Bullitt Group’s Modern Slavery Statement for 2018

Statement from the Board of Directors of Bullitt Mobile Limited made on 29 March 2019
We are committed to maintaining practices and policies to combat slavery and human trafficking. This statement is made in compliance with the Modern Slavery Act 2015 (the Act) and covers our financial year which ended on 31 December 2018.

Organisation’s structure
We are a manufacturer of consumer electronic devices, including mobile phones. Our main trading entity, Bullitt Mobile Limited (Bullitt Mobile), which reports its revenue through group consolidated accounts published by its parent company, Bullitt Group Limited, has a turnover in excess of £36million. On that basis, we have decided to produce a single statement addressing the requirements of the Act in the name of Bullitt Group Limited covering all entities within the Bullitt group of companies (Bullitt Group), including Bullitt Mobile.
Bullitt Group is headquartered in the United Kingdom and has approximately 180 employees worldwide, with overseas operations located in the USA, China and Taiwan.

Our supply chain
Bullitt Group operates primarily through a limited number of suppliers and original design manufacturers based in Asia, as well as distribution partners across Asia, Europe and the Americas.
To ensure all those in our supply chain and other contractors comply with our values, we procure that adherence to a compliance programme – including provisions in relation to anti-slavery and human trafficking – is a mandatory requirement for third parties who want to work with us, wherever they are based in the world.
Whilst we consider the risk of modern slavery or human trafficking occurring within our supply chain partners to be low, Bullitt Group’s management and other Bullitt Group personnel visit our supplier manufacturing sites on a regular basis to monitor compliance with all our policies and requirements.

Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
To support that commitment, we operate an Ethical Employment policy which specifically addresses the issues of forced labour and human trafficking. The policy is drafted in terms which reflect our dedication to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within our supply chain.
Our effectiveness in combating slavery and human trafficking
Following a review of the effectiveness of the steps we have taken over the course of the past year to ensure that here is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking:
1. Review and update our Ethical Employment policy in order to create a more specific Modern Slavery policy (“Policy”);
2. Distribute copies of the updated Policy to key stakeholders, including those working within our supply chain to raise awareness and understanding of its content;
3. Review contractual arrangements with our supply chain to attempt to reinforce appropriate levers which better ensure supplier compliance with the Policy; and
4. Update our Whistleblowing policy to include provision for making protected disclosures related to forced labour, human trafficking and other unethical employment practices.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2018.