American Golf (Trading) Limited - Anti-slavery and Human Trafficking Policy

Working to eradicate modern slavery in our supply chain

Working to eradicate modern slavery in our supply chain

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, casual workers, volunteers, agents, contractors and suppliers. American Golf (Trading) Limited strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain.

The majority of our business comprises of the retail of product supplied by globally recognised third party brands. The brands are aware of their obligations to source ethically and in accordance with the principles at the heart of the Modern Slavery Act and we monitor the modern slavery statements of our key brands. Our own label business accounts for around 5% of our sales and we are committed to ensuring that all our suppliers operate in line with our ethical standards. The relationships we have with suppliers and the core values at the heart of our business are vital in tackling modern slavery. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our supply chain. We expect that our suppliers will hold their own suppliers to the same high standards.

Modern Slavery and Human Trafficking Definition

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Commitments

We are a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chain.
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf.
• Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

Our due diligence processes

To uphold our commitments, it is important that we strive to better understand and manage our complex supply chain. We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking. As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers including visits to factories and identifying second tier suppliers to ensure their compliance with our Code of Conduct.

If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

Updated 31st January 2023