Ethical Trading Statement

As a business we take the issues of ethical trading and the elimination of bribery and corruption, modern slavery and human trafficking seriously and expect our employees to raise any concerns they have, or observe, with their immediate manager or a Director of the Company. We are also committed to taking all reasonable steps to uphold and promote responsible business practices related to all of these topics.


The purpose of this Statement is to outline our position in relation to ethical trading, and should also be read in conjunction with our Modern Slavery Statement which can be found on our website.


It is intended that all employees are informed of and abide by the principles laid out within this Statement. In addition, we communicate to and seek to encourage all of our and suppliers to comply with the principles of this Statement.

Our Business 


Recommerce Ltd is focused on the recycling and remarking of used electronic devices. Our model is inherently sustainable and supports the circular economy which helps to reduce carbon emissions by slowing down new production.


Our employees are all employed within the United Kingdom and, as a minimum, are employed on terms protected by United Kingdom employment and health a safety legislation. Much of our supply chain for our business activities, together with the products we use inhouse are also sourced from within the UK or EU and thus their workforces will also be protected by the same legislative requirements.

Core principles of Ethical Trading


We comply with the terms of the Ethical Trading Initiative Base Code (ETI Code) and expect the same standard within our supply chain, namely;


  1. Employment is freely chosen
  2. Freedom of association and the right to collective bargaining are respected
  3. Working conditions are safe and hygienic
  4. Child labour shall not be used*
  5. Living Wages are paid
  6. Working hours are not excessive
  7. No discrimination is practised
  8. Regular employment is provided
  9. No harsh or inhuman treatment is allowed

*(where employees are under the age of 18 they are only employed in accordance with UK law, they are free to leave at any time and thus any employment undertaken will in no way impinge upon their opportunity for full time education.)


If at any time we identify we are falling materially short in any area, we will take immediate action to rectify matters and if we identify similar shortfalls in third party stakeholders such as suppliers, we will inform them of our concerns, encourage them to take rectification action and if this is not forthcoming, take action to cease our relationship with them as soon as is reasonably practical.

Due Diligence


It is the role of the Directors, to ensure that all employees abide by and are protected by the principles of the ETI Code. As a business we will, as far as is reasonably practicable, given the resources available to us seek to:


  • Assess the level of risk of exposure to us from any third-party stakeholder
  • Instigate a process to ensure that any high-risk stakeholders identified understand and are encouraged to comply with the principles of the ETI Code
  • Not knowingly trade with any organisation where there are clear breaches of the ETI Code

We conduct regular audits in line with our ISO certification, to ensure compliance to this Ethical Trading Statement. We also audit the key suppliers within our supply chain on a similar basis. As part of the key supplier onboarding process, all suppliers must sign to accept adherence to meeting the same Ethical standards as Recommerce Ltd, and allow an audit of their premises, people, and operations. A site visit is mandatory before any key supplier is onboarded.


Audits take place annually unless more regular assessment is required. A checklist will review performance against the core principles of ethical trading and adherence to UK/EU or local employment legislation. This may involve employee interviews or suppliers providing evidence of their own HR, or supply chain records to prove adherence. If performance fall short in any area corrective action will be required within a specified timeframe or the supplier will be removed from the approved list.


Training & Communication


This Statement will be communicated to all employees and where necessary, training will be provided. A copy of this Statement will also be supplied to any third-party stakeholders when it is considered appropriate to do so.




We will maintain a zero-tolerance approach to unethical and illegal trading practices and will expect our third-party stakeholders to adopt a similar approach to this issue.


Company policies are in place to support our stance on this and to assist us in the assessment, prevention, and elimination of such issues in our organisation or its supply chain. These policies include: 


  • Anti-Slavery Policy
  • Anti-Bribery and Corruption Policy
  • Grievance Policy 
  • Whistle Blowing Policy 
  • Health and Safety Policy 

Approval of this Statement 


This statement was approved by the Board of Directors at the February 2022 Board Meeting.

Chris Eaton

Managing Director

Recommerce Ltd