Costrick Modern Slavery Statement 2026

Version 1.0 / August 2025 / Business-to-Business Platform / English

Introduction

Costrick Ltd, a company registered in Scotland (company number SC806470) at 6 Ristol Road, Glasgow, G13 1UY, is committed to combating modern slavery and human trafficking in all its forms, including forced labour, bonded labour, child labour, and exploitation for personal or commercial gain. As a B2B platform connecting convenience store retailers and wholesalers, we recognize our responsibility to uphold human rights across our operations and supply chain, in line with the UK Modern Slavery Act 2015, the UN Guiding Principles on Business and Human Rights, and the International Labour Organization (ILO) Core Conventions.

This statement outlines the steps Costrick Ltd has taken during the financial year 2025–2026 to identify, prevent, and mitigate modern slavery risks within our operations and supply chain. It applies to Costrick Ltd and is published on behalf of our organization, reflecting our commitment to transparency and ethical business practices. For further details on our data practices, see our Privacy Policy at www.costrick.com/privacy-policy.

Our Business

Costrick Ltd operates a digital platform (www.costrick.com) and an upcoming mobile application, facilitating efficient transactions and inventory management for convenience stores and wholesalers across the UK. Headquartered in Glasgow, Scotland, we employ a small team dedicated to supporting our platform’s operations, including customer support, technology development, and supplier coordination. Our supply chain involves partnerships with wholesalers, distributors, and logistics providers, primarily in the UK, with some sourcing of products from international suppliers in sectors such as food and beverages, consumer goods, and technology.

Our value chain encompasses platform development, supplier onboarding, product distribution, and customer support. While our direct operations are UK-based, our supply chain extends to tier 1 suppliers (direct wholesalers and distributors) and, in some cases, tier 2 suppliers (manufacturers or processors), particularly for food, beverages, and consumer goods. We are committed to ensuring that all parts of our value chain operate free from modern slavery.

Our Policies

Costrick Ltd has established policies to prevent modern slavery and uphold human rights, aligned with our commitment to responsible business conduct:

  • Human Rights Policy: We adhere to the UN Guiding Principles on Business and Human Rights, prohibiting forced labour, child labour, and discrimination, and ensuring freedom of movement, association, and access to grievance mechanisms.
  • Supplier Code of Conduct: All suppliers must sign our Code of Conduct, which mandates compliance with anti-slavery laws, prohibits worker-paid recruitment fees, compulsory overtime, and document retention, and requires fair working conditions. It also emphasizes protections for vulnerable groups, such as migrant workers.
  • Responsible Sourcing Policy: This outlines requirements for ethical sourcing, including regular audits and due diligence to ensure suppliers meet our anti-slavery standards.
  • Whistleblowing Policy: We provide an anonymous reporting channel (www.costrick.com/speak-up) for employees, suppliers, and stakeholders to report modern slavery concerns, ensuring access to remedy and justice.

These policies are communicated to all employees and suppliers during onboarding and reviewed annually to ensure compliance.

Risk Assessment and Due Diligence

We recognize that modern slavery risks, including forced labour and human trafficking, can occur in supply chains, particularly in high-risk sectors like food and beverages, logistics, and manufacturing. Our risk assessment focuses on identifying and mitigating these risks across our operations and supply chain.

Identified Risks

Based on our 2025–2026 risk assessment, key modern slavery risks include:

  • Supply Chain Risks: Potential for forced labour or exploitative practices in tier 1 and tier 2 suppliers, especially in international manufacturing or agricultural sourcing (e.g., food and beverage products from regions with weaker governance).
  • Vulnerable Groups: Migrant workers and temporary workers in logistics or distribution may face risks such as recruitment fees, wage withholding, or excessive overtime.
  • Local Operations: While our UK-based operations have lower risk, we remain vigilant about agency workers or subcontractors in warehousing and delivery.
Due Diligence Processes

To address these risks, we implement the following:

