Our Policies

1. Introduction

1.1. We are committed to safeguarding the privacy of our website visitors and service users.

1.2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. 'Personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.3. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4. In this policy, "we", "us" and "our" refer to Fluid Branding Ltd. For more information about us, see Section 11.

2. How we use your personal data

2.1. In this Section 2 we have set out:

2.1.1. the general categories of personal data that we may process;

2.1.2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

2.1.3. the purposes for which we may process personal data; and

2.1.4. the legal bases of the processing.

2.2. Usage Data:

We may process data about your use of our website and services ("Usage Data"). This data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of this data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3. Lead Data:

We may process data about your company's use of our website and services ("Lead Data"). This data may include your company IP address, company name, business telephone number, email address and names of key decision makers at your company.

2.3.1. GatorLeads from Spotler:

We use GatorLeads as part of Spotler’s suite of marketing tools to collect information on visitors to our website. This is accomplished in the following ways:

2.3.1.1. Automatically: When you browse our website, we may collect information about your visit to our website, your usage of our service, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our website or Service. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below (see section 9). To ensure our prospects and clients receive the most relevant communications, we may use some automated processes to send you communications. These processes (such as lead scoring and marketing based on behaviour), might indicate what the contents of a marketing email may be, or indicate to us when the best time to contact you might be.

2.3.1.2. IP address lookup: When you visit our website we will record your IP address. This address will be matched against public and proprietary IP address databases to provide us with information about your visit. This information may identify the organisation to whom the IP address is registered but not individuals. In some limited cases i.e. single person companies, it may be possible to identify personal data from publicly available ICANN data.

2.3.1.3. Cookies, tracking & beacons: We may use various technologies to collect and store information when you use our website or Service, and this may include using cookies and similar tracking technologies, such as pixels and web beacons, to analyse trends, administer the website, track users’ movements around the website and Service, serve targeted advertisements, and gather demographic information about our user base as a whole.

2.3.1.4. The legal basis for the above processing is our legitimate interests, namely growing our business by forming relationships with new clients and developing relationships with existing clients in a B2B environment.

2.4. Service Data:

We may process your personal data that is provided in the course of the use of our services ("Service Data"). This data may include your name, email address, telephone number, physical address, company details, and information regarding your requirements for us to complete services offered to you. The source of this data is you or your employer. This data may be processed for the purposes of offering and selling relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4.1. Individual Mailing Data:

Certain orders may require us to deliver products and/or services to individuals on your behalf. Examples of such data include personal address information, names, and contact details. These individuals have not entered into a contract with us - this data is provided by you or your employer. We act as Processor to such data, with you as the Controller.

The legal basis for this processing is the performance of a contract between you and us. Details on our data retention policy can be seen in section 5. Individual Mailing Data will not be used for any other processing than that mentioned in this section (2.4.1). They will not be processed for marketing or prospecting purposes.

2.5. Transaction Data:

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("Transaction Data"). This data may include your contact details, your card details and the transaction details. The source of this data is you or your employer. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our business.

2.6. Marketing Data:

We may process personal data to market our products and/or services to users of our website and services ("Marketing Data").  This data may include name, company name, email address, job title, industry sector, information regarding your contact preferences, and any other information that may be deemed required to further enhance our ability to market products and/or services to you effectively. This data may be processed to send you email communications or show advertisements intended to offer you services and/or products that we think may be of interest to you.

We also use Google Signals - a feature of Google Analytics. Google Signals associates the data it collects from our website with Google data from accounts of signed-in users who have consented to this association, for the purpose of ads personalization. This data is used to provide aggregated and anonymized insights into cross device behaviours, and may include location, search and YouTube history, and data from certain Google Partner sites. To alter your personal settings, please visit https://myactivity.google.com/myactivity.

The legal basis for this processing is our legitimate interests for company growth based on a business to business company model.

We may obtain the above information;

2.6.1. Through you or your employer: This includes information given by you via form fills on our website or associated landing pages, or information provided verbally or in writing.

2.6.2. Through prospecting activities: We may obtain information about you from third party sources, such as public databases, data service companies, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us.

Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, email address, contact number, technographics, and online behavioural data (such as information about your use of social media websites, page view information, and search results and links).

We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.

2.7. Personalisation Data:

We may process personal data obtained in the aforementioned ways to build profiles on users of our website and services ("Profile Data"). This data may include company type, job title, department, industry sector, age, gender, information on the use of our website, general interests, and any other information that may be deemed required to further enhance our ability to market products and/or services to you effectively. This data may be processed to give us a wider understanding of how our website and services are used, as well as allowing us to improve and/or personalise your experience through the website. The legal basis for this processing is our legitimate interests, namely improving our website and services and business growth.

