Slavery and Human Trafficking



The Modern Slavery Act 2015, which came into force on 29 October 2015 places a duty on larger organisations to publicly report steps they have taken to ensure that their operations and supply chains are trafficking and slavery free. SPS (EU) Limited is committed to social and environmental  responsibility and at all times tries to ensure that its supply chains are free from forced labour slavery and human trafficking.

Organisation Structure

SPS (EU) Limited is part of Europe’s largest supplier of promotional products and of a range of apparel to satisfy all marketing requirements. SPS (EU) Limited is a subsidiary of Polyconcept Holding B.V., part of the Polyconcept Group of Companies, which has its operational head office in the USA.

Supply Chains

The Polyconcept Group supply chains include the sourcing of gift products and apparel suitable for all promotional marketing requirements and customisation.

Policies on Slavery and Human Trafficking

The Polyconcept Group is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its business. Its Anti-Slavery policy reflects its commitment to acting ethically and with integrity in all of the Polyconcept Group’s business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in its supply chains.

Due Diligence Processed for Slavery and Human Trafficking

The Polyconcept Group is confident that it has a robust system for monitoring its supply chain, and has a zero tolerance for any factory that is found to be engaged in human trafficking and slavery.

The Polyconcept Group believes that its policies and procedures are consistent with requirements under the UK Modern Slavery Act 2015. It requires its suppliers to abide by its code of conduct. The Polyconcept Group also conducts factory inspections and audits, which include criteria, related to unacceptable labour practices embodied in the Act.

As part of the Polconcept Group’s initiative to identify and mitigate risk it has in place systems to:

  • Identify and assess potential risk areas in supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in its supply chains.
  • Monitor potential risk areas in supply chains.
  • Encourage the reporting of concerns and the protection of whistle blowers.

Supplier Adherence to Value and Ethics.

The Polyconcept Group has a zero tolerance to slavery and human trafficking. To ensure all those in its supply chain and contractors comply with its values or ethics the Group has in place a supply chain compliance programme.

The Polyconcept Group has a dedicated compliance team, which consists of involvement from the following departments:

  • Leal
  • Audit and compliance
  • Human resources
  • Procurement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Anti Slavery and Human Trafficking Statement of SPS (EU) Limited