Modern Slavery Statement

The Business acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Business understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Business does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Business in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Business strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, and in many cases ~xceeds those minimums in relation to its employees.

In order to fulfil its activities, the Business's main supply chains include those related to the manufacture of components as well as in some instances finished products, spares and accessories. 
We understand that the Business's first-tier suppliers are intermediary traders and therefore have further contracted relationships with lower-tier suppliers.

The Business considers its main exposure to the risk of slavery and human trafficking to exist in the components and products supply chain where their production may involve the provision of labour in a country where protection against breaches of human rights may be limited.
In general, the Business considers its exposure to slavery/human trafficking to be relatively limited.
Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

The Business carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Business has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Business has taken the following steps to ensure that modern slavery is not taking place:

  • reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
  • reviewing supplier policies to ensure that they are up to date and relevant
  • ensuring staff are aware of the Business's zero tolerance policy toward modern slaver

In the event that modern slavery is exhibited or suspected by the Business originating from a supplier.

  • The supplier is to be immediately suspended as an approved supplier
  • Further checks made with the supplier to confirm or deny any suspicions
  • If suspicions are founded, then the supplier is to be removed from our approved supplier list
  • In addition, any customer or supplier found to be in breach of the Modern Slavery Act 2015,
    may have contracts which exist between The Business and the supplier cancelled

The Business has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in The Business or its supply chains.

  • All staff in the Business to be fully conversant with its modern slavery policy and signed off within the HR system that they have completed this task
  • First-line suppliers to have their Slavery policies checked and monitored on an annual basis
  • All suppliers used within the Business to be checked for overall quality and adherence to the Modern Slavery Act 2015. Suppliers who do not come up to the required standard will be removed from our approved supplier list until such time as they do

The Business provides the following training to staff to effectively implement its stance on modern

  • Training on induction to the Business covering all our internal policies including modern
  • Training on induction to the Business to explain what we are looking for when considering a
    new supplier to add to the approved supplier list
  • An annual refresher for all staff to review and sign off that they have read and understood
    all sections of the staff and company manuals

The Business has a Compliance Officer, to whom all concerns regarding modern slavery should be
addressed, and who will then undertake relevant action with regard to the Business obligations in
this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed annually.


Jim Platt - VP EMEAA