1.1 Purpose

UK School Badges Ltd (“the company”, “we”) designs, personalises and supplies badges, embroidered, printed and engraved products, and garments such as leavers’ hoodies, through our brands School Badges UK, Personalised Badges UK, Legacy Outfitters, Leavers Hoodies UK and Car Badge UK. We print in-house (including on our OKI C650 printer) and carry out embroidery and engraving at our premises in Aldridge, and we buy garments and blanks, badges and components, and materials from suppliers.

Many of our customers are schools, pupils and families. They trust us to make sure that the products we sell are not made at the expense of the people who make them. This policy sets out the standards we expect throughout our supply chain and how we check that they are met, with a particular focus on preventing modern slavery, forced labour, human trafficking and child labour.

1.2 Voluntary best practice and the Modern Slavery Act 2015

Section 54 of the Modern Slavery Act 2015 requires a commercial organisation that supplies goods or services and carries on business in the UK to publish an annual slavery and human trafficking statement only if its total turnover is £36 million or more (Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, regulation 2).

The company’s turnover is well below £36 million, so it is not required to publish a statement. This policy is not a statutory section 54 statement. It is voluntary, and we have adopted it as best practice because we believe that every business, whatever its size, should take responsibility for the people in its supply chain. If the company ever falls within section 54, we will publish a statutory statement each financial year, approved by the board and signed by a director.

2.1 Who this policy applies to

This policy applies to:

• all suppliers of goods and materials to the company, and their own suppliers and subcontractors;
• service providers, such as couriers and cleaning and maintenance contractors;
• agents or other third parties who source products on our behalf; and
• everyone at the company who chooses, manages or places orders with suppliers, or engages workers through third parties.

We buy from suppliers in the UK and overseas. This policy covers products and materials made anywhere in the world, as well as our own operations in the UK.

2.2 Our supply chains

Garment and textile supply chains, including cotton, are widely recognised as carrying a higher risk of forced labour, child labour and excessive working hours, particularly further down the chain (raw materials, spinning, dyeing and finishing). We apply this policy with particular care to these suppliers.

Badges, lanyards and some garments are made for us in China, and we buy them direct from the factories that make them. Buying direct means we know which factory makes our goods and can deal with it directly, but the factory will usually rely on its own suppliers for fabric, yarn and components. Most of our garments come from UK suppliers, who have their own policies in place. Sections 5 and 6 explain how we assess and check our suppliers, including overseas factories.

2.3 Our own operations

Our own production (printing, embroidery and engraving), warehouse and dispatch work is carried out by our employees at our Aldridge premises.

We expect all suppliers to meet the standards in this section, to apply them to their own suppliers and subcontractors, and to work with us to improve where they fall short.

These standards are set out for suppliers in our separate Supplier Code of Conduct. We ask every supplier to sign the Code and our Supplier Acknowledgement Form, which confirms that they accept the Code and this policy and asks them to disclose any subcontractors and homeworkers.

3.1 The ETI Base Code

Our supplier standards are based on the Ethical Trading Initiative (ETI) Base Code, an internationally recognised code of labour practice founded on the conventions of the International Labour Organization (ILO).

3.2 Legal compliance and other requirements

Suppliers must also:

• comply with all applicable laws in the countries where they operate, including the Modern Slavery Act 2015 where it applies, and, where national law and this policy differ, apply whichever gives workers greater protection;
• not offer or accept bribes or facilitation payments, in line with the Bribery Act 2010;
• meet applicable product safety and chemical requirements for the goods they supply;
• comply with environmental laws relating to their operations;
• provide workers with a way to raise grievances safely and confidentially; and
• be open and honest with us about where and how our products are made.

3.3 Recognised audits and certifications

We may accept recent, credible independent social audits or certifications as evidence of good practice, for example SMETA (Sedex Members Ethical Trade Audit), amfori BSCI, SA8000, WRAP or Fair Wear membership, and, for materials and product safety, OEKO-TEX STANDARD 100 or GOTS. An audit or certificate does not replace our own judgement; it is one part of our risk-based approach (section 5).

We do not yet hold a record of the audits and certifications our suppliers have. Suppliers are asked to list them on the Supplier Acknowledgement Form.

We have zero tolerance of modern slavery, slave labour, forced labour, human trafficking and child labour in our business and in our supply chains.

4.1 Slavery, servitude and forced labour

• Slavery is where someone is treated as the property of another person. Servitude is a serious form of control in which a person is obliged to provide services and live in conditions they cannot change.
• Forced or compulsory labour is defined by the ILO Forced Labour Convention, 1930 (No. 29) as all work or service exacted from any person under the threat of a penalty and for which the person has not offered themselves voluntarily. It includes bonded labour, where a person is forced to work to repay a debt that they can never realistically clear, and forced prison labour.
• Holding someone in slavery or servitude, or requiring them to perform forced or compulsory labour, is an offence under section 1 of the Modern Slavery Act 2015.

