Modern Slavery Act 2015

Anti-Slavery and Human Trafficking Statement*

*with reference to the Modern Slavery Act (2015)

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another, in order to exploit them for personal or commercial gain.

This statement sets out the actions that Hotcakes Ltd is taking to ensure the business complies with the Modern Slavery Act (2015) and that modern slavery and human trafficking is not taking place within the business or its supply chains.

This constitutes our anti-slavery and human trafficking policy for the financial year ending 30th June 2017.

Hotcakes (T/A Elite and Tin Treats) is committed to ensuring that there is no modern slavery or human trafficking occurring within our business or supply chains. Our policy reflects our commitment to use only ethical and legal business practices and to implement effective controls to ensure these practices are not taking place in our supply chains.

Organisational Structure

Hotcakes is a limited company registered in England (No 1970768) trading as Elite and Tin Treats. Elite are designers and contract manufacturers of homeware and giftware sold wholesale in the UK and exported worldwide. Tin Treats supplies food-filled giftware for wholesale, mainly to the UK gift industry. Approximately 90% of the food-fills used are sourced from within the UK, 10% from the Netherlands.

Hotcakes pays all permanent members of staff over and above the National Living Wage and complies with the Working Time Regulations (1998). When recruiting we carry out checks to ensure potential staff members have the right to work in the UK. All salaries are paid directly into the employee’s own bank account. On occasion, in the autumn season we contract a small number of temporary staff, all temporary staff are sourced from reputable UK employment agencies.

Key Responsibilities

The Directors are responsible for ensuring Hotcakes complies with the Modern Slavery Act.
The Operations Manager has primary and day-to-day responsibility for implementing, monitoring and dealing with any queries on the policy.

Supply Chain Categories

We can divide our supply chain into three main pathways:

A: Products developed and manufactured in China and subsequently shipped to our UK warehouse;
B: Food-fills manufactured in the EU (predominantly in the UK) and used in Tin Treats;
C: Services and miscellaneous items sourced in the UK.

Supplier Adherence

We have a zero tolerance approach to slavery and human trafficking and will review our existing suppliers to ensure compliance with anti-slavery measures.

Steps taken in the financial year to end June 2017

We have compiled an Anti-Slavery and Human trafficking Statement (although this is not mandatory as our turnover is below the threshold value of 36M).

We have appointed a compliance director, the Managing Director, who has responsibility, together with the Operations Manager, for overseeing policies and procedures, including the preparation of the annual anti-slavery and human trafficking statement.

Relevant staff members have been trained to raise awareness of modern slavery and to recognise its associated signs and risks.

We have instigated a risk assessment of our supply chain; the main focus initially will be on our suppliers overseas.

Further Steps

Record and investigate any allegations made to us by staff or any suppliers.

Finalise and update the risk assessment of our supply chain.

Update any training needs.

This statement has been approved by the Director and will be reviewed annually.


James Brierley
Managing Director of Hotcakes T/A Elite and Tin Treats
14th July 2017