Bullitt Group’s Modern Slavery Statement for 2021

Statement from Bullitt Mobile Limited made on 10 March 2022

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 2021.

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 140 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.

In 2021, we became members of the Responsible Business Alliance (RBA) and committed to furthering the aims of that organisation by subscribing to the RBA Code of Conduct, which specifically includes arrangements relating to trafficked and forced labour. In turn, we have adopted and published our own Supplier Code of Conduct, compliance with which is now a mandatory requirement for all partners delivering services and goods to us. A copy of our Supplier Code of Conduct can be found here.

To better ensure that the principles of our policies and procedures (including those relating to ethical employment) are upheld, we have established a new whistleblowing reporting mechanism to allow anyone to make an anonymous report of a concern to us. Such concerns are reviewed by our newly created Ethics Committee which is formed of members from our ESG, Finance, HR and Legal teams. Our Ethics Committee is empowered to take appropriate action, including escalation to the board of directors, in response to a report received from a whistleblower.

Our effectiveness in combating slavery and human trafficking

We continue to review the effectiveness of the steps we have taken over recent years to ensure that here is no slavery or human trafficking in our supply chains. Any improvements identified will be quickly implemented to support our commitment to combat slavery and human trafficking.

As part of that commitment, in 2022 we intend to launch a new Employee Code of Conduct to ensure expectations around compliance matters are clearly understood amongst our colleagues. We also intend to publish an updated CSR report covering recent developments.

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 2021.


Nathan Vautier

Chief Executive Officer, Bullitt Group

10 March 2022