First published:              31 August 2017

Last updated:                 Board approved 24 June 2024

This statement is made pursuant to the Modern Slavery Act 2015.

Gear4music Limited is the retailing subsidiary of Gear4music (Holdings) plc, which is listed on the AIM market of the London Stock Exchange.

Our Business

We are an online retailer of musical instruments and music equipment, and since 2021, of Audio-Visual equipment including HiFi speakers and home cinema systems. We operate 21 websites in 15 languages and 9 currencies.

We supply products manufactured by many of the industry's best-known brands, and a range of good value, high quality own-brand products.

Whilst over 95% of revenue comes direct from consumers, we also supply educational and governmental institutions. Our customers typically purchase direct from our websites, but they can also buy certain products via other third-party sites such as eBay and Amazon.

More details of our business can be found at https://www.gear4musicplc.com/.

Our Policy

We are committed to adopting and improving practices that ensure there is no slavery and human trafficking in our supply chains or any other part of our business.

The products we sell are manufactured in many different countries, and we aim to ensure that these values are upheld across our supply chain.

To achieve this, we are committed to identifying and assessing areas of our business where there could be potential risks of modern slavery, be that directly or indirectly within our supply chain. We seek to develop and implement effective systems and controls to review and monitor compliance with our policy.

Third-party brands

We sell many well-known other-branded products including Yamaha, Fender, Gibson and Roland, and in the financial year ended 31 March 2024 third party brands accounted for 73% of our sales. We purchase these products predominantly from European-based suppliers, many of whom are part of larger global organisations. These organisations acknowledge and typically publish their commitment to anti-slavery practices. We review the Anti-slavery policies and statements of our major suppliers and are committed to assessing all suppliers of third-party brands.

Our suppliers are familiar with our Anti-Slavery policy, and the expectation that their own policies and the policies of their own suppliers meet our same high standard.

We will assess any instances of non-compliance if they arise and take the appropriate action to remedy such non-compliance.

Own-brands

Our own-branded products are sourced from manufacturers in several countries around the globe and are often manufactured to own specification and design. As at 31 March 2024 we had active relationships with over 93 manufacturers, predominantly in the Far East.

We operate a strict supplier code of conduct that all our own-brand suppliers are signed up to, detailing our rigorous expectations and requirements in relation to:

• Labour
  • Child Labour
  • Hours, Wages and Benefits
  • Humane Treatment
  • Slavery and Human-Trafficking
  • Discrimination
  • Freedom of Association
• Health and Safety
• Environmental
• Anti-Corruption

Furthermore, we conduct our own independent inspections of third-party facilities involved in the manufacture of our products. Nominated members of our Own-brand Procurement Team are trained to complete the checks. During these inspections we carry out extensive checks and produce written ‘factory inspection’ reports that are shared with the managers and/or owners of the facilities and include formal recommendations to be actioned where appropriate. We will stop using any factories that fail to meet the standards that we set.

Checks include:

• Working environment - Ventilation, lighting, cleanliness, temperature
• Working hours of factory employees
• Machinery & equipment standards and guards
• Safety equipment including firefighting equipment and first aid kits
• PPE & training
• Emergency exits & signage
• Staff facilities – WC, kitchen, etc.
• Factory certification - BSCI social responsibility certificate; OHSAS18001 Occupational Health & Safety

Between the first publication of our policy in September 2017 to Covid lockdowns in March 2020, we had conducted 40 factory inspections.

In May 2023 travel restrictions eased and we were able to resume inspections. Between May 2023 and June 2024, we conducted 28 inspections with more planned for later in the calendar year.

Responses to our factory inspections to date have been positive.