2.8. Correspondence Data:

We may process information contained in or relating to any communication that you send to us ("Correspondence Data"). This data may include the communication content and metadata associated with the communication. The source of this data is any communication you send to us, through email, via telephone or through forms on our website (through which the metadata is generated). This data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.9. Publication Data:

We may process information that you post for publication on our website or through our services ("Publication Data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The source of this data is any information you submit regarding our products and/or services, either via email or through channels such as review collection services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and growing our business through the publication of verified customer reviews.

2.10. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.11. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.12. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3. Providing your personal data to others

3.1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims.

3.3. We may disclose data to our suppliers insofar as reasonably necessary for the fulfilment of orders through our services.

3.4. Fluid Rewards is a client benefit offering points for each order placed, which can be redeemed for rewards such as gifts or experience days. This service is run on behalf of Fluid Branding by a third party, Incentivesmart.

3.4.1. Upon order completion, customers will be invited to sign up for this service.

3.4.2. Customers signing up for this service submit their personal data willingly to Incentivesmart.

3.4.3. Incentivesmart's Privacy Policy can be viewed here (https://rewards.fluidbranding.com/privacy).

3.5. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. International transfers of your personal data

4.1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2. We use third party facilities (such as our website hosting, and online chat software) in the United States of America. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the United Kingdom and the European Commission. Further details on these safeguarding measures can be obtained by emailing privacy@fluidbranding.com.

4.3. We use third party facilities (such as our supplementary graphics studio service, Binated) in India. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the United Kingdom and the European Commission. Further details on these safeguarding measures can be obtained by emailing privacy@fluidbranding.com.

4.4. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting your personal data

5.1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

5.3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5.4. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or purposes.

5.5. We will retain your personal data as follows:

5.5.1. Personal Data will be retained by Fluid Branding for as long as there is a legitimate business need for retention, unless otherwise stated in this clause, including for the purposes of  satisfying any legal, regulatory, tax, accounting, record keeping, analysis, reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

5.5.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

5.5.3. Google Analytics Data will be retained for a maximum period of 50 months following the user's last session on our website, as per our Data Retention Policy.

5.5.4. A copy of our Data Retention Policy is available upon request, and can be obtained by privacy@fluidbranding.com.

5.6. As stated in section 7.5, you have the right to request removal of your personal data from our systems. See section 7.5 of this policy for further details on the right to erasure.

5.7. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments to this policy

6.1. We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

6.2. We may notify you of changes to this policy by email.

7. Your rights

7.1. In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2. Your principal rights under data protection law are:

7.2.1. the right to access;

7.2.2. the right to rectification;

7.2.3. the right to erasure;

7.2.4. the right to restrict processing;

7.2.5. the right to object to processing;

7.2.6. the right to data portability;

7.2.7. the right to complain to a supervisory authority; and

7.2.8. the right to withdraw consent.

7.3. You have the right to request access to your personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.5.1. It may take up to 28 days for any such request for erasure to take effect in our systems. Occasionally it could take us longer than 28 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

7.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9. To the extent that the legal basis for our processing of your personal data is:

7.9.1. consent; or

7.9.2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.10. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In the UK this will be the Information Commissioner's Office (ICO).

7.11. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.12. You may exercise any of your rights in relation to your personal data in writing to us at our registered office address.

8. About cookies

8.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies used on our website

9.1. We and our service providers use cookies and those cookies may be stored on your computer when you visit our website.

9.2. The following is a list of cookies that are set on our website whilst browsing, along with information of the third party that sets them (if applicable), and an explanation of their purpose:

10. Managing cookies

10.1. You can use the button below to edit your cookie preferences for this website:

Cookie Settings

11. Our company details

11.1. Our website is owned and operated by Fluid Branding Ltd.

11.2. We are registered in England and Wales under registration number 05867605, and our registered office is at ESAM, Carluddon Technology Park, Carluddon, St Austell, PL26 8WE.

11.3. You can contact us:

11.3.1. by post, to the postal address given above;

11.3.2. using our website contact form;

11.3.3. by telephone, on the contact number published on our website; or

11.3.4. by email, using enquiries@fluidbranding.com.

12. Data protection contact details

12.1. Fluid Branding is not required by law to appoint a Data Protection Officer, however any enquiries relating to privacy and data laws can be directed to privacy@fluidbranding.com.

