Modern Slavery Statement

This statement is made voluntarily by Custom Iron On Patches Ltd (“the Company”) in the spirit of the Modern Slavery Act 2015. The Company’s annual turnover is below the £36 million threshold that requires a mandatory statement under section 54 of that Act. However, we publish this voluntary statement because we believe transparency about our employment practices and supply chain is the right standard for a responsible UK manufacturing business.

This statement covers the financial year 2026.

1. About Custom Iron On Patches Ltd

Custom Iron On Patches Ltd is a UK-based manufacturer of custom embroidered, woven, PVC, printed and chenille patches. Founded by Jake Davey in Birmingham in 2017, the Company employs more than 60 staff at its manufacturing workshop at 10 Newhall Street, Birmingham B3 3AG. All production takes place at the Birmingham workshop.

The Company is a private limited company registered in England and Wales.

2. Our Structure and Supply Chain

2.1 Production Structure

All patch production is carried out in-house at the Birmingham workshop. The Company does not sub-contract production to overseas manufacturers. This means:

• Every patch is made by directly-employed workers in Birmingham
• There is no offshore manufacturing tier in the production chain
• Labour standards are governed by UK employment law throughout the production process

This structure significantly reduces the modern slavery risk inherent in extended international supply chains. Customers, procurement teams and auditors can have confidence that the patches they receive were made by employed workers operating under UK legal protections.

2.2 Direct Employment

The Company employs more than 60 staff directly at the Birmingham workshop. All employees:

• Are employed under written UK employment contracts
• Are paid at or above the National Living Wage / National Minimum Wage for their age band
• Are entitled to statutory holiday, sick pay and pension rights
• Are not in debt bondage or subject to unlawful deductions
• Are free to leave employment without penalty beyond notice periods
• Have the right to join a trade union

The Company does not use zero-hours contracts as the primary employment model. Where flexible working is offered, it is agreed with the employee and documented.

2.3 Supply Chain Tiers

The Company’s supply chain is limited to the following categories:

Far East-sourced raw materials (primarily backing adhesives and some base fabrics) are sourced from established suppliers with documented trading history. The Company purchases these through UK-based distributors with their own supply chain transparency commitments.

3. Policies and Due Diligence

3.1 Employment Policies

The Company operates the following employment policies relevant to modern slavery risk:

• Safer recruitment – all employees provide right-to-work documentation in line with Home Office guidance. No worker is employed without confirming their legal right to work in the UK.
• Identity verification – employee identity is verified at onboarding through UK-standard documentation (passport, national identity card, biometric residence permit)
• Age verification – no worker under the age of 16 is employed at the workshop. Workers aged 16–17 are employed only in non-production roles and subject to working-time restrictions for young workers
• Pay compliance – payroll is processed through Xero with audit trail. Pay is reviewed against National Minimum Wage/National Living Wage rates at each uprate cycle
• No forced labour – workers are never required to work as a condition of receiving their documentation back, and documents are never held by the Company

3.2 Supplier Due Diligence

For suppliers of raw materials and services, the Company takes the following due diligence steps:

• New suppliers – reviewed against standard selection criteria including UK/EU registration and trading history before onboarding
• Far East-sourced materials – purchased through UK-based distributors who represent established international manufacturers. The Company requests disclosure of major manufacturing sites and requests any available ethical sourcing documentation
• Ongoing relationships – suppliers showing signs of pricing below credible market rates (which can indicate labour exploitation) are queried before orders are placed

The Company does not currently operate a formal supplier audit programme due to its scale, but it maintains the right to request supply chain transparency information from any supplier at any time.

3.3 No Agency Labour Arrangements Without Oversight

Where the Company uses temporary staffing (e.g. production peak periods), all agency workers are supplied through established and registered UK employment agencies. The Company verifies that any agency used:

• Is registered with a recognised industry body or the Employment Agency Standards Inspectorate (EASI)
• Pays workers at or above the applicable National Minimum Wage

The Company does not use informal, unregistered or “gang” labour arrangements.

4. Risk Assessment

4.1 Our Risk Profile

The Company considers its modern slavery risk to be low, based on:

• 100% UK manufacturing – all production under UK employment law jurisdiction
• Direct employment model – no labour intermediaries in production
• Birmingham location – an established UK manufacturing centre with active local employment law enforcement
• Small management chain – the Director and operations management have direct visibility of the workforce
• Limited supply chain depth – the Company’s supply chain is primarily UK and EU sourced, with a limited Far East component for raw materials sourced via UK distributors

4.2 Higher-Risk Areas

The Company acknowledges the following as relatively higher-risk areas, albeit still low in absolute terms:

• Far East-sourced backing materials and base fabrics, these pass through supply chains the Company cannot fully audit. Mitigated by UK distributor intermediaries and established manufacturer relationships.
• Temporary/seasonal staffing – mitigated by registered UK agency use only.

5. Training and Awareness

The Director and management team are aware of modern slavery indicators as part of their responsibilities as employers. Staff are informed during induction that:

• The Company does not tolerate forced, bonded or trafficked labour in any form
• Workers are free to leave their employment at any time on notice
• Any concerns about exploitation, of themselves or of colleagues, should be reported to the Director or, anonymously, to the Modern Slavery Helpline

Modern Slavery Helpline: 08000 121 700 (24 hours/7 days)

The Company will introduce formal modern slavery awareness training for management as part of its ongoing B2B procurement readiness programme.

6. Key Performance Indicators

The Company tracks the following in relation to modern slavery:

• No modern slavery incidents identified or reported internally – ongoing status: zero incidents identified
• All employees verified against right-to-work requirements – ongoing status: compliant
• No workers below National Minimum Wage – ongoing status: compliant
• No use of unregistered or informal labour agencies – ongoing status: compliant

7. Commitment and Sign-Off

Custom Iron On Patches Ltd is committed to acting ethically and with integrity in all business relationships. We will continue to improve our supply chain transparency, training and due diligence practices in proportion to the Company’s scale and risk profile.

This statement has been reviewed and approved by the Company Director.

Jake Davey Director, Custom Iron On Patches Ltd

Jake Davey

08-May-2026

8. Review Schedule

This statement is reviewed annually and updated to reflect the current year’s practices and any significant supply chain changes.

9. Contact Us

For questions about this statement or the Company’s ethical sourcing practices:

• Email: [email protected]
• Phone: 07746 501247

Address: Custom Iron On Patches Ltd, 10 Newhall Street, Birmingham, B3 3AG