Slavery and Human Trafficking

Forced labour is a global problem affecting over 20 million people around the world. Tackling forced labour protects vulnerable workers and prevents human rights violations. This statement sets out our policy and what we are doing to ensure its effective implementation within Bonhams and our supply chain. It is made pursuant to section 54 of the Modern Slavery Act 2015.

Bonhams emphatically opposes the use and exploitation of forced labour. We expect everyone working for us, or on our behalf, to share our zero-tolerance approach. This reflects our legal duties but also our wider commitment to ethical and social responsibility.

Bonhams is one of the world's largest and most renowned auctioneers. Its main salerooms are in London, New York, Los Angeles and Hong Kong, but it also holds regular auctions in Edinburgh, Paris, San Francisco and Sydney through its global network of offices and regional representatives in 22 countries.

Bonhams has recently conducted a thorough review of its global business and is confident that it does not benefit from forced labour. This position will be kept under regular review. Bonhams has also taken the following steps this year in respect of its global supply chain:

  • prepared the annexed Supplier Code of Conduct on Forced Labour with which we expect

our suppliers to comply and against which we will assess compliance when deciding whether to enter into contractual arrangements;

  • established annual reviews of our supply chains to evaluate forced labour risk and, if a risk is identified, we will take immediate steps to address it;
  • commenced training personnel on the annexed Supplier Code of Conduct on Forced Labour and on identifying risks of forced labour in our supply chain.

The Board of Directors is ultimately responsible for ensuring compliance with this policy and will regularly review its effectiveness. All managers are responsible for ensuring that it is applied within their area of responsibility and all personnel are required to comply with it in full.

Our employees are aware that we do not tolerate forced labour within our business or our supply chain. If they suspect a breach of this policy or have concerns about forced labour in any part of our business or our supply chain, then they are required immediately to notify their manager or to report it in accordance with our well-established whistleblowing policy.

Matthew Girling
Global CEO
15th June 2018

ANNEX SUPPLIER CODE OF CONDUCT ON FORCED LABOUR

Bonhams opposes the use and exploitation of forced labour. We expect everyone working for us or on our behalf to share our zero-tolerance approach.

References in this Code to "forced labour" include slavery, servitude and any type of forced or compulsory labour as well as trafficking for the purposes of exploitation.

Accordingly, our expectations of suppliers are as follows:

1. Suppliers must not use forced labour.

2. If requested by us, suppliers must complete and return our self-assessment questionnaire regarding the use of forced labour and the steps they have taken to ensure that neither they nor their supply chain make use of it.

3. Suppliers must allow us to audit compliance with this Code of Conduct by inspecting their facilities, reviewing records, policies and practices and interviewing personnel. Suppliers are expected to provide prompt access to their facilities, records, documentation and personnel.

4. If we identify any non-compliance, suppliers must prepare, permit us to review and execute an improvement plan approved by us to rectify matters.

5. Suppliers must place similar expectations to those set out above on their own suppliers.

Subject to any contractual terms, we may terminate our relationship if a supplier fails to comply with this Code of Conduct. If appropriate, we may report any breach of the Code of Conduct to the appropriate authorities.

If a supplier or any other person has any concerns about the use of forced labour by Bonhams or in its supply chain, or suspects violations of this Code of Conduct, then please immediately notify the Chief Operations Officer of Bonhams.