Modern Slavery/Supply Chain Transparency

In compliance with the Modern Slavery Act 2015 (United Kingdom, this statement sets out the policies and actions of Performance Designed Products LLC (the “Company”) relating to the prevention of slavery and human trafficking in our business and supply chain.  While the Company is not subject to the provisions of the California Transparency in Supply Chains Act of 2010 (SB 657), this disclosure also satisfies the disclosure obligations of that Act. 

The Company is committed to preventing slavery and human trafficking within its business activities and to ensure that our supply chains are free from modern slavery and human trafficking in any form.

This statement relates to actions and activities during the Company’s last fiscal year commencing April 1, 2018 and ending March 31, 2019.

ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS

Countries of Operation:

The Company is a leading provider of video game accessory products.  Headquartered in San Diego, California, the Company has multiple offices and facilities throughout the world, including the United States, Canada, Mexico, United Kingdom, France, the Netherlands, China and Australia. 

Countries of Supply:

The Company sources its products from multiple suppliers, all of whom must meet established high standards of quality.  The Company exercises caution when approving suppliers to ensure that products are only sourced from providers that respect human rights.

Responsibility:

Responsibility for the Company’s anti-slavery initiatives lies with Operations and Demand Planning Team and Human Resources Team.  Risk assessments, due diligence and training are carried out by these teams who then review policies as required and submit any necessary revisions to the Company’s Board of Managers for approval.

RELEVANT POLICIES

The Company has developed the following policies to address human trafficking and slavery in its’ supply chain and business.

Employee Workplace:

The Company’s Employee Handbook sets out the ethical and practical framework within which employees are invited to act.  The Company is committed to providing a safe working environment for all employees. 

Ethical Sourcing Policy:

The Company’s sourcing policy includes provisions that employment should be freely chosen and that no forced, bonded or involuntary prison labor will be tolerated.  Suppliers whom engage in or support slavery or human trafficking in any way will not be used.

Reporting Violations of Company Policy:

The Company has an established policy which sets forth multiple mechanisms by which employees can raise legitimate concerns over wrongdoing within its own operations.  A part of this policy is a commitment by the Company to protect employees from retaliation for making a good faith report. 

DUE DILIGENCE AND VERIFICATION

The Company undertakes due diligence when considering new suppliers and regularly reviews existing suppliers, using a variety of tools to assess potential and existing supply chain partners in all tiers.

Certification of Conduct:

All suppliers are required to certify with each purchase order that the materials in their product(s) comply with all laws of the country where they do business, including anti-slavery and human trafficking laws. 

Verification and Audit of Supply Chain:

The Company routinely visits supplier’s facilities, which are subject to inspections (both announced and unannounced), which may be performed by representatives of the Company’s Operations and Demand Planning Team, Human Resources Team and/or unrelated third parties for the purpose of ensuring compliance with applicable laws, including prohibition of slavery and human trafficking. 

Corrective Actions:

Non-compliances found during ethical audits, whistleblowing or other methods form the basis for Corrective Action Plans.  Any supplier found in non-compliance is strongly encouraged to work through their Corrective Action Plan in a timely fashion and the Company will support suppliers with their Corrective Actions Plans as required.  If critical issues such as evidence of human trafficking are found, the Company would suspend further business with the supplier until necessary corrections are made.  If not timely resolved, the business relationship will be permanently terminated. 

TRAINING AND AWARENESS RAISING

The Company continues to develop training for those who are involved directly with supply chain management, to improve knowledge and awareness of the issues and concerns surrounding modern slavery.  The Company further encourages employees within the Operations and Demand Planning Team and Human Resources Team to participate in external training programs and seminars on social compliance issues, human trafficking and modern slavery.

BOARD of managers APPROVAL

The Company’s Board of Managers approved this statement by written resolution on December 23, 2019.