Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Club Of Aces ("the Company", "we", "us", "our") has taken and continues to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chains.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Club Of Aces has a zero-tolerance approach to any form of modern slavery and is committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chains.

Our Business and Supply Chains

Club Of Aces is a UK-based golf brand specializing in premium golf equipment, apparel, and accessories. We are committed to delivering exceptional quality products to golf enthusiasts while maintaining the highest ethical standards throughout our operations.

Our Business Structure

• Headquarters: United Kingdom

• Business Model: Design, sourcing, and retail of golf equipment and apparel

• Revenue: [Insert annual revenue if applicable]

• Employees: [Insert number of employees]

Our Supply Chains

Our supply chains include:

• Manufacturing Partners: Golf equipment manufacturers primarily based in Asia and Europe

• Textile Suppliers: Apparel and accessory manufacturers

• Component Suppliers: Providers of raw materials including metals, composites, and fabrics

• Logistics Partners: Shipping, warehousing, and distribution services

• Retail Partners: Authorized dealers and online platforms

We recognize that our supply chains, particularly those involving manufacturing in regions with varying labor standards, may present higher risks for modern slavery practices.

Our Policies

Club Of Aces is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our policies reflect our commitment to acting ethically and with integrity in all our business relationships:

Code of Conduct

Our Code of Conduct clearly outlines our expectations regarding:

• Prohibition of forced, bonded, or compulsory labor

• Prohibition of human trafficking

• Freedom of association and the right to collective bargaining

• Fair wages and working hours

• Safe and healthy working conditions

• Zero tolerance for child labor

Supplier Code of Conduct

All suppliers are required to:

• Comply with all applicable laws and regulations

• Maintain workplace standards that prohibit modern slavery

• Provide evidence of compliance through certifications and audits

• Allow access for monitoring and inspection

• Report any concerns or violations immediately

Whistleblowing Policy

We have established confidential reporting mechanisms for employees and supply chain partners to report concerns about modern slavery or other unethical practices without fear of retaliation.

Due Diligence and Risk Assessment

Club Of Aces undertakes comprehensive due diligence on all suppliers and regularly assesses the risk of modern slavery in our supply chains:

Supplier Onboarding

• Comprehensive background checks on all new suppliers

• Mandatory completion of modern slavery questionnaires

• Site visits and audits where feasible

• Review of certifications and compliance documentation

Risk Assessment Criteria

We assess suppliers based on:

• Geographic location and country risk ratings

• Industry sector and labor intensity

• Supplier size and capacity

• Previous compliance history

• Subcontracting arrangements

High-Risk Areas Identified

• Manufacturing facilities in regions with weak labor law enforcement

• Suppliers using extensive subcontracting networks

• Labor-intensive production processes

• Seasonal or temporary workforce arrangements

Monitoring and Auditing

Regular Audits

• Annual compliance audits of key suppliers

• Unannounced site visits where geographically feasible

• Third-party audit verification for high-risk suppliers

• Review of working conditions, wages, and employment practices

Key Performance Indicators

We monitor:

• Percentage of suppliers completing modern slavery assessments

• Number of supplier audits conducted annually

• Corrective action plans implemented

• Training completion rates

Remediation Process

When issues are identified:

1. Immediate investigation and risk assessment

2. Development of corrective action plan with timelines

3. Regular monitoring of implementation

4. Termination of relationship if adequate progress is not made

Training and Awareness

Employee Training

All relevant employees receive training on:

• Modern slavery recognition and prevention

• Supply chain risk assessment

• Reporting procedures and responsibilities

• Legal obligations under the Modern Slavery Act

Supplier Education

We provide suppliers with:

• Modern slavery awareness materials

• Best practice guidance

• Regular updates on regulatory requirements

• Access to training resources and workshops

Effectiveness and Continuous Improvement

To measure the effectiveness of our approach, we:

• Conduct annual reviews of our modern slavery risks and controls

• Track and analyze key performance indicators

• Seek feedback from stakeholders including suppliers and employees

• Benchmark our practices against industry standards

• Engage with industry bodies and NGOs focused on supply chain ethics

Continuous Improvement Initiatives

• Enhanced due diligence procedures for high-risk suppliers

• Increased frequency of audits and monitoring

• Investment in supply chain traceability technology

• Collaboration with industry peers on best practices

Governance and Accountability

Board Oversight

Our Board of Directors maintains oversight of modern slavery risks and mitigation efforts through:

• Regular reporting on supply chain compliance

• Review and approval of modern slavery policies

• Allocation of appropriate resources for compliance activities

Management Responsibility

Day-to-day responsibility for modern slavery compliance rests with:

• [Chief Executive Officer]: Overall accountability and strategic direction

• [Procurement Director]: Supplier management and compliance

• [Operations Director]: Implementation of policies and procedures

• [Legal/Compliance Officer]: Regulatory compliance and reporting

Looking Forward

Club Of Aces remains committed to continuous improvement in our approach to preventing modern slavery. In the coming year, we will:

• Enhance our supplier assessment and onboarding processes

• Increase the frequency and scope of supply chain auditing

• Invest in technology solutions for improved supply chain visibility

• Strengthen partnerships with industry bodies and NGOs

• Expand our training programs for employees and suppliers

• Develop more robust metrics for measuring our effectiveness

Approval and Sign-off

This statement has been approved by the Board of Directors of Club Of Aces and will be reviewed annually.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Club Of Aces' slavery and human trafficking statement for the financial year ending Dec 2025.