Background

Fluid Branding believes that it is important to behave in a socially and ethically exemplary way. We believe that we are responsible for the people who take part in the production and support of our products and services worldwide. We believe that people whose work contributes to our success should not be deprived of their basic human rights, nor be forced to suffer physically or mentally from their work in any way.

Purpose

Fluid Branding expects employers to respect fundamental human rights, to treat their workforce fairly and with respect. In order to make our position clear to our own staff, our suppliers and any other affected parties, we have documented an Ethical Policy.

Application

This directive is applicable to Fluid Branding operations as well as Fluid Branding suppliers. All Fluid Branding suppliers are also requested to sign an Ethical Trading Initiative (ETI) Base Code of Conduct.

 

This document outlines Fluid Branding's intent to work in a responsible and sustainable way. It sets out the policies which guide our operation and our overall approach to the five key areas of sustainable business: People, Communities, Ethics, Environment and Quality. CSR and Sustainability are terms used often, and often misunderstood. They are also fast-moving concepts - subject to continuous change as global understanding of these areas improves and the bar is raised higher. Because of this, we do not claim to have all the answers. However, we do believe we have the right attitude and the very best intentions - and firmly commit our business always to change and improve whenever new ideas show us better ways of working. When our clients work with Fluid Branding we will ensure they can trust us to provide quality, effective services and solutions - all safely delivered within the parameters of this policy, protecting both their brand reputation and ours.

1. Our people

Fluid Branding is passionate about its people and believes strongly that we can only meet our business objectives through a well-trained, empowered and motivated workforce who also enjoy working with us. We aim to be a fair and respected employer, one valued by its employees.

Our commitment:

"Fluid Branding will offer fair and equal employment opportunities for all - regardless of gender, race, religion, or age. We will provide a good quality working environment, with comfortable facilities, the most appropriate technology and equipment, and individual attention to career planning and support. We will always provide the right level of health and safety equipment and training. We aim to not just meet, but exceed, the necessary legislation. We will communicate properly our company aims, values and objectives, and consult our people about all relevant issues."

2. Our community

We intend to operate our business always to the highest standards. This also affects our behaviour in respect of the community in which we operate and other organisations with which we come into contact. In our local area, we will seek actively to be involved in community projects and initiatives, business mentoring and charity contributions, to extend our value to the local economy and community. We will engage constructively and shape our activities so that our business is always regarded as a valued and listening contributor to local life.

Our commitment:

"Fluid Branding view our local community as an asset and one in which we should fairly invest and give-back to through wide-ranging means. Ultimate measurement is demonstration that our community is enhanced as a result of the Fluid Branding business operating within it."

3. Our ethics

We will apply the highest possible business ethics in all our supplier relationships focussing on integrity, professionalism and standards. An important aspect of our work involves buying materials in overseas marketplaces. Wherever we buy, we will apply the same high standards that we apply to our own local operation plus additional diligence in relation to the pertinent additional risks.

Our commitment:

"All Fluid Branding personnel responsible for supplier relationships shall be trained in and abide by the Chartered Institute of Purchasing and Supply 'Personal Code of Ethics'. All Fluid Branding suppliers shall have completed and passed the Fluid Branding 'EEQ (Ethical, Environmental & Quality) Commitment' prior to achieving 'approved supplier' status. The Ethical element of this commitment will work towards standards outlined within the SA8000 accreditation by Social Accountability International, the leading international benchmark for ethical compliance. Further, random audit programmes shall be undertaken by both Fluid Branding and independent, accredited and recognised bodies, to ensure information contained within the 'EEQ Commitment' is executed satisfactorily."

4. Our environment

Fluid Branding seeks to operate its business in a sustainable way, which minimises our impact on the environment. We operate a process of continuous improvement that reacts quickly to new advice and will seek always to apply the most up to date standards.

This takes account of several factors. Internally the approach manifests itself through the intelligent and minimal use of resources such as energy and water and effective waste handling, promoting multi-material recycling with zero-tolerance to landfill.

Externally we shall ensure that product suppliers hold similar values and have a process-driven approach in this area. We shall then consult with clients on environmentally positive alternatives when developing merchandise programmes as well as ensuring a continual focus with transport partners on programmes to reduce emissions impact.

Our commitment:

"Fluid Branding will work to the standards of ISO 9001, the internationally accepted standard for development and execution of an effective Quality Management System."

5. Our quality

Fluid Branding recognises Quality is the cornerstone of our business. Without the provision of a quality service and quality products we will not have a sustainable business.

