Modern Slavery Statement and Human Trafficking Statement
We are committed to taking steps and improving our practices to prevent slavery, human trafficking and other human rights violations (including child and forced labour) in both its operations and supply chain.
Responsibility and approach
We understand that the issue of slavery and human trafficking is a global one and that no business sector will be able to eliminate slavery or human trafficking from their supply chain without working collaboratively within its industry.
As part of our commitment, we undertake regular reviews of our supplier base, encouraging frequent interaction with suppliers by multiple persons from within our organisation, and strongly support and undertake visits to our suppliers manufacturing facilities as frequently as is possible. We will immediately suspend purchasing from a supplier, pending an investigation, if we believe there to be any evidence of slavery or human trafficking, and we will cease trading with the supplier if the investigation confirms any slavery or human trafficking.
Our Supply Chain and Interaction
We work closely with our suppliers throughout the year, and suppliers are met with as frequently as is possible through:
- Meetings at suppliers manufacturing facilities and/or showrooms;
- Meetings at the Company’s premises; and
- Trade shows, and collaborative events/presentations.
Frequent interaction is undertaken by the delegated buyers within the Company with regular support from members of the Company’s Executive Team. During all its interactions the Company is committed to stating its commitment to a supply chain free from slavery and human trafficking. Additionally, the Company is committed to reviewing firsthand the suppliers’ operations, facilities and living arrangements (where they are provided by the supplier to their workforce), to better ascertain that its supply chain is free from slavery or human trafficking. The Company also requests and reviews the results of its suppliers’ own audits and any related policies where available.
Ongoing support and resource will be given to the Company’s employees interacting with suppliers to better help them identify slavery or human trafficking practices. Employees are protected by certain policies the Company has in place, including Anti-Corruption and Bribery, Fraud and Anti-Money Laundering and Whistleblowing and these were all reviewed during 2019 to ensure that they continued to be fit for purpose. The Company’s Whistleblowing Policy sets out the formal process by which an employee may, in confidence, raise concerns about possible improprieties in financial reporting or other matters, including any concerns relating to modern slavery.
Any potential new suppliers in higher risk areas will be assessed for modern slavery and human trafficking purposes prior to establishing a business relationship. They will be required to complete a questionnaire detailing their policies and procedures and provide all supporting documentation to the Company’s satisfaction. We will not enter into any business relationship with any new supplier who does not reach our standards during this review. Each new supplier in higher risk areas will be visited and within the first twelve months of establishing the business relationship. Should any potential supplier not reach the high standards demanded by the Company, the Company will work with the supplier to improve its processes. If it is ultimately unable to reach the required standard within a specific timescale, the Company will not work with that supplier.
Effectiveness of procedures
During 2019 all of our suppliers from outside the EU received either a visit or completed a questionnaire. The Company therefore believes its procedures which have been implemented to minimise the risk that slavery and human trafficking does not take place in its business or supply chain are effective. The procedures are reviewed annually.