The Imago Group – Modern Slavery Act Policy and Statement 2021-22

Introduction from Simon Rosenheim, Group Managing Director

Modern slavery is a crime and a violation of fundamental human rights. Imago recognises that modern slavery and human trafficking exists in every region of the world and in every business sector and that there is an increased risk when dealing with developing countries.

We have a zero-tolerance approach to modern slavery and human trafficking of any kind, both in our own operations and our supply chain. We recognise the responsibilities we have towards our colleagues and to our customers to be alert and to enforce our zero-tolerance policy at all times.

This statement sets out the steps and measures we take to assess and mitigate, as far as possible, the risk of modern slavery and human trafficking taking place in our supply chain.

This statement refers to the financial year ending 31st December 2021 and is published in accordance with the UK Modern Slavery Act 2015.

Our Business Structure

The Imago Group is an international group of companies providing printing and product sourcing services to the international publishing community. Imago has a network of offices located in China, South East Asia, Australia, North America, South America, France and UK. Our head office is based in Thame, Oxfordshire.

The Imago Group of Companies comprises:

• Imago Publishing (IPL)
  Set up: 1980 – Sales and Production for UK, France and GermanyAlso includes European Estimating, Group Finance, IT and Marketing
• Imago Sales Inc (ISI)
  Set up: 1985 – Sales and Production for USA East and West Coasts and Brazil
• Imago Services (ISE)
  Set up: 1987 – Estimating, Sourcing and Production in China and Hong Kong

As part of the above, Imago also has the following offices:

• Imago West (California)
• Imago Australia (Sydney)
• Imago France
• Imago Shenzhen
• Imago Malaysia
• Imago Brazil

The Holding Group is IMAGO HOLDINGS LIMITED

The Group Board of Directors have overall responsibility for ensuring our Anti-Slavery Policy is upheld and that management and their teams understand and comply with the policy.

Our Supply Chains

Imago’s international business partners and supply chain comprises approximately 70 suppliers located throughout China, South East Asia, Turkey, EU, UK, and the USA.

All suppliers must demonstrate that they have a clear understanding of their duties and responsibilities to provide a safe and good workplace environment for their employees. We expect our suppliers to share our values, operate ethically and be open and transparent in all dealings.

In each region the partner relationships are handled by local ‘on the ground’ teams. These teams include members of the group board, senior management team and sales and/or production employees who handle the day-to-day liaison.

Our compliance team monitors the approval of new suppliers to the Imago Group and ensures existing suppliers are reviewed regularly. Ongoing due diligence checks are made including regular visits by our staff to supplier’s facilities, checks on their social and environmental responsibility, and upkeep of accreditations.

Risk Assessment

Imago conducts an annual risk assessment of the business, more frequently if there is any significant issue of risk or change in business practice. This is carried out to monitor compliance with anti-slavery laws and to identify areas of the business that may be regarded as being at “high risk” of exposure to Slavery.

The following factors are taken into consideration when assessing risk;

• the territories or countries in which we are operating
• the sector in which we are operating
• the business partners with whom we work with

Following a risk assessment review, we implement any additional anti-slavery measures identified and update our policy accordingly.

Our Due Diligence Process

• New employees to the company are provided with a copy of our Anti-Slavery policy and it is discussed at their induction. Existing employees are reminded regularly of our policy and are trained to recognise the signs of modern slavery in the workplace and supply chain. Our Whistle Blowing Policy outlines the procedure for raising complaints within the company and any concerns about suppliers.
• All new suppliers to the Imago Group are visited by experienced members of our team who see the factory in action. Our staff have a high level of awareness and use a checklist to flag any business or ethical concerns.
• New suppliers are required to submit a Self-Assessment Questionnaire to share recognised accreditations or certification in order that we can gauge their level of social responsibility and assess their risk as a partner to Imago
• When starting a new supplier relationship, we communicate our expectations and exchange comprehensive Supplier Agreements / Terms and Conditions. Included within these agreements are details of the Imago Group’s Anti-Slavery Policy highlighting our commitment to ensuring slavery and human trafficking do not take place anywhere in our supply chains.
• Imago requires suppliers in high-risk areas to take an annual social audit. Audits are to be conducted by accredited audit companies and acceptable programs include:- IETP (ICTI Ethical Toy Program)- SMETA 4 pillar (Sedex Members Ethical Trade Audit)- BSCI (Business Social Compliance Initiative)
• Suppliers share their annual audit reports with our compliance team who assess and record them within our systems. Corrective actions are discussed with the suppliers and followed up locally until there is satisfactory conclusion.

The Book Chain Project – Beyond Auditing

Imago is an active member of The Book Chain Project (BCP) which is a collaboration of US and US publishers who have been working together since 2003 to improve labour standards in the supply chain.

BCP are effective in shining a light on any areas of concern to their members and at co-ordinating appropriate and fair responses. For example, BCP have recently worked at the behest of their members, to ensure malpractices surrounding the recruitment of migrant workers and exploitation of the Uyghur Muslims have been thoroughly investigated in the context of member’s shared supply chain. In the one case where issues were identified, they have been dealt with robustly.

Imago is aware that ensuring our supply chain is free from modern slavery can require intervention over and above the remit of a social audit. The Book Chain Project is a vital tool for Imago and helps us to stay aware of global and local issues and address them with our suppliers.

Impact of Covid-19

During 2021, in line with government guidelines, we have adapted our working practices, activities and priorities in response to COVID-19 particularly in relation to;

• The health and safety of employees – ensuring that the relevant local and national policies have been implemented throughout the Imago Group and supply chain to prevent the spread of the virus. Where possible our employees worked from home during the pandemic.
• Support for suppliers, we have been open to paying early for orders where possible to alleviate supplier cash flow difficulties.
• Grievance procedures – our IT infrastructure ensures that employees still have access to important procedures when working from home.
• Emerging risks – we have undertaken a new risk assessment to consider which parts of our workforce may be particularly vulnerable and increased our awareness of emerging and heightened risks attributable to the pandemic.