Our commitment:

"Internally, all Fluid Branding managers will have quality-orientated SMART objectives for their departments, which shall be regularly reported, analysed and reviewed. Product sourcing quality comprises both Quality Assurance and Quality Control. QA is the "designing-in" of quality prior to manufacture through the pertinent testing of a particular product to relevant standards. QC is the post-manufacture control of this, minimising the risk of sub-quality product reaching consumers. Audit logs of QA and QC checks employed will be maintained for all sourcing activity."

Purchasing a sample

In most cases, products that appear on our website can be purchased as single, unbranded samples. This can give you a better understanding of the end product, and help with the decision making process. If a product is available for a sample purchase, you will find a link to purchase the sample on the main product page of that item.

Details of costings for individual samples can be found on the samples page for that product, but generally samples are charged at their base unit rate, plus delivery (£9.95 or your currency equivalent).

It is not possible to specify colour choices or branding for a sample purchase - they are intended as an indicator to help guide you only. In some cases, the sample provided may be a ‘dummy’ product only, and will not have the full functionality of the end product (for example: USB flash drives may not work as data storage devices).

Please note, you can only purchase a maximum of 5 samples of a particular item at any one time. If you have additional sample requirements, please contact our sales team. Any additional purchases beyond this limit will be refunded to the buyer.

Obtaining a sample during the order process

If you are placing an order with us, in most cases we can provide a sample free of charge. If a period of 30 days has passed and you have not placed the order with us, then we will invoice you for the sample(s). Please note - certain high value items will be chargeable, even if an order has been placed. Please seek advice from your account manager for further details.

Returns and Refunds

Our products come from the UK, Europe and the Far East and as such not all samples are returnable. This is due to high logistics and shipping charges. Please as your account manager for further details if you require information on a particular product sample.

Delivery

Delivery is based on a UK address. Please contact us for samples outside the UK.

Our WEEE registration number is - WEE/CB4238XX.

WEEE stands for Waste Electricals and Electronic Equipment. If you are a producer of electrical equipment you are required by law to join a compliance scheme.

Introduction

This statement is made on behalf of Fluid Branding Ltd pursuant to section 54(1) of the Modern Slavery Act 2015 (‘The Act’) and constitutes our Anti-Slavery and Human Trafficking Statement for the financial year ended July 2018.

Fluid Branding Ltd is committed to social and environmental responsibility and at all times tries to ensure that our supply chains are free from forced labour slavery and human trafficking.

Organisation Structure

Fluid Branding Ltd is one of the UK’s largest distributors of promotional merchandise. We have offices across the UK, Ireland, Malta and Amsterdam as well as a US Partnership.

Supply Chains

Our supply chains include the sourcing and distribution of promotional products and apparel suitable for all promotional marketing requirements.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery, servitude and forced compulsory labour or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due Diligence Processes for Slavery and Human Trafficking

We are confident that we have a robust system for monitoring our supply chain and we have a zero tolerance for any factory that may be found to be engaged in human trafficking and slavery.

We require our suppliers to abide by our code of conduct. We also conduct factory inspections and audits, which include criteria related to unacceptable labour practices embodied in the Act.

As part of our initiative to identify and mitigate risk we have in place systems to:

• Identify and assess potential risk areas in our supply chains
• Mitigate the risk of slavery and human trafficking occurring in our supply chains
• Monitor potential risk areas in our supply chains
• Encourage the reporting of concerns and the protection of whistle blowers

Risk Assessment

We consider that the main areas at risk of Modern Slavery at Fluid Branding Ltd are our workforce, subcontractors and suppliers, and that the risk of Modern Slavery occurring in any of these areas is being proactively managed through the efforts of the Anti-Slavery Compliance Team and the measures described in this Statement.

Supplier Adherence to our Values

We have a zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and suppliers comply with our values or ethics we have in place a supply chain compliance programme.

We have a dedicated compliance team, which consists of involvement from the following departments:

• Procurement
• Human Resources

Further Steps

We will continue to keep under review our internal processes to identify what further steps can be taken to ensure that our obligations under the Act are met and that our Anti Slavery Policy is effectively implemented and complied with, so as to ensure that there is no slavery or human trafficking in any part of our business.

Some of the specific measures we are considering include:

• Enhancing our employee verification checks to minimise the risk of slavery
• Continuing to review our procurement processes to consider what, if any, adjustments might be made to further reduce the level of risk of slavery and human trafficking in our supply chains
• Considering what KPIs may be appropriate for us to adopt