  • Supplier Mapping: We maintain a list of tier 1 suppliers and are working to map tier 2 suppliers to improve traceability, particularly for imported goods.
  • Supplier Onboarding: All new suppliers undergo due diligence, including signing our Supplier Code of Conduct and providing evidence of anti-slavery policies. We review public records for any labour disputes or non-compliance.
  • Risk-Based Audits: We conduct annual audits of high-risk suppliers, focusing on working conditions, recruitment practices, and compliance with ILO indicators (e.g., no debt bondage, no document retention). Audits are performed by our internal team or certified third parties.
  • Contractual Requirements: Contracts with suppliers include clauses mandating compliance with anti-slavery laws and allowing termination for non-compliance.
  • Grievance Mechanisms: Our anonymous whistleblowing channel (accessible at www.costrick.com/speak-up) allows workers and stakeholders to report concerns, with prompt investigation and remediation.

In 2025, we identified no confirmed cases of modern slavery in our operations or supply chain but noted one instance of excessive overtime at a tier 1 logistics supplier, which was remediated through revised scheduling and worker consent protocols.

Training and Capacity Building

To ensure awareness and compliance, we provide training to employees and suppliers:

  • Employee Training: All staff, including procurement and customer support teams, complete annual e-learning modules on modern slavery, covering ILO indicators (e.g., abuse of vulnerability, wage withholding) and our policies. In 2025, 100% of our team (approximately 20 employees) completed this training.
  • Supplier Training: New suppliers receive training on our Supplier Code of Conduct during onboarding, with refreshers offered annually for high-risk suppliers. In 2025, we trained 10 tier 1 suppliers on responsible recruitment and anti-slavery practices.
  • External Collaboration: We engage with industry bodies, such as the Ethical Trading Initiative, to stay informed on best practices and share learnings.

Training is delivered via our internal platform and supplemented by resources from expert organizations, ensuring our team and suppliers are equipped to identify and address modern slavery risks.

Addressing Risks and Impacts

When risks or non-conformities are identified, we take immediate action:

  • Remediation: In 2025, we addressed the excessive overtime issue by working with the supplier to implement voluntary overtime policies and ensure compliance with legal working hours. No loss of income occurred for workers.
  • Preventive Measures: We updated our Supplier Code of Conduct to include stricter requirements on overtime and worker consent, effective from July 2025.
  • Collaborations: We are exploring partnerships with organizations like the Mekong Club to enhance our due diligence and traceability efforts, particularly for international suppliers.

Our goal is to eliminate recruitment fees in our supply chain by 2027, with progress monitored through supplier audits and worker feedback.

Progress and Key Performance Indicators (KPIs)

We track our efforts to combat modern slavery through the following KPIs for 2025–2026:

  • Forced Labour Cases: 0 confirmed cases (target: maintain 0).
  • Non-Conformities: 1 case of excessive overtime (remediated; target: 0 non-conformities by 2026).
  • Supplier Training: 10 tier 1 suppliers trained (target: 15 by 2026).
  • Employee Training: 100% completion rate (target: maintain 100%).
  • Grievances Reported: 0 grievances related to modern slavery (target: maintain robust reporting channels).

These KPIs are reviewed annually, with results shared in our next statement.

Looking Ahead

For 2026–2027, we aim to:

  • Expand supplier training to include all tier 1 and select tier 2 suppliers.
  • Enhance supply chain mapping to cover 100% of tier 2 suppliers.
  • Strengthen partnerships with industry bodies to improve traceability and risk mitigation.
  • Introduce quarterly reviews of high-risk suppliers to ensure ongoing compliance.
  • Maintain our commitment to zero recruitment fees by 2027.

Approval

This statement has been approved by the Board of Directors of Costrick Ltd on 26 August 2025, signed by [Director’s Name], Director, on behalf of the organization. It reflects our ongoing commitment to preventing modern slavery and ensuring ethical practices across our operations and supply chain.

Contact Us

For questions or concerns about this statement or our practices, contact: