Gift Universe Modern Slavery Statement

About Gift Universe
Gift Universe Group recognises its responsibility to address and mitigate the risk of modern slavery and human trafficking within its business operations and supply chains. As one of the UK’s leading operators in the gift and gadget market, trading as Menkind and The Source Wholesale, we are committed to acting ethically and with integrity in all areas of our business.

Gift Universe Group has a zero-tolerance approach to slavery, human trafficking, forced labour, child labour and exploitation. We expect the same standards from our suppliers, manufacturers, business partners and service providers, whether products are sourced directly from factories overseas or purchased from suppliers within the UK.

We recognise that modern slavery risk management is an ongoing and evolving area of responsibility, requiring continuous improvement, supplier engagement and transparency throughout our supply chain.

Supply Chain
Gift Universe Group works to ensure our goods are sourced and manufactured in circumstances and environments which do not tolerate or involve exploitation or abuse of any persons. All suppliers must sign a contract outlining our policies and accept our business code of conduct before trade can commence. Gift Universe maintains regular dialogue with all our suppliers and insists that any suspicion of modern slavery or human trafficking must be communicated and escalated.

Where we are importing products, Gift Universe Group carries out regular audits and visits by third party experts as part of our regular due diligence to monitor our supply base. All suppliers are audited to ensure compliance with local laws and human rights. Areas which are monitored include wages, working hours, working conditions, accommodation, health and safety and discrimination whilst ensuring there is no child labour, human trafficking, or modern slavery.

Values and Policies
Gift Universe Group has detailed policies in place to ensure we are doing all we can to pursue an ethical supply chain. These policies include ethical audits, compliance with the Modern Slavery Act and our whistleblowing policy where we strongly urge any members of staff, customers, and suppliers alike to report any concerns regarding modern slavery within our supply chain.

Where we directly import products from factories, we detail the importance of responsible sourcing and the promotion of fair and safe working conditions within our supply chain and complying with all policies we have put in place in our General Terms and Conditions of Business.

Where we purchase products within the UK, all suppliers must comply with our Domestic Terms and Conditions of Business which contains confirmation of our zero-tolerance position about modern slavery.

Due Diligence
Identifying and managing areas of potential and higher risk remains an important focus for Gift Universe Group. We recognise that modern slavery risks can arise at different stages of the supply chain, particularly where products are sourced from overseas factories, where labour-intensive manufacturing is involved, or where subcontracting, temporary labour or migrant workers may be used. We work closely with our sourcing, procurement, compliance and quality teams to raise awareness of these risks and to improve communication with our supply base.

Our due diligence process includes supplier onboarding checks, review of supplier documentation, ethical audit requirements where appropriate, ongoing supplier communication and escalation of any concerns identified.

Gift Universe Group will continue to develop its policies, supplier due diligence processes and approach to modern slavery risk management, with the aim of improving transparency, accountability and ethical standards throughout our supply chain.

Training and Awareness
Gift Universe recognises that employee awareness is important in identifying and preventing modern slavery risks. Relevant employees involved in sourcing, procurement, quality, compliance, logistics and supplier management are expected to understand the signs of modern slavery and the importance of escalating concerns.

Employees
Gift Universe Group Ltd has over 450 team members. Our HR department follows employment procedures designed to ensure compliance with UK legal obligations and fair employment practices. The following steps are implemented:

• Full pre-employment check to confirm identity and right to work in the UK.
• All employees are paid no less than the National Minimum Wage.
• Full compliance with all employee statutory rights

Looking Forward
Gift Universe will continue to develop its approach to modern slavery risk management. Our planned actions for the next reporting period include:

• Review and revise current ethical policies and code of conduct to ensure our expectations remain clear and up to date.
• Increase supplier engagement. Further encourage our suppliers to become members of the third-party compliance organisation we are using.
• Improve internal training to raise awareness among sourcing, compliance and procurement teams.
• Review whistleblowing routes. Ensuring concerns can be reported and escalated effectively.

Board Approval
Gift Universe’s Modern Slavery Statement in conjunction with the Modern Slavery Act 2015 has been prepared for and approved by the Gift Universe Board of Directors.

Signed