Introduction
As a UK employer and retailer of specialist fireworks, Bright Star Fireworks recognises its role in ensuring that no slavery or human trafficking takes place within either its direct operation or wider supply chain. With the fireworks supply chain often encompassing a complex and global operation, we know that our customers and our employees share our wish to ensure that our supply chains are free from slavery and human trafficking.
This statement sets out the actions we have taken to understand all potential modern slavery risks within our supply chains and our plans to effectively and pro-actively manage these risks on an ongoing basis.
Organisational structure
Bright Star Fireworks UK Ltd T/A Brightstar is a UK registered limited company based in Lincolnshire. Part of a wider family of businesses, including Cube Fireworks, Bright Star supplies fireworks to the UK. Bright Star Fireworks currently employs people at its licenced storage and distribution site near Gainsborough. The business is a retail-focused, customer-facing supplier of specialist fireworks to procure, manage and assure partnerships with a number of global fireworks suppliers.
Industry Risk
Bright Star Fireworks engage agents and contractors to provide some services to support our business regarding Management System Consultancy, Health & Safety, Facilities Management Tasks & Security. Bright Star Fireworks purchase certain products from a UK based supplier, whose supply chain extends to South East Asia, China and other global locations.
Steps Taken
The business recognises the risk that certain contractors might engage and exploit casual workers and has controls in place to ensure that it only appoints reputable contractors who comply with applicable employment standards. The business recognises the risk of working with suppliers whose supply chain extends into areas outside the EU, and has taken additional due diligence steps to ensure that those third-party supply chains comply with applicable employment standards.
As a family business which is firmly rooted in the local area, Bright Star Fireworks has always valued its wider role in delivering positive impacts, both within the local community and its wider supply chains. However, as the organisation has grown and global supply chains have become the norm, we recognised that a coordinated approach to sustainability and responsible business practice was required. We time to time review and refresh of all our existing policies and procedures.
Compliance with UK employment regulations
• Right to work checks
Under section 15 of the Immigration, Asylum and Nationality Act 2006 (the 2006 Act) an employer may be liable for a civil penalty if they employ someone who does not have the right to work in the UK. To ensure our compliance with this requirement, all current and prospective employees must provide evidence of their legal status and entitlement to work in the UK. For prospective employees, this evidence is checked before employment commences and a copy or the relevant documentation retained. Where agency staff is utilised, we ensure that we only work with reputable employment agencies and will always verify the practices of any new agency before accepting employees from them.
• Rate of Pay
As a minimum, all UK employees are paid in line with the National Living Wage. This is reviewed annually and increases made automatically where required. Whilst we are confident that we offer fair and competitive rates of pay, we regularly review this to ensure that our reward structures allow us to both attract and retain the talented individuals our growing business needs. All employees are paid via a payroll which is managed in accordance with HMRC regulations.
• Employing Young People
Whilst we seek to actively promote opportunities for young people and currently employ a number of apprentices, we do not employ people under 18 years of age due to the nature of the products on site. We are also alert to the risk of both conscious discrimination and indirect bias linked to age and carefully monitor our organisational age profile to ensure an appropriate balance is maintained.
• Terms of Employment
All permanent employees have a signed, written agreement which outlines the terms of their employment, including pay rates, working hours (in line with the Working Time Directive) and notice period.
In addition, all employees are provided with a copy of the Employee Handbook which sets out the code of conduct expected of our employees. At Bright Star Fireworks we set high standards for the behaviour we expect of our people and we trust them to maintain these standards and behave ethically at all times.
• Whistleblowing policy
We encourage all our employees, customers and other business partners to report any concerns related to our direct activities, or those of our supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure, which was fully reviewed and updated regularly, is designed to make it easy for our employees to make disclosures, without fear of retaliation.
Policies in Relation to Slavery and Human Trafficking
• Supplier ethical code of conduct
We are committed to ensuring that our suppliers meet our high ethical standards. We ask our direct suppliers to provide safe working conditions, treat their employees with dignity and respect, and act ethically and within the law in their use of labour. Given the potential for complexity in fireworks supply chains, we pay particular attention to promoting and monitoring ethical standards in our wider supply chain. We regularly visit, or have our over-seas representatives, visit all factories we use to manufacture fireworks.
• Anti-bribery and corruption policy
We are clear that bribery and corruption will not be tolerated within Bright Star Fireworks or our wider supply chains and we encourage employees across the supply chain to report any concerns that they may have so that we can investigate them fully.
Due Diligence and Assessing and Managing Risk
All new suppliers are subject to rigorous checks and due diligence process before contract commencement. We also regularly review our existing suppliers via methods including:
• Supply chain review process based on an initial supply chain mapping. Risk assessment linked to industry, geography and product.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains, including by reviewing, where necessary, the controls that our suppliers have in place and carrying out other suitable checks via supplier audits and/or assessments. Monitor potential risk areas in our supply chains on a periodic basis.
• Working with supplier to improve areas of concern, including providing advice and support to develop action plans
• In the case of serious violations or failure to improve, additional sanctions including contract termination.
Assurance and Key Performance Indicators
Responsibility for ensuring that our procedures are adequate and are adhered to in all areas of our activities rests with the directors of Bright Star Fireworks.
Training and Awareness
Everyone within Bright Star Fireworks has a responsibility to be alert to the risks, however small, of slavery and human trafficking within our business or in the wider supply chain. We also provide training to relevant employees on supply chain risks, including the risk of slavery and human trafficking at suitable intervals. Our participation in industry associations and our dealings with suppliers also provide information on where slavery and human trafficking risks may arise in the industries where we are active and best practice in avoiding them.
Employees are expected to report any concerns that they may have and we expect our suppliers to act upon them. Bright Star Fireworks and Cube Fireworks require all employees working with suppliers to be aware of the Modern Slavery Act and its objectives. Where required, modern slavery prevention training is provided to ensure awareness and compliance. Our Ethical Code of Conduct is also set out in our employee handbook and all suppliers are required to agree to operate in line with these fundamental principles.
Nature of this Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.
This statement has been approved by the board of directors of Bright Star Fireworks who will review and update it annually.