Modern Slavery Statement 2025/2026

At STEPPERS, operated by HRK TECH LTD, we are fully committed to preventing modern slavery and human trafficking within our business and throughout our supply chain. As an independent brand that designs, manufactures and sells its own products, we take responsibility for ensuring that every step of our production reflects ethical, fair and transparent working practices.

Modern slavery, forced labour, child labour, human trafficking and all forms of exploitation are strictly prohibited in our operations. We remain committed to continuously improving our safeguards, strengthening our policies, and ensuring that every individual connected to our brand is treated with dignity and respect.

1. Our Business & Supply Chain

STEPPERS is a UK-registered independent brand primarily focused on designing and selling high-quality consumer products.
Our supply chain includes:

  • Contracted manufacturers
  • Packaging suppliers
  • Logistics and shipping partners
  • Service providers (IT, marketing, website hosting)

While our supply chain is relatively simple compared to large wholesalers, we still implement strict standards to ensure that all partners uphold the same ethical principles we follow.

2. Our Internal Policies

We operate several internal policies to ensure ethical conduct across all areas of our business:

2.1 Recruitment Policy

  • All employment within HRK TECH LTD is voluntary.
  • We conduct legal right-to-work checks for all UK-based employees.
  • No individual will ever be required to work against their will or be subjected to coercion, bonded labour or involuntary work.

2.2 Whistleblowing Policy

We maintain an open reporting structure, allowing any employee, contractor or partner to raise concerns confidentially.

  • Individuals can report issues regarding unethical practices, suspicious activity, or worker mistreatment without fear of retaliation.
  • Concerns are reviewed promptly and handled with full confidentiality.

2.3 Code of Conduct – Ethical Trading Standards

Our Code of Conduct outlines the expectations we place on ourselves and all suppliers. We require compliance with the following principles:

  1. Employment is Freely Chosen
     No forced, bonded or involuntary labour.
  2. Freedom of Association
     Workers must be free to join organisations or unions where legally permitted.
  3. Safe & Hygienic Working Conditions
     Suppliers must ensure a safe workplace with proper training and protective measures.
  4. No Child Labour
     Absolutely no worker under the legal minimum age in any territory we operate in.
  5. Fair Wages
     All workers must receive wages at or above the legal minimum.
    No unlawful deductions.
  6. Working Hours Are Not Excessive
     Working hours must comply with legal standards.
    Overtime must be voluntary.
  7. No Discrimination
     No discrimination based on gender, race, religion, identity, disability, or any protected characteristic.
  8. Stable Employment
     Employment must be based on recognised and lawful contracts.
  9. No Harsh or Inhumane Treatment
     Physical, verbal, or psychological abuse is strictly prohibited.
  10. Anti-Bribery
     Bribery, corruption, or unethical influence of any kind is not tolerated.

3. Transparency & Supplier Responsibility

Although STEPPERS works with a smaller number of manufacturers compared to wholesale organisations, we still hold each partner to high standards:

  • Suppliers must provide full transparency into their production sites.
  • No subcontracting is permitted without written authorisation from HRK TECH LTD.
  • We conduct supplier assessments and request documentation to ensure compliance with labour, safety and ethical standards.

If a supplier fails to demonstrate compliance or refuses to improve after corrective actions, we will terminate the business relationship immediately.

4. Internal Auditing & Risk Monitoring

We regularly review:

  • Supplier documentation
  • Manufacturing facility information
  • Material sourcing
  • Working conditions and labour standards

Any risks or concerns identified are escalated, documented, and resolved through corrective action plans.

5. Training & Awareness

We ensure that all individuals involved in sourcing, product development and supplier management understand:

  • The signs of modern slavery
  • How to report concerns
  • Our brand’s ethical expectations

We keep our team updated with new legal requirements and best practices.

6. Continuous Commitment

STEPPERS (HRK TECH LTD) is committed to ongoing improvement. Our focus includes:

  • Strengthening supplier screening
  • Expanding transparency
  • Encouraging continuous ethical development
  • Reviewing policies annually

We will never knowingly work with any organisation involved in forced labour, modern slavery or human trafficking.

This statement has been approved by the directors of HRK TECH LTD and will be reviewed annually.

Signed:

 Director, HRK TECH LTD