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Modern Slavery Statement

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Gibsons Games Ltd has taken and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Gibsons Games Ltd has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and relationships, and to implementing and enforcing effective systems and controls to safeguard against any form of modern slavery taking place within the business or our supply chain.

As a business, we want to ensure that working conditions in our organisation and our suppliers’ businesses are safe and hygienic, child labour is not used, employment is freely chosen, a living wage is paid, working hours are controlled and that there is no discrimination or harsh or inhumane treatment.

The company

Gibsons is a family-owned company founded in London in 1919.  Our mission is to create cherished moments through first class jigsaw puzzles and games, uniting innovation and heritage in a sustainable way.

Sutton, Surrey is home to Gibsons HQ where employees work together to drive worldwide growth. Our retail customers include major high street retailers and independent toy and gift stores, as well as garden centres and department stores. In 2019, we launched our e-commerce website which is now an integral revenue stream, alongside a thriving Amazon Seller Central business.

We develop our jigsaw puzzles and games in-house, working closely with game designers, artists and illustrators. We care deeply about what we do and are proud of our values: in our team, you’ll find passion, excitement and a determination to bring joy with our puzzles and games to our customers across the world.

Behind the puzzles and games is a passion to make a real difference to people. The service we provide our customers is second to none and we partner with our supply chain to ensure that together we achieve transparency and raise standards, whilst reducing our impact on the planet as much as possible. We are proud to have Investors in People accreditation and are thrilled to have become a B Corporation certified business in December 2023.


Due Diligence and Risk Assessment:

Our Ethical Trading Policy (code of conduct)


At Gibsons Games we aim to source responsibly. We have long-standing relationship with our partners and we care about the impact we have on the people who make Gibsons products.  We value these relationships and work to ensure that there are fair wages and decent working conditions throughout our supply chain.   

We believe that our commitment to these relationships support our values of bringing people together.  This Ethical Trading Policy outlines how we work with our supply chain and our standards. 

We also recognise that we live on a planet with finite resources and that we have a duty to seek to minimise our impact on the environment.   


We want our impact in the world to be a positive one.  All of our suppliers are reviewed to ensure the highest standards.  We use the Ethical Trading Initiative Base Code as our foundation, which is internationally recognized code of labour practice, and based on the standards of the International Labor Organization (ILO).   

Download the ETI Base Code (Available in various translations) 


As part of our commitment to ensuring high ethical and social compliance within our supply chain, all suppliers to Gibsons should be carrying out routine third party audit programmes. For our understanding of your business social compliance we would like to see an up to date SMETA, BSC, SA8000 or another globally recognised audit methodology for your business.  

For the production sites used by Gibsons Games you must supply a current (within 12 months) audit for this year and a corrective action plan (CAP) that is in progress. If you are unable or the data is not available, Gibsons will ask you to carry out an audit by an approved auditor at your expense which is approx. $800+ per day. We will try to limit audit duplication as much as possible and use existing audits when possible. 

If you are using multiple factories, please ensure you let us know all the factories addresses and send us audits to support each factory being used for Gibsons Games products.  

Working Together  

We recognise the challenges in every supply chain, and we encourage our suppliers to be open and honest in disclosing ethical issues. We will work in partnership with co-operative and socially responsible suppliers and factories to help them achieve the required improvements. However, if suppliers conceal information, or are not willing to take steps to improve their compliance, we are not able to begin (or continue) a commercial relationship with them.  


Our key suppliers in the UK are members of Sedex, a global non-profit organisation dedicated to driving improvements in ethical and responsible business practices. The Sedex company reference numbers are ZC3957787 and ZC1035431. Our Head office also is Sedex registered ZS419825777 and is connected through the platform with our suppliers. Through this membership, Gibsons Games Ltd has access to the Sedex on-line platform where suppliers share self-assessment questionnaires, ethical audits and non-conformities with the applicable policies which occurred. In addition, Sedex provides a risk assessment tool to evaluate the risk profile of suppliers in sourcing.


We require all recruitment and employment agencies used by our suppliers to hold a GLAA (Gangmasters and Labour Abuse Authority) License.


This Statement has been reviewed and approved by the Managing Director of Gibsons Games Ltd on 22nd August 2023 and will be reviewed annually.


Kate Gibson - Managing Director


Kate Gibson - Managing Director

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