MODERN SLAVERY ACT STATEMENT
Tangle Teezer Limited
07 December 2022
OVERVIEW
At Tangle Teezer, we believe that forced labour in any form has no place in our operations or supply chains and recognise the importance of ensuring that our business is conducted responsibly. We welcome the UK’s Modern Slavery Act and the transparency it encourages and take a zero-tolerance approach to modern slavery occurring in our business or supply chains.
This statement covers the activities of Tangle Teezer Limited (“Tangle Teezer”) and has been made on a voluntary basis. This statement covers our financial year ending 31 December 2021.
BUSINESS STRUCTURE AND SUPPLY CHAINS
Tangle Teezer is a British based manufacturer of detangling, blow-drying and styling hairbrushes. Established in 2007, our brushes are now sold in over 75 countries around the world. Our brushes are predominantly manufactured in the UK, however we are in the process of establishing additional strategic sites of manufacture in other countries to support our logistics and sustainability objectives. Our Detangling Sprays are manufactured outside of the UK in Sweden and a limited number of brushes and some of our packaging and production tooling is made in China. Our products are distributed globally by reputable freight forwarders and transport companies. Where appropriate, we seek to ensure that third party independent audits have been or are carried out by us on our behalf to help ensure safe, inclusive, and respectful workplaces within our supply chains.
POLICIES AND PROCEDURES
Tangle Teezer has in place a Supplier Manual that includes various company operational standards and policies to help mitigate the risk of slavery and human trafficking occurring in our supply chains, among other things. The manual covers areas such as our values, corporate social responsibility, the environment, work ethics and appropriate procedures and is provided to our suppliers and vendors.
In addition, in Quarter Four of 2022 we are launching a fully comprehensive Colleague Handbook which will include a variety of broader policies, processes and procedures and is designed to address our commitment in related areas, which will include:
• Corporate Social Responsibility Statement
• Anti-Discrimination and Equality, Diversity and Inclusion Policies
• Speak Up Policy
• Anti-Bribery and Corruption and Gifts and Hospitality Policy
Annual company-wide training in Modern Slavery, Anti-Bribery and Corruption, Gifts and Hospitality, Whistleblowing (Speak Up) and Anti-Discrimination, Equality, Diversity and Inclusion will also be provided to all new-starters and employees, with enhanced training given to any employees that work in areas that require a more detailed level of knowledge.
It is our intention to ensure that all Tangle Teezer company employees receive appropriate training on Modern Slavery, Anti-Bribery and Corruption, Gifts and Hospitality and Whistleblowing (Speak Up) by the end of January 2023.
RISK MANAGEMENT AND DUE DILIGENCE
In summary, as part of our initiative to identify and manage risk:
• We are actively looking to improve and build on our systems to (a) continue to work with partners who share our values and are prepared to support their workforce with a fair wage appropriate for that marketplace, (b) assess and monitor potential higher risk areas in our supply chains, (c) mitigate the risk of slavery and human trafficking occurring in our supply chains through enhanced contractual terms (to the extent appropriate and obtainable), (d) train our employees as to the risks to look out for and the need to manage them and (e) protect those who wish to speak up on matters of concern.
• Where appropriate we take all reasonable steps to ensure that third party audits have been conducted either by or on behalf of ourselves or by utilising 3rd party audit reports on higher-risk suppliers by reputable auditors affiliated with Sedex Members Ethical Trade Audit (SMETA)
• In addition, we will also eventually seek to conduct own company audits by Tangle Teezer’s Quality Manager which will include additional checks and due diligence measures on higher-risk suppliers.
• More generally, where possible we look to build long-standing relationships with our key suppliers and ensure that expectations of fair and appropriate business behaviour are communicated clearly and consistently.
IMPLEMENTATION
Our Head of Operations shall take responsibility for implementing the objectives considered in this statement.
Our Chief Financial Officer will monitor progress of our efforts in this area and issues (should they arise) and report back to our Board directly.
TRAINING
Our People Director will ensure regular training is provided to educate our employees on the importance of implementing and enforcing effective checks and steps to ensure slavery and human trafficking is not taking place in our supply chain. This will also form part of a wider programme of compliance training for all employees and Directors, which will take place on a regular basis and will form part of a package of mandatory onboarding training for new employees
MONITORING AND REPORTING
If issues are identified in relation to modern slavery or human trafficking, these must be immediately reported to our People Director using our Speak-Up policy.
More general issues in relation to the running of this policy will be reported back to the Board when required and on a regular basis.
This statement will be reviewed annually and published on our website www.tangleteezer.com.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 on a voluntary basis and constitutes Tangle Teezer’s slavery and human trafficking statement for the financial year ending 31 December 2021.
The Board approved this statement on 07th December 2022.
Signed by James Vowles, Chief Executive Officer, on behalf of Tangle Teezer Limited
Date: 07th December 2022