Modern Slavery and Human Trafficking Statement


This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Sun Mark Ltd (The Company) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Sun Mark Ltd has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.

Our Business
We are a distributor of Fast Moving Consumer Goods which are sold in the UK and exported across the world.

Our high risk areas
As part of our initiative to identify and mitigate risk we seek suitable assurances from suppliers that their businesses and supply chain are free from slavery and human trafficking. We ensure that we work with suppliers who treat their obligations towards modern slavery with the same importance that we do.

Due Diligence Processes for Slavery and Human Trafficking.

We are committed to ensuring that there is no modern slavery or human trafficking in any part of business or in our supply chains. We operate a number of internal policies to ensure that we are conducting business in an ethical, fair and transparent manner. These include:

  1. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
  2. Whistle-blowing policy. We operate a whistle-blowing policy so that all employees know that they can raise concerns about mal practice or wrong doing including in respect of slavery and human trafficking within our business or supply chain, without fear of reprisals.
  3. Where possible we build long standing relationships with local suppliers and tenancy customers and make clear our expectations of business behaviour;
  4. Most of our suppliers are based in the European Union. With regards to national or international supply chains, our point of contact is preferably with a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes.
  5. The company directors ensure equality, fairness and egalitarianism in the workplace in keeping with the requirements of the legislation.

Our Supply Chain

Sun Mark Ltd operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery. We expect all those in our supply chain and contractors comply with our values. The Directors and Senior Managers are responsible for compliance in their respective departments and for their supplier relationships.

Sun Mark Ltd is committed to acting ethically and expect all of our suppliers to make the same commitment. Sun Mark Ltd will address failures by the supplier to meet the required standards on a case by case basis and ultimately may lead to their ceasing to trade with any such supplier


To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors have been briefed on the subject.

Our Effectiveness in Combating Slavery and Human Trafficking:

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • Ensure that labour sourcing, recruitment and placement processes are under the control of trusted staff members and are not open to corruption.
  • Encourage workers to report cases of hidden third party labour exploitation and investigate and act on reports appropriately.
  • No reports are received from employees, the public or law enforcement agencies to indicate that modern slavery practices have been identified.
  • Use of labour monitoring and payroll systems.
  • Use of time-sheets to ensure fair working hours which are reinforced with biometric fingerprint scanners to ensure legitimacy.

Approval for this statement:

The Board of Directors have reviewed the processes and effectiveness of the various Group companies that fall within the scope of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for our current financial year (03/09/2018).

Approved by the Board of Directors of

Sun Mark Ltd

Dr Rami Ranger CBE