UK Modern Slavery Act Statement
This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 for Original Additions (Beauty Products) Limited (the “Company”) for the financial year 2023.
This statement describes the steps that the Company has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place in its business or supply chain during the financial year 2023.
The Company is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain. We will continue to take all steps necessary to identify and address any actual or potential adverse impacts in which our business may be involved and will share our progress annually through these reports.
Our Structure and Business Operations
The Company is incorporated in the UK and it is wholly owned by PDC Brands, a US company, which is majority owned by CVC Partners.
The Company specializes in add-on cosmetics such as artificial eyelashes and nails, award-winning colour cosmetics and products for salon professions such as waxing, nail and lash products.
Our leading consumer brands include:
• Elegant Touch
• Eylure
• Salonsystem
• Cantu
• Dr Teal’s
Our Policies and Procedures
We operate several internal policies (Ethics Policy, Labour and Human Right Policy, Supplier Code of Conduct, Environmental Policy) to ensure that we are conducting business in an ethical and transparent manner.
Key policies are reviewed annually and are provided to all employees on joining the company and circulated annually.
Stakeholders across the business are involved in these policies, including Sourcing, Legal, Supply Chain Management and Operations Directors.
The Company is a member of the industry body Cosmetic, Toiletry & Perfumery Association, which coordinates the industry’s viewpoints to promote good working practices to ensure that consumers are provided with the very best products.
Reporting Issues
All employees are able to raise any concerns with their HR contact in a confidential process. We have a whistle blower policy, setting out the procedures to raise issues and complaints in a confidential manner.
Our Due Diligence Processes
The Company addresses the need to consider the risk of modern slavery in its supply chain by conducting appropriate due diligence processes across its suppliers. For this purpose, the Company operates a Sustainable Procurement Policy and Supplier Code of Conduct.
All suppliers are expected to sign the Supplier Code of Conduct, which sets out the standards of expected behaviour also in respect to the prevention of modern slavery and human trafficking.
Our Sustainable Procurement Policy sets out the steps that the Company takes to minimise modern slavery risks. These include:
1. Conducting audits of our top 10 suppliers every two to three years.
2. Including social and environmental clauses in our suppliers’ contracts.
3. Screening our potential suppliers through on-site audits on environmental and social issues.
4. Training employees responsible for procurement and supply chain in the Company’s Sustainable Procurement Policy.
We continue to develop our supplier monitoring and due diligence as part of our overall assessments.
Our Goals and Performance Indicators
In the financial year 2023, no reports of modern slavery practices were received from employees, the public, or law enforcement agencies. Our audits and 2024 risk assessment will further develop appropriate performance indicators to monitor progress.
Training
The Company requires staff to participate in modern slavery training and is reviewing its training in relation to procurement and supply chain for 2024.
Board Approval
This statement was approved by the board of directors on 27/06/2024 with respect to the financial year ending 31 December 2023.
Date: [27/06/2024]
Signed: Veronica Beaumont, Managing Director
