Modern slavery

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 01/04/2019 to 29/03/2020.

The statement sets down the commitment we make as a company to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small.  Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Ponte Velha Ltd which are as follows:

A company involved with importing and retailing recycled clothing/accessory products for children.

The Company currently operates in the following countries:         


  • China


  • UK
  • Ireland       

The following is the process by which the Company assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking: (Auditing from external sources namely to meet customer requirements).

High Risk Activities

The following activities are considered to be at high risk of modern slavery or human trafficking:

Sourcing in China still represents a high risk of modern slavery and to counter this we carry out an assessment of our suppliers prior to doing business with them. We have responsibly sourced our products to ensure that we are in no way part of, or contributing to any modern slavery methods. 

Responsibility for the Company’s anti-slavery initiatives is as follows:

1.1    Policies: The process by which policies are developed are by assessing relevant standards associated with the companies operations and putting relevant policies in place in accordance with this.

1.2    Risk assessments: risk assessments in respect of human rights and modern slavery by a process of vetting each supplier for suitability and carrying out a full assessment including visiting and documenting the company before them becoming an approved supplier.

1.3    Due diligence: for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

1.4    In some cases, the above procedures will need to be carried out by an approved third party acting on behalf of Kooties. In this circumstance the above statements will be based on the evidence provided by these third parties.


To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to undertake an online training course within three months of their employment start date.


The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations [insert links to the relevant Company policy]:

2.1    Whistleblowing policy - the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.

2.2    Company Code of Conduct - The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.

2.3    Corporate Social Responsibility (CSR) Policy - The Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.

Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier this includes invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Performance indicators

The Company uses key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including requiring all staff to have completed training on modern slavery.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary.