Introduction
This statement is made on behalf of Mustang Advertising Trading LLC (“GIFTSUPPLIERS4UAE”) pursuant to section 54 of the Modern Slavery Act 2015 and comprises our slavery and human trafficking statement.
Our Business
Mustang Advertising Trading LLC is the leading direct marketer of promotional merchandise in United Arab Emirates, India and Australia.
We supply custom imprinted products that are used with the aim of promoting an organisation, brand, product or event.
Our product range is comprised of around 70% hard goods, for example drinkware, writing instruments, stationery, office products and tech accessories, and 30% soft goods, including apparel, bags, towels and blankets.
Currently, Mustang Advertising Trading LLC has around 20 permanent staff, based in Dubai, United Arab Emirates. The remainder are located in either India or Australia.
Our staff, whether directly employed by a Mustang Advertising Trading LLC entity or engaged through a long-term temporary agency partner, are not in any category that is generally seen to be vulnerable to modern slavery in the UAE. Our focus with regard to slavery and human trafficking is, therefore, primarily directed towards our supply chain.
Our Supply Chain
We are acutely aware that our supply chain is long and often complex, extending far beyond our domestic supply base.
Mustang Advertising Trading LLC does most product decoration/imprinting in our production warehouse in Ras al Khor, dubai, UAE.
Our tier 1 suppliers are predominantly domestic suppliers of ink or machine inputs that are purchased from renowned manufacturers who have their own compliance in place.
The main Machines , inks and parts we use for our manufacturing are from the below suppliers
Our domestic tier 1 suppliers, in turn, purchase most of their blank inventory from tier 2 manufacturers of the base product who may be located around the globe. China and the USA represent the dominant countries of tier 2 manufacture, together accounting for around 80% of our products. Products may also originate in Central America, South and East Asia, and a small amount from African markets.
Further down the supply chain are tier 3 suppliers who are generally raw material suppliers, component manufacturers or process specialists, e.g. dye houses.
Our Policies on Slavery and Human Trafficking
Generally, our Social and Ethical Policy Statement reflects our over-riding commitment to acting ethically and with integrity in all of our business relationships.
Specifically, our aim is to guard against the occurrence of modern slavery or human trafficking in any part of our business or at any level in our supply chain through the communication of our expectations, the implementation of appropriate procedures and the other actions that we take.
Furthermore, our Whistleblowing Policy acts in tandem with our policies on slavery and human trafficking by encouraging staff to report concerns including any situations related to modern slavery, human trafficking and child or forced labour.
Despite our best intentions and the steps that we take, a possibility remains that without our knowledge and consent certain factors may compromise our ability to mitigate against the risk of slavery or human trafficking occurring at some level in our supply chain. When any such circumstances come to our attention, we will take prompt and decisive action with a view to remediating the situation as a first preference, whilst ultimately being prepared to terminate the offending supply relationship if necessary.
What are we doing?
It is our view that the risks of modern slavery, human trafficking and related social issues increase the further that we go back in our supply chain. This view is based on the US State Department’s Trafficking in Persons assessments and is backed up by our extensive supply chain experiences over the last decade and more.
We have implemented a Supply Chain Code of Conduct to address the risk of modern slavery, human trafficking and broader corporate and social responsibility perspectives. This Code of Conduct is in line with International Labour Organisation principles and the Fair Labor Association’s Code of Conduct. The signature of our tier 1 suppliers to this document affirms their acceptance.
Compliance is reviewed and verified through site visits/inspections by 4imprint’s merchandising and vendor compliance specialists. These visits extend to tier 1 suppliers’ domestic facilities, as well as the operations of their overseas (tier 2) manufacturers. A high level of trust and transparency is essential for our suppliers to allow us access into their supply chains.
In addition, we conduct a programme of independent audits, carried out by reputable third party audit firms, of tier 2 supplier facilities, including worker interviews, review of recruitment processes, grievance mechanisms and other common potential indicators of modern slavery. Audit failures or material issues raised are addressed as a matter of priority.
Awareness
We concentrate our awareness initiatives on those members of staff who are involved with the supply of products. Awareness of modern slavery, human trafficking and related issues tends to be communicated to appropriate supply chain team members by senior merchandising and vendor relations/compliance managers who are active in visiting and assessing our tier 1 and tier 2 suppliers.
We anticipate that our awareness and training programme regarding modern slavery and human trafficking will continue to be refined and expanded in 2019 and beyond.
Responsibility
Responsibility for overseeing and implementing of the contents of this Statement rests with the Senior Vice President – Merchandising and Supply Chain (suppliers and supply chain), the Senior Vice President – Administration (4imprint internal operations), and ultimately the Chief Executive Officer.
Approval
This statement has been formally approved by the Directors of 4imprint and signed by the Chief Executive on their behalf.
