery Statement 2024

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps The Entertainer has taken as a business during the financial year ending January 2024 and sets out plans to prevent modern slavery and human trafficking within our business and supply chain.

The Entertainer’s policies and practices reflect our commitment to act ethically and with integrity in all our business relationships. This includes identifying, implementing, and enforcing effective systems and controls to ensure that no slavery and human trafficking, or any other aspect of Modern Slavery, is taking place anywhere within our business or supply chain.

The Entertainer is committed to working with suppliers that effectively address the risk of modern slavery.

The Business

The Entertainer is a multi-faceted British toy retailer. The backbone of the business are the wholly owned shops and 2 dedicated websites delivering ‘The Entertainer’ & ‘The Early Learning Centre’ retail brands. The business also operates through third party retailers in the UK, such as Tesco, M&S, Matalan and Moonpig, as well as internationally where the business has a well-established international franchise business operating over 200 stores across 18 countries.

The business is built upon strong values. It donates 10% of trading profits to a range of charitable causes and cares passionately about the well-being of its people.

We are proud of our values which uphold and proclaim the dignity of all, in particular children. We are committed to the eradication of slave labour and human trafficking. This includes ensuring that our suppliers are free from such practices, as far as the company, its contractors and subcontractors can control or influence such actions.

The Entertainer has an active partnership with Slave-Free Alliance who we work collaboratively with on our approach to tackling Modern Slavery. This partnership supports Hope for Justice, a charity working to bring an end to modern slavery and human trafficking, and to protect the human rights of victims and survivors is fighting human trafficking and helping victims and survivors all around the world.

Our Supply Chain

Products sold in the Entertainer are sourced globally. We expect those within our supply chain to respect the rights, well-being and welfare of their workforce and their working environment. All suppliers must adhere to our requirements set out in our existing supplier code of conduct; no forced, bonded or child labour, no slavery or human trafficking, no discrimination, no harsh or inhumane treatment, freedom to choose employment, hygienic and safe working environment, minimum living wage payment, no excessive working hours with at least one day off in every seven, freedom of association and collective bargaining.

Our supplier network is approved and monitored via our factory audit programme. We work closely with our sister company, Addo Play Ltd, who are specialists in product development and toy sourcing. In 2023, factory audits were conducted by the Addo team in Hong Kong and QIMA, who carried out ethical factory audits with us throughout the year.

Overview of progress during 2023

Our interdisciplinary team, comprised of members from The Entertainer and ADDO, has been actively pushing the company's Modern Slavery agenda. The primary goal of this group is to develop, implement, and review policies and procedures related to modern slavery within The Entertainer.

Supply Chain and Employment

Our Supplier Code of Conduct was updated and reissued to all suppliers in November 2023. This code sets out the Entertainer fundamental expectations of all suppliers, covering areas from wages and benefits and working hours through to health and safety expectations and environmental compliance.

We reinstated physical factory visits in China, which were not possible previously due to COVID restrictions. This enabled us to visit 8 factory sites to assess social and ethical compliance. Reports have been issued to suppliers and Corrective Action Plans implemented where necessary. No instances or relevant risks of Modern Slavery were detected.

We have also introduced sourcing restrictions from high-risk regions, issued through the vendor QA manual in November 2023.

We worked alongside our UK Employment agencies’ audits to ensure they have thorough and detailed processes and procedures as part of their onboarding of contracted staff for supply to the Business. We are satisfied that they are operating with a reasonable and auditable recruitment process to identify any potential Modern Slavery or Forced Labour in their workforce.

We are continually monitoring our internal documentation to ensure it is compliant and meets the requirements of the Business.

We carried out audits of our labour agencies during the year, they have clear and defined Modern Slavery Policies which are being followed on all sites in which we engage with third party providers. The International Labour Organisation Indicators of forced labour and the eleven components that can be identified have been considered and applied to the Business. We have concluded that there is no evidence at present of forced labour in our domestic UK Business.

Training

We have carried out further training with our ADDO teams to increase the knowledge base of the team. This was delivered by our partners from Slave-Free Alliance.

The training for the store and office teams was issued and completed by all managers and recruiting managers in the business via our online training portal. This training covered the challenges we may face as an employer, and key signals to look for as part of their roles.

Due Diligence

Our Modern Slavery working party meet periodically throughout the year to review progress against our plan, discuss any issues and agree actions for the coming months. The group is made up of managers from all areas of the business, including Buying, Logistics, Supply Chain, QA, Risk, Legal and our People management team.

Regular Board Meeting updates on progress are produced and shared with the Operating Board .

During the year we extended our anonymous Whistleblowing Line, managed through Safecall into our UK warehouse operations as well as to all our suppliers through the Supplier Code of Conduct. This system will allow us to monitor and process any issues raised.

Our Policies

Our Supplier Code of Conduct outlines the standards expected from all our product and service suppliers. It addresses issues such as forced labour, child labour, and working hours. Furthermore, our Modern Slavery Policy has been reviewed and revised to reflect these requirements.

Recruitment Policy – as well as the right-to-work evidence, we also conduct checks on bank accounts (no duplicate accounts on our system) and all interviewees are seen face to face. This also aligns with our labour agencies who have stringent checks that they conduct at the onboarding stage.

Next Steps

For continual improvement and to ensure our business and supply chain is free from slavery and human trafficking, we commit to the following future steps.

Factory Audits – We will continue to work with both third-party auditors and our Hong Kong ADDO team to conduct ethical audits on our direct manufacturing facilities in China. We will also visit a selection of our suppliers to carry out our own audits during the 1st half of 2024.

We will continue monitoring our policies and setting KPIs for the business to ensure we achieve our objectives.

We will keep auditing and monitoring UK labour providers, focusing on our 2 main UK warehousing sites. Additionally, a full audit will be conducted for our new partner warehouse in the East Midlands to ensure Modern Slavery compliance.

We will extend our independent, confidential third-party whistleblowing service to all colleagues. This will enable all of our teams to report any areas of concern for Modern Slavery, unsafe work practices or any other supply chain, starting with our direct manufacturing sites and our UK warehouse operations. We will look at how we develop our whistleblowing processes to include the UK stores and sites.

Our Modern Slavery Statement was prepared by our Modern Slavery Working Party and has been approved by the Board of Directors.

Martin Rothwell

Chief Financial Officer

August 2024