Modern Slavery & Human Trafficking Statement

This statement sets out COYO’s actions to understand potential modern slavery risks related to our business and to put in place measures aimed at ensuring that there is no slavery or human trafficking in our business or supply chain.

Pursuant to Section 54 of the Modern Slavery Act 2015, COYO is not currently required to prepare a formal slavery and human trafficking statement due to the level of our total annual turnover. However, we have prepared this statement to demonstrate our commitment to taking a robust approach to prevent slavery and human trafficking in our activities and to ensure our supply chain is free from slavery and human trafficking.

All workers engaged directly by us are paid in excess of applicable mandatory national minimum pay rates. This is kept under review by Directors and our HR management function whenever workers are recruited and when national minimum wage rates increase from time to time.

COYO does not participate in unlawful discrimination and is committed to fairness and equality of treatment and our organisation has never been subject to any investigations or charges relating to slavery or human rights abuses.

Supply chain & supplier conduct

We are committed to ensuring our suppliers adhere to the highest standards of ethics and treat others lawfully and with dignity.

We inform contractors where relevant of our standards and expectations. Where necessary suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect and act ethically within the law in their use of labour. Where applicable, we are committed to working with suppliers to ensure they meet standards and improve working conditions. However, where serious violations of ethical standards are identified and not rectified, this will lead to the termination of the business relationship.

We keep our supply chain under regular review, assess any risk and undertake due diligence where necessary.

Our anti-slavery initiatives

Risk assessments – COYO keeps under review all recruitment, employment, contractor and supply chain relationships to ensure slavery and human trafficking is not taking place in our supply chain or our business.

Due diligence – COYO keeps its compliance with employment law and human rights under regular review. For this purpose COYO retains independent HR Consultants and Employment Law experts, inHR Ltd, to provide our HR management function and to assist with the assessment of risk and to review and advise on legal changes, compliance and duties. We undertake due diligence when considering new suppliers and regularly review existing suppliers by measures including:

  • assessing any geographical risks of modern slavery and human trafficking;
  • evaluating the slavery and human trafficking risks of new suppliers;
  • reviewing the supply chain based on risk;
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans; and
  • invoking sanctions against suppliers that fail to improve performance in line with an action plan or seriously violate lawful standards of conduct.

Training – Training and advice is provided when necessary by our HR Consultants to members of our team to support the fulfilment of their duties e.g. recruitment or supply chain activities. We provide staff who may encounter slavery issues in their role with necessary training to cover:

  • awareness of our purchasing practices aimed at preventing purchases at unrealistically low
  • prices, the use of labour on unrealistically low wages or on wages below a country’s national minimum wage;
  • the assessment of the risk of slavery and human trafficking; the identification of the signs of slavery and human trafficking; awareness of the initial steps to be taken if slavery or human trafficking is suspected;
  • the escalation of potential slavery or human trafficking issues; and
  • awareness of the external help available, for example Unseen UK and through the UK Modern Slavery and Exploitation Helpline

Relevant policies and processes

We operate the following processes and policies that are drawn to the attention of our team to support our approach to the identification of slavery risks and the prevention of slavery and human trafficking in our operations:

  • Whistleblowing and Safeguarding policies: We encourage our workers and business partners to report any concerns related to our direct activities or supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures without fear of retaliation.
  • Employment Contracts: All our employees enter into comprehensive written Employment Contracts which include standards expected when working for and representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour. This is supported by our formal Disciplinary and Grievance policies which apply to all employees. Our values, staff policies and contracts of employment make clear to employees the actions and conduct expected of them when representing our organisation.
  • Recruitment: All recruitment, selection and engagement actions are conducted by our staff, managers or HR Consultants who are all aware of their legal duties and committed to compliance. We do not use employment agencies to recruit labour overseas. If we do in future, we are committed to only using reputable employment agencies to sources labour and we will verify the practices of any agency we are using before accepting workers from that agency.

LAST UPDATED: Monday 6th January. 2025