This disclosure statement (the “Statement”) has been published pursuant to section 54(1) of the UK Modern Slavery Act 2015 (“the Act”) and is made on behalf of Funko UK, Ltd (“Funko UK”), which is in scope for the purposes of the Act. Funko UK is a subsidiary of Funko, Inc. (the “Company”, “we” or “our”). This Statement sets out the steps taken by the Company during the fiscal year ending December 31, 2019. In accordance with the Act, this Statement is published on the Company’s website.
As a part of our global organization, Funko UK is committed to high standards of ethical conduct and compliance with applicable laws. It is our expectation that our suppliers also conduct themselves in this manner. Our commitment to ethical conduct and compliance with laws includes compliance with laws prohibiting human trafficking and slavery. The Act defines “modern slavery” as including the offences of “slavery, servitude and forced or compulsory labour” as well as “human trafficking”.
Business structure and supply chain
The Company is a leading pop culture consumer products company, and involved in the design, manufacture and distribution of licensed pop culture consumer products, including collectibles, apparel, accessories, home goods, board games and more, featuring characters from an extensive range of media and entertainment content, including movies, TV shows, video games, music and sports.
The Company’s products are designed in the U.S.A., while its principal manufacturing facilities are based in Vietnam and China. The Company also manufactures or assembles certain apparel and other products in the U.S.A. and Mexico.
We are dedicated to ensuring that our supply chains do not rely on or benefit from slavery or human trafficking. To this end, we have formulated, and seek to enforce, a code of conduct for our suppliers (the “Code of Conduct”). The Code of Conduct requires our suppliers to:
- not make use of “Forced Labor” (which includes any kind of prison labor, indentured labor, bonded labor or any other form of forced labor) and “Child Labor” (which is defined as the use of employees either being below the local minimum working age, or below the age of 16, whichever is greater);
- recognize and respect the right of employees to freedom of association and collective bargaining, without being penalized for the non-violent exercise of these rights;
- ensure that their employees’ work hours do not exceed the permitted hours under the applicable national laws and that employees are compensated for any overtime hours (which shall be voluntary at all times), and also aim to provide a living wage to employees (and to their families as well);
- not subject their employees to any physical, sexual, psychological or verbal harassment or abuse (including any physical or mental punishment, or psychological coercion); and
- provide migrant employees with contracts, treatment and wages that are equal to those of local workers.
By requiring strict adherence to the Code of Conduct from our suppliers, we seek to implement and maintain a robust framework of controls to prevent slavery and human trafficking in our supply chains. We believe this framework is in turn strengthened by the broad definition of “employee” in the Code of Conduct, which encompasses all our supplier’s workers, including but not limited to full time employees, part time employees, day workers, contract labor and temporary labor, as well as the mapping and monitoring that we undertake of our supply chains (in the manner outlined below).
Due diligence in the supply chain
The Company carries out risk assessments of their suppliers to monitor their compliance with the Code of Conduct as well as any other applicable national regulations. Where we identify potential risks, we seek to implement strengthened contractual provisions to mitigate such risks. Provisions that we would look to implement include additional enhanced representations about compliance with national labor laws, compliance with the Code of Conduct, and granting the Company certain audit rights to inspect suppliers’ facilities. To the extent that we have had any reason to suspect that any of our suppliers are relying on or benefitting from modern slavery or human trafficking, we would terminate our relationship with that supplier and make the necessary reports to the relevant authorities as applicable.
Where required by applicable national regulations, we obtain compliance certificates from our suppliers, which include representations and warranties that the suppliers would take all steps in ensuring that their manufacturing processes do not in whole, or in part, use forced labor. Under these certificates, suppliers are also required to undertake to perform the necessary due diligence on its own manufactures, in order to fulfill their contractual responsibility to preventing the use of forced labor in their supply chains.
To date, we have received no reports of any incidents relating to modern slavery or human trafficking in our supply chains.
Training & Reporting
Each of the Company's employees and directors are required to adhere to the “Code of Business Conduct and Ethics” (the “Code”), which reflects our commitment to acting ethically and with integrity in our business dealings. Under the Code, all employees and directors have a duty to report any known or suspected violation of the Code, including violations of the laws, rules, regulations or policies that apply to the Company, and can do so through various reporting channels such as their supervisors, General Counsel, or the Company’s anonymous ethics hotline.
Further to the Code, we also ensure that our key employees are aware of any potential risk of modern slavery or human trafficking in our supply chains.
This Statement has been approved by the board of directors of the Company.
October 13, 2020
By /s/ Ken Brotman
Director, Funko, Inc.