Modern Slavery Act Statement
Modern Slavery Statement
Modern slavery is a crime and a violation of fundamental human rights. Allowing it to take place within an organisation, either consciously or through complacency, results in extensive and unnecessary suffering – often in a way that disproportionately affects groups of the most disadvantaged people.
We are committed to acting ethically to implement and enforce effective systems and controls to ensure modern slavery is not taking place within our operations or supply chains.
Our organisational structure and business
We design, make and sell fantasy tabletop miniatures, games and associated hobby products (including books, paints, and other modelling accessories). We also licence our intellectual property (IP) to carefully selected partners to allow them to exploit our IP in connection with board games, merchandise and apparel, and media and entertainment.
We are a vertically integrated business, retaining control over every aspect of design, manufacture and distribution of our miniatures and games.
The Games Workshop head office is located in Nottingham, UK, and includes the main design and manufacturing facilities. Distribution centres to support our global sales network are located in Castle Donington, Derby, Memphis, Tennessee and Sydney, Australia.
Our products are sold through a chain of over 500 retail stores in the United Kingdom, the United States, Canada, Australia, New Zealand, Japan, China, Hong Kong, Malaysia, Singapore, France, Germany, Spain, Italy, the Netherlands, Eire, Belgium, Austria, Poland, Norway, Sweden, Denmark and Finland. Products are also sold through more than 6,000 other hobby, game and toy shops around the world. These outlets are complemented by our global webstore.
In addition to our international workforce, we also rely on a network of global suppliers for the sourcing of raw materials and components for the manufacture of our products, the sourcing of supplementary hobby products for resale, and the procurement of goods and services needed for day to day business operations.
All of our suppliers are required to meet the standards set out within our Anti-Slavery Policy.
All suppliers of products or product components are required to undergo independent third party ethical sourcing audits in order to become and remain a Games Workshop supplier.
We have not found any evidence of slavery through these audits.
All employees of Games Workshop are required to comply with our Anti-Slavery Policy at all times. Any breach of the Anti-Slavery Policy by an employee shall result in disciplinary action being taken against that employee.
All of Games Workshop’s suppliers and partners are required to meet the compliance standards set out within the Anti-Slavery Policy.
The key principles outlined in our anti-slavery policy are:
that we undertake all business ethically and with integrity in accordance with all applicable laws and regulations.
that we take a zero tolerance approach to acts of slavery, and operate in full compliance with our obligations under all applicable anti-slavery legislation, including the Modern Slavery Act 2015.
that we will not undertake business with any suppliers which do not agree to act in a manner consistent with our commitment against slavery.
The Anti-Slavery Policy is communicated to all suppliers of (i) raw materials and components used for the manufacture of our products, and (ii) supplementary hobby products for re-sale. These suppliers are required to comply with the Anti-Slavery Policy as part of our corporate social responsibility (CSR) requirements. These CSR requirements are detailed within our Supplier Manual, purchase agreements and within our standard terms and conditions for the purchase of goods and services.
Our suppliers of goods and services for day to day business operations, as well as our licensing partners, are also required to meet the compliance standards set out within the Anti-Slavery Policy. This may be achieved by requiring these suppliers and partners to comply with our standard CSR requirements in the manner detailed above, or by reliance on the ethical codes and standards of these suppliers and partners where appropriate.
Modern slavery risks are identifed, assessed and managed as part of our company-wide risk management process. Risks are identified through a range of processes at all levels of the business. Each identified risk is assessed based on the likelihood of occurrence and the potential impact of that risk.
The effective management of modern slavery risks forms an important part of our Social Responsibility and Sustainability (SRS) strategy. Responsibility for management of modern slavery risks – such as maintenance of our associated policies, training, and risk assessment activities – lies with our Head of Social Responsibility and Sustainability.
Ultimate accountability for modern slavery risks sits with our Board. These risks are reviewed via our Audit and Risk Board Committee, at least twice a year.
Whilst we consider the overall risk of modern slavery to be low, we recognise the following areas of our business as being at elevated risk and so additional controls are implemented in order to manage this risk.
Licensing, Buying and Merchandising – Our supply chain is global and when we engage with external companies (often in diverse industries and high risk territories), our ability to control and influence how modern slavery risks are managed is reduced. This increases the likelihood of a situation where our business becomes associated with an organisation that does not conform to our high standards for ethical and responsible business practices.
Recruitment – The use of agency workers in our operations and facilities through a third party reduces our visibility for how these employees are treated by their employer. This increases the likelihood of a situation where our business becomes associated with activity that does not conform to our high standards for ethical and responsible business practices.
Our staff that work in these areas receive mandatory refresher training on our policies regarding modern-slavery, responsible supply chains, and ethical sourcing. This includes tailored sessions that provide relevant examples for each business function and provide clear guidance on how to evaluate the business practices of potential partners and ensure they have robust anti-slavery and responsible business practices in place that are at least equivalent to our own.
Due Diligence Processes
As part of our systems and controls to ensure modern slavery is not taking place within our operations or our supply chains, we undertake the following:
Appropriate vetting and due diligence in respect of all new suppliers.
Whenever possible, we maintain long standing relationships with suppliers, such relationships being based on good supplier performance and trusted compliance with Games Workshop’s CSR requirements.
Auditing and inspections of suppliers. All suppliers of products or product components are required to undergo independent third party ethical sourcing audits in order to become and remain a Games Workshop supplier. We have not found any evidence of slavery through these audits.
Conducting risk assessments every year to identify those areas of the business that may be regarded as being at high risk of exposure to slavery, with such high risk areas being subject to additional safeguards.
Reporting procedures for employees and suppliers which encourage the reporting of any incidents of potential, suspected, attempted or actual slavery.
Communication and Training
We communicate our Anti-Slavery Policy to all employees, and to suppliers in the manner described above. We provide training to relevant members of staff in connection with the Anti-Slavery Policy and help them maintain our high standards of ethical and responsible business practices.
We will continue to review and update our policies and procedures as required to ensure that appropriate safeguards are maintained against modern slavery within our operations and our supply chains.
This statement is made on behalf of all companies within the Games Workshop group, including but not limited to, Games Workshop Group PLC, and Games Workshop Limited.
This statement is approved by the board of directors of the Games Workshop group, is made pursuant to section 54(1) of the Modern Slavery Act 2015, and constitutes our slavery and human trafficking statement for the financial year ending 29 May 2022.
Chief Executive Officer
Games Workshop Group