INTRODUCTION
The statement is made pursuant to the Modern Slavery Act 2015. It sets out our commitment to operating with openness, honesty and integrity. In keeping with this commitment and with our vision of a just world, free from poverty, Comic Relief embraces the purpose of the Act, applying it to all of our activities to work towards a world without slavery and human trafficking.
Our relevant annual turnover is under the £36 million reporting threshold. Although we are not required to make a statement under the Act, we are making this statement voluntarily to demonstrate our commitment to ethical trading principles and to set out the steps we are taking to ensure our organisation and supply chains are free from modern slavery and human trafficking.
1. OUR ORGANISATION
Comic Relief is a UK based charity, with a vision of a just world, free from poverty. Our mission is to drive positive change through the power of entertainment. We raise funds in a number of ways, including through our annual Red Nose Day campaign, Sport Relief fundraising, events, corporate partnerships, and sale of merchandise. With the money raised, we fund and invest in organisations across the UK and around the world. Our funding strategy is set out here: https://www.comicrelief.com/funding/funding-strategy.
We are a registered charity governed by a board of trustees. The Comic Relief group is comprised of Charity Projects, Comic Relief Limited and Brand Relief Limited.
Charity Projects is a company limited by guarantee and a charity registered with the Charity Commission in England and Wales and the Office of the Scottish Charity Regulator. Charitable activity is undertaken through this entity and Comic Relief is the operating name of this entity.
Comic Relief Limited and Brand Relief Limited are private companies limited by shares and a wholly owned trading subsidiary.
We are head-quartered in London and employed an average of 180 staff members in 2022. We also work with contractors, consultants and others to deliver our organisational and operational needs. To find out more about the team leading the organisation, please visit: https://www.comicrelief.com/about-comic-relief/meet-the-team/.
In our own operations, we:
Operate as a Living Wage employer and funder;
Provide training for our staff on our policies; and
Have a clear reporting concerns/ whistleblowing process for our staff and our contractors.
2. APPROACH TO TACKLING MODERN SLAVERY
Commitment to Ethical Trading
Our Ethical Sourcing Policy demonstrates our commitment to acting ethically and with integrity in all our business relationships, and our commitment to the act through implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain. We recognise that our highest point of risk in our merchandise sourcing is in the production of branded merchandise and have taken steps to combat this. Compliance with our Ethical Sourcing Policy is measured against the Ethical Trading Initiative Base Code which is based on the International Labour Organisation Conventions.
Partners
Most branded merchandise is manufactured by our Corporate Partners, who share our zero-tolerance commitment to slavery and human trafficking. We require our partners to contractually comply with our Ethical Sourcing Policy or an equivalent standard. Our partners regularly audit their process, practices, and standards, and where such audits reference parts of the supply chain involved in the manufacture of our branded merchandise, we will actively and critically review such audits with our partners.
Non-Partners
When we engage suppliers for branded merchandise directly, we undertake due diligence in advance following our Ethical Sourcing Guide. We also require their contractual commitment to comply with our Ethical Trading Policy and to work in accordance with the Act. We annually review, and audit, such manufacturing processes.
Outside our supply chain
When we engage with partners who provide us with services, we contractually require those partners to comply with law, which includes the Act.
Due Diligence and Risk Assessment
To identify and monitor the risk of slavery and human trafficking in our supply chain new suppliers are reviewed internally and then by Ethical Sourcing Consultants, highlighting any recommendations. Our key Corporate Partners have carried out audits in the supply chain throughout the year, although audit procedures may have been impacted by the pandemic.
Effectiveness in combatting slavery and Human Trafficking
We use the following key performance indicators to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:
Factory audit grading and monitoring; and
Clear process for reporting concerns.
Our strategy includes the following initiatives which are reviewed to assess their effectiveness:
Ethical Audit Programme
Comic Relief continues to tier its factories. Tier 1 refers to the factories declared by our suppliers and where Comic Relief's supply contract is assigned, and bulk production takes place. The facility is either owned or contracted by the Supplier. Comic Relief requires audits to be carried out on a semi-announced or unannounced basis and must have been conducted within the last 6 months to be valid. Comic Relief grades all audits received for sites we use for production. This allows us to benchmark factories in terms of ethical sourcing and ensuring that all factories strive for improvement and best practice.
Ethical Sourcing Projects
There are areas where there is higher risk to modern slavery, which we feel require increasing levels of scrutiny. We have continued to progress Ethical Sourcing initiatives with key Corporate Partners.
Our financial year end is 31 July 2022.
Download a PDF of the statement here(opens in new window).