4.2 Human trafficking

Human trafficking is arranging or facilitating someone’s travel, including recruiting, transporting, transferring, harbouring or receiving them, with a view to their exploitation. It is an offence under section 2 of the Modern Slavery Act 2015, whether or not the person consents and whether the travel is across borders or within one country. Trafficking is often linked to unscrupulous recruitment agents and to migrant workers.

4.3 Warning signs

Indicators of forced labour and trafficking, based on ILO guidance, include:

• workers’ passports or identity documents held by the employer or an agent;
• recruitment fees or debts owed to a recruiter or employer, or wages withheld, delayed or used to repay debts;
• threats, intimidation, violence, or threats to report workers to the authorities;
• restrictions on movement, such as locked premises or workers not being free to leave employer-provided accommodation;
• deception about the nature of the work, pay or conditions;
• excessive overtime that workers cannot refuse, and abusive working or living conditions; and
• workers who seem fearful, isolated, controlled by someone else or unable to speak freely.

4.4 Child labour and young workers

Child labour is work that deprives children of their childhood and education, or that is harmful to their health, safety or development. Our standards follow the ILO minimum age conventions and the ETI Base Code:

• ILO Minimum Age Convention, 1973 (No. 138): the minimum age for work must not be lower than the age of completing compulsory schooling and, in general, not less than 15. The convention allows a limited exception of 14 in some developing countries, and sets 18 as the minimum age for hazardous work.
• ILO Worst Forms of Child Labour Convention, 1999 (No. 182): prohibits the worst forms of child labour for anyone under 18, including slavery, trafficking, debt bondage and forced labour, and work likely to harm children’s health, safety or morals.
• Suppliers must not employ anyone below the legal minimum age in their country or below the ILO minimum age, whichever is higher. They must keep reliable records to verify every worker’s age.
• Young workers (under 18) must not work at night, in hazardous conditions or for excessive hours, and their work must not interfere with their education.
• Where child labour is found, suppliers must act in the best interests of the child (section 10.2).

4.5 Our commitments

UK School Badges Ltd will:

• not knowingly work with any supplier that uses slavery, forced or bonded labour, human trafficking or child labour;
• take a risk-based approach to due diligence and focus our efforts where risk is highest;
• make sure our own buying practices do not encourage exploitation;
• include ethical requirements in our supplier terms where practicable;
• train the people who manage our suppliers to recognise and act on warning signs;
• put the welfare of workers and potential victims first when concerns arise; and
• review this policy and how well it is working at least once a year.

We cannot check everything at once, so we focus on the suppliers and products where the risk of harm to workers is greatest.

5.1 Assessing risk

When assessing a supplier, we consider:

Badges, lanyards and some garments are made for us by factories in China that we buy from direct. Each of these factories is assessed against these factors in the same way as any other supplier. We pay particular attention to working hours and overtime, wages, recruitment practices, any use of agency workers, and where the factory sources its fabric, cotton and components, because these risks can arise further down the chain even where the factory itself is known to us. Most of our garments come from UK suppliers, who have their own policies in place. We take those policies into account when assessing these suppliers, but they do not replace the checks in this section, because garments bought from a UK supplier may have been made outside the UK.

5.2 New suppliers

Before we place regular orders with a new supplier of goods or materials, we will:

• give the supplier our Supplier Code of Conduct and ask them to sign it and the Supplier Acknowledgement Form, confirming that they accept the Code and this policy;
• ask for the information listed in section 6.2, including where products are made and whether any work is subcontracted or carried out by homeworkers;
• for overseas factories, including those in China, ask for the name and full address of each factory that will make our goods and for any recent independent social audit or certification (section 3.3);
• assess the supplier’s risk level using section 5.1; and
• record the results of these checks.

5.3 Action by risk level

The risk level for each overseas factory, including those in China, is set using section 5.1 and the minimum actions above then apply. Where a factory is assessed as high risk, we will ask for a recent independent social audit, or arrange one, before placing regular orders.

5.4 Ongoing monitoring and responsible purchasing

• We review key suppliers periodically, and whenever there is a concern, a change of production site, new subcontracting or a significant change in volumes.
• We plan orders, especially for peak periods such as back-to-school and leavers’ hoodie seasons, so that suppliers have reasonable lead times and are not pushed into excessive overtime or unauthorised subcontracting.
• We aim to agree fair prices, pay suppliers on time, avoid last-minute changes and build long-term relationships that support improvement.

