01
Purpose and scope
This policy consolidates the company’s human-rights, modern-slavery, ethical-recruitment, child-labour, worker-welfare, supplier, due-diligence, training and grievance commitments. It applies to:
- employees, workers, contractors and anyone acting on the company’s behalf;
- direct suppliers, wholesalers, manufacturers, distributors, brands and service providers;
- human hair and synthetic wigs, toppers, systems, headwear, caps, lace, tapes, adhesives, aftercare products, packaging, logistics, fitting, alteration and maintenance;
- supplier selection, purchasing, product records, customer service, complaints, referrals and corrective action.
The policy is applied proportionately. Higher attention is directed to products, sourcing routes and business relationships with the greatest potential impact on people.
02
Principles and commitments
- Respect dignity and rights. People connected to our operations and supply chains should be treated fairly, lawfully and with dignity.
- Prioritise severe risks. We focus first on forced labour, trafficking, child labour, unsafe work, recruitment-fee debt and coercion.
- Seek reliable information. We request proportionate supplier and product information and pay attention to unexplained gaps, inconsistent claims and unusually low prices.
- Improve over time. Due diligence is ongoing; a policy is not proof by itself.
- Put people before process. Safety, confidentiality, non-retaliation and appropriate remedy take priority where exploitation may have occurred.
03
Human-rights and labour standards
Forced labour, trafficking and freedom of movement
- Work must be freely chosen. Forced labour, bonded labour, involuntary prison labour, slavery, servitude and trafficking are prohibited.
- Workers must not be controlled through threats, violence, coercion, deception, debt, withheld wages, restricted movement or confiscated identity documents.
- Identity documents may only be handled temporarily for lawful verification, with the worker’s knowledge and prompt return.
Child labour and young workers
- Child labour and work that is exploitative, harmful, unsafe or interferes with education or development are prohibited.
- Suppliers must comply with applicable minimum-age, education, employment and health-and-safety laws and maintain appropriate age-verification processes.
- Any response should protect the child’s safety, welfare, education and long-term interests.
Ethical recruitment and migrant workers
- Recruitment must be lawful, fair, transparent and non-discriminatory.
- Workers should receive accurate information about role, pay, hours, location and conditions before accepting work, in a language they understand where reasonably possible.
- Workers must not be charged unlawful or excessive recruitment fees or trapped through debt linked to recruitment, travel, accommodation or employment.
- Migrant workers must receive the same dignity and lawful protections as other workers.
Wages, welfare and safety
- Wages, deductions, benefits and working hours must comply with applicable law and agreed terms.
- Working conditions and any employer-linked accommodation must be safe, hygienic and appropriate.
- Discrimination, harassment, abuse, threats and retaliation for raising concerns are prohibited.
04
Supplier and product expectations
These expectations form our Supplier Code of Conduct. Suppliers are expected to cooperate with reasonable information requests and to tell us if a serious labour, traceability, safety or ethical-sourcing concern may affect supplied products or services.
- Provide accurate legal identity, contact, trading and manufacturing information where relevant.
- Provide accurate product descriptions, composition or fibre type, manufacturer or brand, country of supply or origin where known, order or batch references, care instructions and safety warnings.
- Do not make ethical-sourcing, origin, hypoallergenic, medical, safety or quality claims without a reasonable basis.
- Maintain lawful employment, wage, working-time, recruitment, equality, health-and-safety and welfare practices.
- Do not conceal labour arrangements, subcontracting, manufacturing locations or known concerns in response to a reasonable enquiry.
- Cooperate with proportionate review, corrective action, complaints, product-safety enquiries and recalls.
05
Risk-based due diligence
Additional checks may be appropriate before introducing a new key supplier; for human hair sourcing, hand processing, ventilation, overseas manufacture, lace, caps, adhesives, tapes and very low-cost accessories; when a supplier or product changes materially; following a complaint or traceability gap; and during annual review.
Checks may include
- supplier identity, address, contact information and trading details;
- product category, brand or manufacturer, country of supply or origin where known, invoices, order records, labels and batch references;
- supplier policies, declarations, certifications or sourcing information where relevant and available;
- pricing, product claims, complaints, recalls, traceability and known labour-risk indicators;
- clarifying questions, further evidence or corrective-action requests.
Warning signs
- unwillingness or inability to provide basic company, product or origin information;
- unusually low prices without a credible commercial explanation;
- vague, conflicting or unsupported human-hair sourcing and ethical claims;
- recruitment-fee debt, document retention, withheld wages, coercion, unsafe work, child labour or forced labour;
- unexplained subcontracting or traceability that changes when challenged.
06
Prevention, corrective action and remedy
Where a concern is identified, the Director will consider the seriousness and immediacy of potential harm, the available evidence, the supplier’s response and the risk that an abrupt decision may cause further harm.
- Seek clarification, supporting evidence or specialist advice where appropriate.
- Pause an order, product listing or supplier relationship during review.
- Agree time-bound corrective action and request evidence of completion where proportionate.
- Reduce, suspend or stop purchasing where risk cannot be addressed or serious non-compliance continues.
- Escalate to an appropriate contracting authority, safeguarding lead, regulator, law-enforcement body or statutory agency.
- Prioritise safety, confidentiality, non-retaliation and appropriate support where a victim or potential victim is identified.
07
Raising a concern
Employees, workers, suppliers, clients, carers, referral partners, NHS staff, contractors and members of the public may raise a concern about exploitation, unsafe working practices, misleading traceability, unethical sourcing or supplier conduct.
- Email: info@afiovana.com
- Telephone: 01629 380880 or 07835 919 800
- Post: Sarah Afiovana Ltd, 56 Overdale, Matlock, England, DE4 3ES
Please provide enough information to understand the concern, but do not put yourself or another person at risk to gather evidence. Information will be handled as confidentially as reasonably possible, subject to safeguarding and legal duties.
08
Governance, training and monitoring
- The Director owns this policy and oversees proportionate due diligence, escalation and annual review.
- Anyone supporting purchasing, supplier communication, product records, client service or complaints will be briefed on relevant warning signs and reporting routes.
- The company will retain proportionate records of key suppliers, material product information, concerns, actions and policy review.
- At least annually, the Director will review supplier reviews, identified risks, concerns, corrective actions, awareness briefings and material changes.
A zero-incident figure will not, by itself, be treated as proof that no risk exists.
09
Review and publication
This is a voluntary public policy. It is not presented as a statutory modern-slavery statement for a particular financial year. If the company becomes subject to a statutory, contractual or procurement reporting requirement, it will prepare the specific approval, period-based disclosure and evidence required for that purpose.
REFERENCE FRAMEWORK
Standards informing this policy
References do not imply certification, external audit or endorsement.