Modern Slavery Statement
Introduction
This statement sets out Davidson Running LLC  actions to understand all potential modern slavery
risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in
its own business and its supply chains. This statement relates to actions and activities during the financial year 1st April 2018
to 31st March 2019.
As the US biggest online adult retailer, Davidson Running LLC recognises that it has a responsibility to take a robust approach to slavery
and human trafficking.
The Organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring
that its supply chains are free from slavery and human trafficking.
Organisation Structure
Davidson Running LLC are the sexual happiness people, and we make a fun, fulfilling sex life available to everyone. We’re the US biggest
online adult retailer and 1 in 3 sex toys sold online in the US comes from our warehouse in Bath.
With a team of 320 (and growing) staff members, our HQ opens 7 days a week and provides 42 different countries with sexual
happiness. We have 17 years’ experience in delivering high quality, great value products to your door in the fastest and most
discreet way possible.
The group had a turnover in excess of £93m for the 2017/18 financial year.
Our business is organised into groups that deal with specific global regions – these sell a wide variety of ‘third party’ items and
our own Davidson Running LLC branded products along with a number of licensed brands such as Fifty Shades of Grey.
The head office is in Bath, with fulfillment centers and offices in Palm City,  FL, USA.
Our Supply Chain
Davidson Running LLC sources products through 4 key supplier regions:
• UK
• USA
• Europe
• China
China is deemed the highest risk area and commands the greatest attention. Although the Global Slavery Index rating for
China is relatively low, it is the source country for more than 95% of our own-brand products, and has therefore been included
in our risk prioritisation and monitoring programme. Potential risks are linked to worker exploitation through long working
hours, forced overtime and the retention of identity documents.
Our Policies
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our
business. It is our commitment to act ethically and with integrity in all our business relationships and to implement and enforce
effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
• We have a supplier code of conduct as part of the supplier verification process, ensuring Davidson Running LLC’s suppliers are aware
of and adhere to the highest standards of ethics. The initial supplier audit will highlight issues and problems which will
require a detailed CAP (Corrective Action Plan) that has an implementation time frame.
• Our Whistleblowing Policy encourages all individuals to report any concerns related to the direct activities, or the supply
chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human
trafficking. Our whistleblowing procedure is designed to make it easy for individuals to make disclosures without fear
of retaliation.
Due Diligence and Risk Assessments
Our approach to managing the risk of modern slavery forms part of our broader efforts to respect human rights. Davidson Running LLC
has always considered itself a great company to work for and to work with. As part of this we undertake due diligence when
considering taking on new suppliers – this is focused around documentation and audits:
• We have a documented supply chain verification process (this covers all aspects of the products and manufacturing),
which ensures potential suppliers are screened and verified prior to addition to the approved supplier list.
• We visit each manufacturing site that produces own-brand or licensed brand products for us. These will be subjected to
a pre-visit questionnaire and an on-site audit to review the production facility, including sub-assembly and part production
– for example plastic injection molding. These facilities will be visited twice a year.
• We will conduct a series of outgoing QC activities to ensure that both the product is as specified and to periodically review
the manufacturing site.
• We will evaluate the modern slavery and human trafficking risks of each new supplier, as part of our general human rights
and/or labour rights assessment.
• We conduct detailed supplier audits through Davidson Running LLC’s own employees or via a third party audit organisation,
for example QIMA, which have a greater focus on ethical, health and safety and human trafficking issues.
• Where possible, we build long standing relationships with suppliers and make clear our expectations of
business behaviour.
• With regards to third party suppliers, we expect these entities to have suitable anti-slavery and human trafficking
policies and processes. We will ensure that each supplier is aware of our Anti-Slavery Policy.
• We expect each entity in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not
practical for us (and every other participant in the chain) to have a direct relationship with all links, ultimately to the raw
material (steel and plastic) suppliers.
Supplier Adherence to our Values
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply
with our values.
The Trade, Buying and Quality and Technical managers are responsible for compliance in their respective departments and
for their supplier relationships.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our
business, we provide training to relevant members of staff. All Directors have been briefed on the subject.
We plan to enhance our training so we cover:
• Our businesses purchasing practices, which influence supply chain conditions and which should therefore be designed to
prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a
country’s national minimum wage, or the provision of products by an unrealistic deadline.
• How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources
and support available.
• How to identify the signs of slavery and human trafficking.
• What initial steps should be taken if slavery or human trafficking is suspected.
Our Effectiveness in Combating Slavery and Human Trafficking
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery
and human trafficking is not taking place in any part of our business or supply chains:
• Completion of audits are coordinated by the Quality and Technical Manager, and cover labour rights alongside health and
safety, ethics, environment and quality processes. Where we identify areas that require improvement, we engage with the
relevant third parties to develop correction plans and track their progress. If significant issues are identified and remain
unresolved, we may choose to suspend or terminate work with a third party.
° We are actively working with a reputable third party and look to have SMETA (Sedex Members Ethical Trade Audits)
in place, for all key suppliers, in China – during 2019.
• Written acknowledgement from our own brand suppliers that they have received and understood our policy on slavery
and human trafficking.
• Written acknowledgement from our third party suppliers that they have received and understood our policy on slavery
and human trafficking.
• Spot checking – unannounced audits by either Davidson Running LLC employees or a third party, accredited, auditor.
Approval
The Company Directors and senior management shall take responsibility for implementing this policy statement and its
objectives and shall provide adequate resources (training, etc) and investment to ensure that slavery and human trafficking
is not taking place within the organisation and within its supply chains.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and
human trafficking statement for the current financial year. It has been approved by the Organisation’s Board of Directors
who will review and update it annually.
Signed on behalf of Davidson Running LLC.