6.1 Audits and visits

By accepting orders from us, suppliers agree that we, or an independent auditor acting for us, may check compliance with this policy:

• Announced audits and visits: we may visit or audit any site involved in producing our goods, normally with reasonable advance notice.
• Unannounced visits: we may also carry out visits without notice, particularly where risk is high or a concern has been raised.
• Access: suppliers must allow reasonable access to premises, any worker accommodation they provide, records and workers.
• Worker interviews: auditors may interview workers privately and confidentially, without management present. No worker may be punished or disadvantaged for taking part.
• Third-party audits: we may accept recent credible audits (section 3.3) instead of, or as well as, our own checks.
• Subcontractors: suppliers must secure the same rights for us at any approved subcontractor’s site.

Refusing access, obstructing an audit or providing false information is a serious breach of this policy.

6.2 Documents suppliers must provide

On request, suppliers must provide:

Hidden subcontracting is one of the main ways that exploitation enters garment and product supply chains. We are not aware of any subcontracting or homeworking in our supply chain, but suppliers may buy parts, materials and components from their own suppliers.

• Suppliers must disclose any subcontractors to us, using the Supplier Acknowledgement Form and whenever this changes.
• Suppliers must make sure that their own suppliers, including suppliers of parts, materials and components, meet the same standards as this policy and the Supplier Code of Conduct.
• Suppliers must not subcontract any part of an order for us, including embroidery, printing, finishing or packing, without our prior written approval.
• Approved subcontractors must meet this policy in full, and the supplier remains responsible for their compliance.
• Homeworkers (people working from their own homes) may only be used with our prior written approval. Suppliers must keep a register of homeworkers, ensure they are paid at least the legal minimum (on a piece-rate basis that allows this), make sure no children are involved in the work, and provide safe working conditions and materials.
• Unauthorised subcontracting or use of homeworkers is a serious breach and may result in the measures in section 10.

Our Supplier Code of Conduct sets out these requirements for suppliers, and suppliers are asked to sign it and the Supplier Acknowledgement Form. Where practicable, our purchasing terms and contracts with suppliers and contractors will also require them to:

• comply with this policy, the Modern Slavery Act 2015 and all applicable anti-slavery and human trafficking laws;
• not engage in any activity that would be an offence under sections 1, 2 or 4 of the Modern Slavery Act 2015 if carried out in the UK;
• apply equivalent requirements to their own suppliers and subcontractors;
• not subcontract work or use homeworkers without our prior written approval (section 7);
• tell us immediately of any actual or suspected slavery, trafficking or child labour in their business or supply chain;
• keep accurate records and grant the audit and access rights in section 6; and
• accept that a serious or unremedied breach entitles us to suspend orders or end the contract.

Anyone, whether an employee, a supplier, a supplier’s worker or a member of the public, who suspects modern slavery, forced labour, child labour or other serious breaches of this policy should report it as soon as possible.

• Whistleblowing protection: workers who report wrongdoing in the public interest, including a suspected criminal offence such as modern slavery, are protected by the Public Interest Disclosure Act 1998. Nobody will suffer any detriment for raising a genuine concern, even if it turns out to be mistaken.
• Do not investigate yourself: do not confront anyone you suspect, as this could put workers at risk.
• Supplier grievance routes: we expect suppliers to give their workers safe, confidential ways to raise concerns, without fear of reprisal.

Our approach is to put the welfare of affected workers first, to work with suppliers to put things right, and to end a relationship only as a last resort.

10.1 Protecting workers and victims

• Where there is a risk to anyone’s safety, call 999 or contact the police.
• We will seek specialist advice, for example from the Modern Slavery & Exploitation Helpline, before taking any action that could affect potential victims.
• We will not take action that could leave workers worse off, such as sudden order cancellations that lead to job losses, without first considering the impact on them.
• Reports and the identities of those involved will be kept confidential.
• Where a criminal offence may have been committed, we will co-operate with the police, the Fair Work Agency and other authorities.

10.2 Remediation first

• Where a breach is found, we will normally work with the supplier to fix it rather than walk away, because ending the relationship can leave workers worse off.
• Remediation should address the root cause as well as the immediate problem, for example by returning identity documents, repaying recruitment fees or unpaid wages, or changing recruitment or overtime practices.
• Child labour: the child must not simply be dismissed. The supplier must act in the child’s best interests, for example by removing them from hazardous work, supporting them to attend school and, where appropriate, offering suitable work to an adult family member.

10.3 Corrective action plans

10.4 Termination as a last resort

We may suspend orders, and will end the business relationship, where:

• a supplier refuses to co-operate, to allow access or to agree a corrective action plan;
• agreed corrective actions are not completed within the agreed time;
• the breach is extremely serious, deliberate or concealed; or
• a supplier provides false information.

Before ending a relationship, we will consider how to do so responsibly, including giving reasonable notice where appropriate and considering the impact on workers. All breaches, actions and outcomes will be recorded.

