Company Name: Curveball Leisure Limited
Address: Unit C Redbrick Court, Ferryboat Close, Swansea Enterprise Park, Swansea, SA6 8QN, UK
Registered in England and Wales No: 5287160
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and outlines the steps Curveball Leisure Ltd., a proud video game distributor headquartered in Swansea, Wales, has taken and continues to take to combat modern slavery and human trafficking in our business operations and supply chains.
We are committed to upholding the highest standards of ethical conduct and responsibility across our operations and ensuring that modern slavery and human trafficking do not take place within any aspect of our business or supply chain.
Our Business
Curveball Leisure Ltd. specialises in the distribution of video games, consoles, and gaming-related accessories across the United Kingdom and international markets. We work with a wide range of suppliers, including manufacturers, publishers, and logistics providers, to bring high-quality products and services to gamers worldwide.
Our headquarters are based in Swansea, Wales, and our operations include warehousing, distribution, retail operations, and customer support. We recognise that the global nature of our supply chain increases the potential risk of encountering modern slavery practices and other unethical labour practices.
Our Policies
Modern Slavery and Ethical Conduct Policy
We have implemented a Modern Slavery and Ethical Conduct Policy that sets out clear expectations for our employees, suppliers, and business partners to:
- Comply with all relevant laws and regulations concerning modern slavery and human trafficking.
- Treat all employees and workers with dignity and respect in accordance with international human rights standards.
- Ensure that all work is freely chosen, with no individual being subject to any form of forced, coerced, or involuntary labour.
Code of Conduct for Suppliers
Our Supplier Code of Conduct establishes minimum standards that our suppliers must meet in relation to fair working conditions, pay and hours, anti-discrimination, and freedom of association. Failure to comply with these standards may result in termination of the business relationship.
Risk Assessment and Due Diligence
We understand that certain areas of our supply chain may pose a higher risk of modern slavery due to factors such as geographic location, industry practices, or the sourcing of raw materials. To address these risks, we have taken the following steps:
- Supplier Audits: Conduct due diligence checks on suppliers, assessing their compliance with our Modern Slavery and Ethical Conduct Policy. This includes reviewing their own anti-slavery efforts.
- Risk Mapping: Evaluate the regions and industries in which our suppliers operate to prioritise focus areas and mitigation efforts.
- Contractual Requirements: Include clauses in all supplier contracts that require compliance with our anti-slavery policy and ensure suppliers implement measures to prevent modern slavery.
Training and Awareness
We have provided training to key employees, particularly those managing procurement and supply chain operations, to raise awareness of modern slavery risks and equip them with the knowledge to identify and act on potential issues.
Additionally, we regularly engage with suppliers and partners to ensure understanding and alignment with our values and policies.
Measuring Effectiveness
To gauge the effectiveness of the steps we have taken, we monitor and review the following:
- Policies and Procedures: Regularly evaluate and update our policies to ensure they remain fit for purpose.
- Supply Chain Audits: Track the results of supplier audits and spot checks.
- Reporting and Resolution: Monitor reports or allegations of non-compliance and ensure they are investigated and resolved promptly.
We have also implemented a whistleblowing mechanism that allows employees, suppliers, and other stakeholders to report concerns anonymously and without fear of retaliation.
Future Commitments:
We are committed to enhancing our efforts by:
- Increasing the frequency and scope of supplier audits.
- Engaging with industry bodies and organisations fighting modern slavery to stay informed on best practices.
- Expanding our engagement with suppliers to include development programs aimed at strengthening compliance capacity.
Reporting Concerns
We encourage employees, suppliers, and other stakeholders to report any concerns related to modern slavery or unethical practices through our confidential whistleblowing mechanism. Reports will be investigated promptly, and appropriate actions will be taken to address any violations.
Board Approval
This statement has been approved by the Board of Directors and reflects our ongoing commitment to tackling modern slavery and human trafficking. It will be reviewed and updated annually.
For more information on our Modern Slavery and Ethical Conduct Policy, or to raise a concern, please contact us at [email protected].