Introduction

This Modern Slavery and Human Trafficking Statement is made on behalf of James Johnson Green Ltd (trading as Envirofone). It sets out the steps we have taken to ensure that slavery and human trafficking are not taking place within our business or our supply chains, in line with the UK Modern Slavery Act 2015.

We recognise that modern slavery is a global issue that requires continuous vigilance. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our organisation or in any of our supply chains.

Our business and supply chains

Envirofone specialises in the refurbishment, recycling, and resale of consumer technology. We operate in the United Kingdom and work with a network of logistics providers, device recyclers, repair partners, and component suppliers to deliver our services to customers and corporate partners.

Our supply chains include the sourcing of used mobile devices and related accessories, the procurement of spare parts, and professional services that support our operations such as marketing, IT, warehousing, and facilities management.

Policies and governance

Our policies reflect our commitment to acting responsibly and include our Code of Conduct, Anti-Bribery Policy, Whistleblowing Policy, and Supplier Standards. These policies are reviewed regularly and are communicated to employees, contractors, and key suppliers.

We expect our suppliers to uphold the same standards. All new suppliers undergo an onboarding process that requires acceptance of our Supplier Standards, which include explicit prohibitions against forced labour, servitude, and human trafficking.

Due diligence

We carry out due diligence on suppliers proportionate to the level of risk they present. This includes assessing their ownership, geographic footprint, labour practices, and the nature of goods or services provided. Where appropriate, we request additional information or certifications to evidence compliance with anti-slavery legislation.

Our contracts include clauses that require suppliers to comply with all applicable laws, including the Modern Slavery Act 2015, and grant us the right to audit or terminate relationships where non-compliance is identified.

Risk assessment and management

We evaluate the potential risks of modern slavery across our operations and supply chains. Higher risk areas include suppliers involved in device refurbishment, reverse logistics, and the sourcing of electronic components, especially where supply chains extend to jurisdictions with weaker labour protections.

To mitigate these risks, we prioritise working with suppliers who can demonstrate robust labour standards, require transparency over their own supply chains, and monitor compliance through periodic reviews and performance meetings.

Training and awareness

We provide employees with access to compliance training that covers our ethical expectations and how to identify and report signs of modern slavery or human trafficking. Managers and team leaders responsible for supplier relationships receive additional guidance on conducting risk-based due diligence and escalating concerns.

Our whistleblowing arrangements allow colleagues, suppliers, and other stakeholders to report concerns confidentially. All reports are investigated promptly, and appropriate action is taken.

Measuring effectiveness

We monitor the effectiveness of our approach through key indicators such as supplier audit outcomes, the number of grievances raised and resolved, and the completion rates of relevant training modules. Findings from these indicators inform updates to our policies and procedures.

During the reporting year we did not identify any instances of modern slavery within our business or supply chains. Nevertheless, we remain vigilant and prepared to act swiftly should any concerns arise.

Our commitments for the coming year

Over the next 12 months we will continue to strengthen our procurement processes, refresh training materials to reflect evolving best practice, and deepen engagement with suppliers in higher risk categories. We will also explore opportunities to collaborate with industry partners and specialist organisations to enhance transparency and responsible sourcing.

Reporting concerns

Anyone with concerns about potential modern slavery or human trafficking in our business or supply chains can contact us at [email protected] or use our confidential whistleblowing channels. All reports are taken seriously and handled sensitively.

Approval

This statement was approved by the Board of Directors of James Johnson Green Ltd on 15 January 2025 and will be reviewed and updated annually.

Signed:
Sam Hargreaves,
Director