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Modern Slavery Statement

Naughty Possessions Modern Slavery Policy: Transparency Statement

This outlines Naughty Possessions Modern Slavery statement in accordance with section 54(2) of the Modern Slavery Act 2015. It details the risk related to Naughty Possessions and to put in place steps aimed at ensuring that there is no slavery or human trafficking in our business or supply chain. We have a zero-tolerance approach to any form of modern slavery (slavery, servitude, human trafficking and forced labour). Here you will find the approach we’ve taken, and continue to take, to make sure that modern slavery or human trafficking is not taking place within our business.

Business Model and Supply Chain

Naughty Possessions principal activity is the retail and wholesale of lingerie, apparel, adult toys and related accessories. Naughty Possessions sells in the UK and internationally.

We have continued to increase the depth and breadth of our work on Modern Slavery, deepening our understanding of risk, and ensuring we have in place the most effective responses to that risk. All our suppliers are required to sign up to and comply with our Code of Conduct which outlines our zero-tolerance approach to forced labour.

We also operate a Whistleblowing policy internally which enables colleagues to report any wrongdoings and extends to human rights violations like Modern Slavery.

Modern Slavery is a growing global issue and we know our customers share our concerns. Our promise to our customers is clear, we will always treat people in our business and supply chain fairly. In addition to the work, we are doing in our supply chains and operations, we continue to prioritise collaborations, which we view as essential given the systemic nature of Modern Slavery.

 

Areas of focus

Extending our work on Modern Slavery and into the whole breadth of our sourcing and operations with particular emphasis on working with international suppliers. Also, understanding further our supply chains including labour providers and recruiters to supply chain and services, as well as sub-contractors, distribution, equipment and services.

 

Governance

We have a robust governance structure with a specific risk management and internal controls framework, both of which are embedded throughout the business, and core to our approach. Our Modern Slavery Group comprises relevant senior management. Its role is to develop and coordinate actions across all the businesses.

Due diligence

We know that our biggest exposure to Modern Slavery is in our product supply chains and therefore we undertake:

· New supplier due diligence, including an internal audit of all new factories and supplier agreement to our code of conduct prior to starting supply

· Audits of factories are undertaken on a supplier risk basis

· Documented supplier visits

In addition, we invest time and resources to support effective communication and work collaboratively with our suppliers to prevent issues arising or help resolve issues when identified.

 

Training

Raising awareness to our employees and providing them with appropriate training remains a key focus area for Naughty Possessions Ltd.

Collaboration

Our business cannot tackle modern slavery alone, so it is essential and valuable for Naughty Possessions’ work with others to develop solutions for some of the more complex and systemic problems found within global supply chains. We believe that by maintaining strong direct relationships and undertaking cooperative work with others we are able to deliver real benefits to workers in our supply chain.

We recognise the need to keep Modern Slavery risk on our agenda and will continually assess our policies, controls and training (both internally and in conjunction with our suppliers) to ensure that risk is mitigated. This Modern Slavery Statement is made pursuant to Section 54(1) Modern Slavery Act 2015 for the financial year. This statement has been approved by the Naughty Possessions’ Board of Director on 1 November 2021.

Marlon Jude

Director

Naughty Possessions Group Limited

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