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.

 

Hotcakes (T/A Elitetins 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.

 

This statement sets out the actions that Hotcakes is taking to ensure the business complies with the Modern Slavery Act 2015. It sets out how Hotcakes Ltd is seeking to ensure that modern slavery and human trafficking is not taking place within the business or supply chains. This constitutes our slavery and human trafficking statement for the financial year ending 31st March 2026.

 

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 gift ware 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. 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 Director is 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;
 

1. Products developed and manufactured in China and subsequently shipped to our UK warehouse.

2. Food fills manufactured in the EU (predominantly the UK) used in Tin Treats.

3. Services and miscellaneous items sourced in the UK.

 

Risk Assessment
We recognise that the risk of modern slavery varies by geography and sector. Overseas manufacturing, particularly in higher-risk jurisdictions, presents a greater inherent risk than UK-based suppliers operating under UK employment law.
 

Accordingly:
 

• Our overseas manufacturing supply chain is identified as higher risk.

• UK and Netherlands food suppliers are assessed as lower risk due to strong labour law frameworks.

• UK service providers are considered lower risk but remain subject to review.

 

We have a zero tolerance to slavery and human trafficking. We periodically review our supply chain to identify and assess potential risks of modern slavery and human trafficking and to ensure compliance with anti-slavery measures.
 

To mitigate risk within our supply chains, we implement the following measures:
 

• Ongoing review of supplier ethical standards

• Encouragement of SEDEX registration for overseas suppliers

• Monitoring of ethical audit documentation where available (including SMETA audits where applicable)

• Inclusion of anti-slavery expectations within our manufacturing agreements.

• Assessment of suppliers prior to engagement, particularly for higher-risk geographies

• Maintenance of long-term supplier relationships to encourage transparency and accountability
   

We continue to work towards ensuring all key overseas suppliers maintain active SEDEX membership.

 

Supplier Adherence

Suppliers are expected to:

• Comply with all applicable labour and employment laws

• Prohibit forced, bonded or compulsory labour

• Ensure that employment is freely chosen

• Provide safe and hygienic working conditions

• Pay wages in line with applicable legal standards
   

If concerns arise regarding a supplier’s practices, we will investigate promptly and take appropriate action, which may include corrective action plans or termination of the relationship where necessary.

 

Steps taken in the financial year to end March 2026

All relevant staff have had refresher training to raise awareness of modern slavery and associated risks. Employees are encouraged to report any concerns relating to modern slavery directly to the Operations Manager. Reports will be treated confidentially and investigated promptly. Suppliers are also encouraged to inform Hotcakes ltd of any reports or investigations relating to modern slavery.

 

We have made significant progress in ensuring all of our oversea suppliers are SEDEX registered.

 

To date, no instances of modern slavery or human trafficking have been reported within our business or supply chains during the financial year ending 31 March 2026.

​

Further Steps

Update and formalise our supply chain risk assessment
 

Review supplier onboarding documentation to strengthen modern slavery controls
 

Continue monitoring supplier compliance documentation

 

Continue working to ensure all overseas supplies are SEDEX registered.

 

​This statement has been approved by the Director and will be reviewed annually. Last review: March 2026​