Modern Slavery Policy


This statement applies to CUBE Distribution (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2019.


CUBE employs 10 office based staff at our HQ in the U.K. We help Mobile and Tablet accessory vendors and channel partners grow their business, by taking emerging technologies to market whilst growing established brands using a range of value added services. We work with over 1,000 resellers and various vendors. With a dynamic and proactive team of product managers, account managers, an experienced marketing team and an industry-leading operational centre CUBE will continue to exceed our partners’ expectations.


The Organisation considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.


The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK.


In order to fulfil its activities, the Organisation’s main supply chains include those related to the supply of Accessories and Consumer Electronics. The supply chain of which extends across Europe and the Far East. Due to the nature and complexity of many of these products, the Organisation is cognisant it’s supply chain extends through primary suppliers to their suppliers and sub-contractors.


The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:


• Robust recruitment processes aligned to employment laws. This includes ‘right to work’ document checks; contracts of employment and checks to ensure everyone employed is aged 16 and above.
• We ensure our people are aware of their contractual and statutory employment rights.
• Our salaries are Market-related and our salary review policies mean that pay can be reviewed at any stage of the year, or employee life cycle.
• All UK employees are paid at minimum wage or above, and we have strict enforcement of shift-ending times to ensure pay never falls below minimum wage.
We will additionally be taking the following steps:

Transparency in our supply chains

• We will commit to seeking confirmation by our suppliers (who work for us providing products and/or services for our own business use), in terms of spend, of their compliance with the Modern Slavery Act 2015 (Act). We will also seek confirmation from any suppliers deemed a material risk due to the sectors in which they operate.
• We will implement a Supplier Code of Conduct, used for all new suppliers or in re-tendering, which addresses the labour rights issues associated with modern slavery, sets out the values and standards we expect of our suppliers. We will include the Ethical Trade Initiative (ETI) Base Code to confirm their support of the Code, or where they have their own codes in place, sought confirmation they are complying with the same standards that we adhere to.
• The Organisation will employ an Ethical Purchasing Policy which sets out its views in eradicating child labour, forced labour, and describes it’s stance on conditions of employment, corruption, pay and health & safety. This policy adopts the ethos of the Ethical Trading Initiative and we share its vision of workers being free from exploitation.


All employees at CUBE will have access to training on our Ethical Purchasing Policy which includes the Modern Slavery Act, ETI Base Code, Environmental Policy, Anti-Bribery and Whistle Blowing. This training will be mandatory for individuals involved in purchasing or sourcing suppliers.
Supporting our people

• Our Employee Handbook reiterates the demonstration of our 4 shared company values: People, Operational Excellence, Profitable Growth and Exceeding Expectations
• Our handbook also requires includes an Anti-Bribery Policy, reiterating the importance of us to act ethically and to comply with legal requirements at all times, putting our values into practice in everything we do.
• Our handbook will also cover the Modern Slavery Act and that we need to adhere to the ETI Base Code
• We have a Whistle Blowing policy outlined in our handbook which clearly outlines the procedure of communicating with a company Director in the first instance, and how to escalate if they feel concerns are not being addressed appropriately. We will add an amendment to specific cover Modern Slavery.


The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.
• Requesting signed agreement to our Supplier Code of Conduct from our key suppliers.
• Communicating our Supplier Code of Conduct to all suppliers and setting expectations.
• Evaluation of awareness training programme for employees involved with purchasing and sourcing suppliers.


The Organisation has appointed a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed by the board each financial year.