Robert James – Managing Director and policy owner

• Overall responsibility for this policy and for ethical trading across the company.
• Owning this policy jointly with Thomas Wagstaff (Sales Director) and approving it.
• Deciding the response to serious breaches and concerns, including suspending or ending supplier relationships.

Thomas Wagstaff – Sales Director, policy owner and supplier due diligence lead

• Owning this policy jointly with Robert James, keeping it, the Supplier Code of Conduct and the Supplier Acknowledgement Form up to date and arranging their annual review.
• Leading supplier due diligence, including supplier onboarding, risk assessment, obtaining the signed Code and form, audits and corrective action plans.
• Applying this policy in purchasing and production.
• Including the contract terms in section 8 where practicable.
• Planning orders and lead times responsibly.
• Reporting to the Managing Director on supplier due diligence, breaches and corrective actions.

Faye James – HR Manager

• Recording training in YouManage and supporting the handling of concerns raised by staff.

Staff who buy or manage suppliers

• Following this policy when choosing and managing suppliers.
• Spotting warning signs and reporting concerns promptly.

Suppliers

• Meeting this policy and the Supplier Code of Conduct, signing the Code and the Supplier Acknowledgement Form, providing information and access, and telling us about any breach.

• Staff involved in buying, supplier management and production planning will receive training on this policy, how to recognise the signs of modern slavery, forced labour and child labour, how to carry out supplier due diligence, and what to do if they have a concern.
• Other staff will be made aware of this policy and how to report concerns, including through the anonymous concerns box in the canteen.
• Training will be given at induction for relevant roles, refreshed periodically and when this policy changes, and recorded in YouManage.
• We will share this policy and our Supplier Code of Conduct with suppliers and, where useful, signpost them to guidance and training resources, such as those provided by the Ethical Trading Initiative.

This policy will be reviewed at least once a year and whenever there is a significant change in the law, our business or our supply chains. The review will consider supplier due diligence results, audits, concerns raised, corrective actions and training. Changes will be approved by the Managing Director and shared with staff and suppliers.

This policy is approved by the Managing Director on behalf of UK School Badges Ltd.

Policy owners: Robert James (Managing Director) and Thomas Wagstaff (Sales Director).

Last reviewed: 1 August 2026

Next review: 1 August 2027

Links were checked in October 2026.

Legislation

• Modern Slavery Act 2015 – https://www.legislation.gov.uk/ukpga/2015/30/contents
• Modern Slavery Act 2015, section 54 (transparency in supply chains) – https://www.legislation.gov.uk/ukpga/2015/30/section/54
• Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, regulation 2 (£36 million threshold) – https://www.legislation.gov.uk/uksi/2015/1833/regulation/2
• Bribery Act 2010 – https://www.legislation.gov.uk/ukpga/2010/23/contents
• Public Interest Disclosure Act 1998 – https://www.legislation.gov.uk/ukpga/1998/23/contents

International labour standards

• ILO – Child labour, including Conventions No. 138 and No. 182 – https://www.ilo.org/topics-and-sectors/child-labour
• ILO – Convention No. 138 (Minimum Age) at a glance – https://www.ilo.org/sites/default/files/2024-04/C138_at_a_glance_EN.pdf
• ILO – Convention No. 182 (Worst Forms of Child Labour) at a glance – https://www.ilo.org/sites/default/files/2024-04/C182_at_a_glance_EN.pdf
• ILO – Forced labour, modern slavery and trafficking in persons – https://www.ilo.org/topics-and-sectors/forced-labour-modern-slavery-and-trafficking-persons
• Ethical Trading Initiative – ETI Base Code – https://www.ethicaltrade.org/eti-base-code

Government guidance and reporting

• GOV.UK – Publish an annual modern slavery statement – https://www.gov.uk/guidance/publish-an-annual-modern-slavery-statement
• GOV.UK – Transparency in supply chains: a practical guide – https://www.gov.uk/government/publications/transparency-in-supply-chains-a-practical-guide
• GOV.UK – How to report serious abuse or exploitation at work (Fair Work Agency) – https://www.gov.uk/guidance/how-to-report-serious-abuse-or-exploitation-at-work
• Modern Slavery & Exploitation Helpline – https://www.modernslaveryhelpline.org/
• GOV.UK – Whistleblowing for employees – https://www.gov.uk/whistleblowing

Audit and certification schemes

• Sedex – SMETA audit – https://www.sedex.com/solutions/smeta-audit/
• amfori BSCI – https://www.amfori.org/en/solutions/social/amfori-bsci
• Social Accountability International – SA8000 – https://sa-intl.org/programs/sa8000/
• WRAP – https://wrapcompliance.org/
• Fair Wear – https://www.fairwear.org/
• OEKO-TEX STANDARD 100 – https://www.oeko-tex.com/en/our-standards/oeko-tex-standard-100
• Global Organic Textile Standard (GOTS) – https://global-standard.org/