Modern Slavery Statement 2023

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 2023 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, which includes identifying, implementing, and enforcing effective systems and controls to ensure that no slavery, human trafficking, or any other aspect of Modern Slavery, is taking place anywhere within our business or supply chain.

The Entertainer will not work with those that are involved with Modern Slavery.

The Business

The Entertainer is a family-owned high-street toy retailer in the UK. The business operates over 170 stores in the UK, a successful e-commerce business along with a growing international business through its franchise partners and the Groups wholly owned Spanish business, TEAL Retail Spain Slu, trading as Poly Jugettes. We work closely with our sister company, Addo Play LTD who are specialists in product development and toy sourcing.

The business is built upon strong values. The Group’s aim is to donate 10% of group trading profits, on average over time, to a range of charitable causes and it 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, in so 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 that works directly with victims and survivors of human trafficking all over the world and is focused on preventing modern slavery happening in the first place.

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 base is approved and monitored through our factory audit programme. Throughout 2022 factory audits were performed by the Addo team based in Hong Kong and QIMA, who we engaged with during the year to support audits.

Overview of progress during 2022

Our cross-functional group from all areas of The Entertainer and ADDO continued to meet and move the company’s Modern Slavery agenda forward. The group’s main objective is to create, deliver and audit the Entertainer's modern slavery policies and procedures.

Supply Chain and Employment

Our Supplier Code of Conduct has been reviewed, updated, and will be reissued to our suppliers during 2023.

We started working with a nominated 3rd party audit company, QIMA, in 2022 to enable us to visit more factories to conduct ethical audits. 8 of these were completed late in 2022, results have been reviewed and corrective action plans implemented where necessary. No evidence of Modern Slavery or relevant risks were identified. We continued 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.

Training

We have carried out further in-depth training with our ADDO and The Entertainer QA and Buying teams to increase the knowledge of the team. This was delivered by our partners from Slave-Free Alliance.

The training for the store and office teams is currently under review, to make it more relevant to the challenges we may face as an employer, and to highlight the 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 the 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.

We have an Operating Board Sponsor who is a member of the Modern Slavery working party.

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

Our Policies

Our Supplier Code of Conduct outlines the minimum standards we expect of all those who supply products or services. It includes topics such as forced labour, child labour, working hours etc. Our Modern Slavery Policy has been reviewed and updated as appropriate.

Recruitment Policy – as well as the right-to-work evidence, we also conduct checks on bank accounts (no duplicate accounts on our system), 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.

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 3rd party providers.

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 the Hong Kong ADDO team to conduct ethical audits on our direct manufacturing facilities in China.

We will update and review our training programme for all our business teams, focussing on their responsibilities and requirements under the Modern Slavery Act. This will enhance the existing training and enable more of the store and warehouse teams to have awareness training.

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

We will continue to complete audits and monitoring of UK labour providers, this will cover our 2 main UK warehousing operations.

We will launch an independent, confidential 3rd party whistleblowing service for the 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. The International Labour Organisation Indicators of forced labour and the 11 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. 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 2023