Modern Slavery Statement
This statement applies to Conway Retail Limited T/A Bathrooms of Distinction (BOD) (referred to in this statement as 'the Organisation'). The information included in the statement refers to the financial year 2019/20 and 202/21
Conway Retail Limited T/A Bathrooms of Distinction (BOD) operated from one centralised office situated in Leeds. The Company consists of several departments, core of which are: Customer Service/Sales, Warehouse/Operations, Marketing, Accounts and HR. We are a Company and Managed by Brett Conway and Hannah Conway.
The Company is based in Leeds, West Yorkshire although the Company operates on a nationwide scale.
The main activity carried out by the Organisation is the sourcing and delivery of bathroom equipment. The Organisation performs its duties through capitalising on existing custom and expanding through providing high quality goods and service. Demand for our product is consistently high throughout the year and is therefore not seasonal.
The labour supplied to the Organisation in pursuance of its operation is carried out in the United Kingdom but on a nationwide scale. This means that delivery drivers may be asked to travel and overnight stay in any county belonging to the United Kingdom.
The Organisation considers that modern slavery encompasses:
- human trafficking
- forced work, through mental or physical threat
- being owned or controlled by an employer through mental or physical abuse or the threat of abuse
- being dehumanised, treated as a commodity or being bought or sold as property
- being physically constrained or to have restriction placed on freedom of movement.
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.
In order to fulfil its activities, the main supply chains of the Organisation include manufacturers, importers and distributors of bathroom products and equipment. The majority of these are based in the United Kingdom, although both Bathrooms of Distinction and our suppliers periodically do operate through companies from all around the world.
In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
Impact of COVID-19
During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the Organisation, as it did for others across the nation.
The Organisation welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.
Despite the permitted, delay, the Organisation remains in a position to publish its statement for the financial year 2019/20 and 2020/21.
The Organisation concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above.
During the pandemic, the Organisation’s employees still had access to the grievance procedure to raise any concerns that they may have had.
In line with emergency legislation passed by the Government, employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking.
Organisation’s modern slavery risks were subject to the same monitoring procedures The during the pandemic as at all other times.
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
Currently no other additional steps have been taken.
The Organisation has the following policies which further define its stance on modern slavery:
- Whistleblowing policy Bathrooms of Distinction encourages all its employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Employee code of conduct Bathrooms of Distinction’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when managing its supply chain.
- Procurement code of conduct Bathrooms of Distinction is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.
- Recruitment policy Bathrooms of Distinction generally recruits new hires itself but when needed will use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
Slavery Compliance Officer
The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.