The UK Modern Slavery Act 2015 (the “Act”) came into effect on 29 October 2015. The Act requires any commercial organisation, including manufacturers carrying on a business or part of a business in the UK, which supplies goods and/or services and which has an annual turnover in excess of £36 million, to disclose information regarding its policies and the steps it has taken to eradicate slavery and human trafficking within its own business and from its supply chain.
This Slavery and Human Trafficking Statement (the “Statement”) is made pursuant to Section 54, Part 6 of the Act with the purpose of clearly setting out the steps the Organisation has taken to ensure that slavery and human trafficking are not taking place in the Organisation’s supply chains and/or in any part of the Organisation’s business.
The Organisation plays an active role to promote (i) a robust supply chain and (ii) supplier development and awareness through its Supplier Code of Conduct (“Code”). The Code clearly communicate the Organisation’s expectations with regards to companies the Organisation works with in the supply chain domain ("Suppliers"). Suppliers have a responsibility to adhere to the Code and to promote human rights within their own supply chains. The breadth of the Organisation’s supply chain has posed a challenge to the Organisation within the financial year 2015 – 2016 with respect to ensuring compliance by all Suppliers with the Code.
The Code makes reference to the Organisation's Corporate Social Responsibility Charter and more specifically to: ethical behaviour, anti-corruption, conflicts of interest, conditions of employment, discrimination, freedom to associate, humane treatment, child labour, working and living conditions, environment, management systems and supply chain management.
In addition, the Organisation issues purchase orders to its Suppliers that incorporate the Organisation’s General Conditions of Purchase (“Terms of Purchase”). The Terms of Purchase expand on the Organisation’s expectations of Suppliers and Suppliers’ obligations in relation to specific topics. The Terms of Purchase govern the majority of purchases by the Organisation of goods and services from its Suppliers. Under the Terms of Purchase, the Organisation reserves the right to terminate its relationship with a Supplier if non-compliance with the Organisation’s Code and Terms of Purchase is discovered and/or such non-compliance is not addressed in a timely manner.
Internally, the Organisation has adopted an Employee Handbook on Business Ethics Policy (“Business Ethics Policy”) which sets out the Organisation’s ethical standards and which details and promotes the Organisation's expectations of its employees to comply with such standards. This Business Ethics Policy applies to the Organisation’s employees and operations, but the Organisation encourages businesses throughout its supply chain and sales network to adopt and enforce similar policies in their own operations.
“Slavery” can take many forms, including but not limited to, human trafficking and child labour. The Organisation’s Code and Terms of Purchase clearly state that the Organisation does not tolerate Slavery in the Organisation’s supply chain and operations. During the financial year 2015 – 2016, the Organisation was not able to conduct audits of all of its Suppliers to ensure compliance with the Code and the Terms of Purchase. The Organisation does however conduct regular internal training on ethics with all of the Organisation’s employees. Additionally, the Organisation's employees involved in supply chain activities are familiar with the Code and its principles.
Senior Management of the Organisation has approved this Statement.