Modern Slavery Statement

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being directly or indirectly involved in this crime through its own operations and its supply chain.

Our Business and Supply Chains

We power the world’s most famous brands to deliver local ecommerce experiences without friction, everywhere in the world. ESW’s supply chain is reliant on trusted partners. ESW works with its retailer partners to manage the risk of unethical practices in the supply chain.

Code of Ethics:  Our Code of Ethics encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing our business. ESW strives to maintain the highest standards of employee conduct and ethical behaviour in every territory that ESW operates and in the management of the supply chain.

ESW Policies

ESW has a zero-tolerance approach to modern slavery. ESW is committed to acting ethically and with integrity in every aspect of our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

Third-Party Risk Management Policy: This policy ensures that ESW’s third party relationships are evaluated to assess the risks related to engaging with each third party including the risk of slavery.

Speak Up Policy: All employees are encouraged to inform management of any actual or perceived wrongdoing that they observe or otherwise become aware of. This includes failure to follow ESW policies relating to modern slavery. Employees and other third parties may make anonymous reports to our Speak Up hotline.

Training

ESW’s ensures that all employees are trained in relation to key policies concerning ethics and prevention and detection of modern slavery.

Review

This statement is continuous and has been approved by the ESW Board of Directors.

This statement is applicable to U.S. Direct E-Commerce Limited trading as ESW and all other affiliated entities (collectively “ESW”), wherever located. 

Eric Eichmann
Chief Executive Officer 

April 2025