OFFICIAL MODERN SLAVERY STATEMENT

LAST REVISION DATE: January 15, 2020

This slavery and human trafficking statement is made by ELITE PROMO INC (EPI) pursuant to section 54 of the Modern Slavery Act 2015 (the "Act") for the financial year ending on January 31, 2020. It sets out the steps taken by EPI to ensure that slavery and human trafficking are not present in our business or direct supply chain.

ABOUT US

EPI is the leading purveyor of premium corporate gifts and customized merchandise. Headquartered in San Mateo, California, EPI serves a global clientele in a wide range of industries and sectors.


OUR SUPPLY CHAIN

At EPI, we consider ourselves to be relatively low risk in relation to modern slavery, given the services we provide and the type of suppliers we use. We periodically review our use of suppliers and, as necessary, adapt our processes if we determine that our risk has changed.


OUR APPROACH TO COMBATING MODERN SLAVERY

EPI is committed to conducting business in a responsible and ethical manner. We have a zero tolerance approach to modern slavery and expect the same high standards and commitment from those we do business with.

EPI’s internal policies and procedures aim to ensure that effective systems and controls are in place to prevent slavery and human trafficking from occurring in any part of our business. EPI’s Code of Conduct and Business Ethics promotes a culture of integrity by establishing principles for how we deal with our clients, employees and the public. Amongst other things, the values and rules set out in the Code encourage us to foster a safe, healthy and productive workplace and to maintain accountability at all levels of the organization. Employees are encouraged to report any concerns they may have, including in relation to the occurrence of slavery or human trafficking, either to management or through an anonymous ethics helpline.

Suppliers forming a key part of EPI’s supply chain undergo a standardized vetting process, with the use of template agreements and a standard questionnaire to gather relevant information. EPI also runs due diligence reports on all of these suppliers as part of the vetting process. All key suppliers must be vetted and approved before they can be used on any engagement. The vetting process is designed as a risk mitigation measure to provide the best service for our clients and to protect our brand.


NEXT STEPS

Our Company will continue to review and update policies and procedures with respect to this issue.