MODERN SLAVERY STATEMENT
This statement is made on behalf of Glen Dimplex Home Appliances Limited ("GDHA") pursuant to Section 54(1) of the Modern Slavery Act (the "Act") and constitutes our slavery and human trafficking statement.
GDHA is a limited company registered in England and Wales (company number 02692306).
Introduction from the Chief Executive Officer
As a key manufacturer and provider in the domestic appliance sector, we always work to the highest ethical standards and ensure that we comply with all laws, regulations and rules that are relevant to our business.
Slavery and human trafficking are totally unacceptable and we will not tolerate forced labour of any description within our business or in our supply chains. We recognise our moral and legal responsibility to help prevent modern slavery and human trafficking and commit to taking robust and effective steps to ensure no such activities arise in the operation of our business.
Our aim is to achieve the highest ethical standards in this regard and as a minimum, we will comply with all relevant legislation. We all have a responsibly to be alert to the risks of modern slavery and human trafficking, however small, in all our daily activities. With that in mind, our employees are expected to report to us any concerns they may have in this regard and our managers are expected to act upon any concerns raised without delay.
Continual improvement in the area of business ethics is supported and monitored by the measurement of our performance by auditing and reporting. Additionally, we periodically review internal policies and procedures and will, in particular, review them in the event of any major organisational changes, the introduction of new legislation or in the event of any breach of the policy.
This statement sets out the action we have taken to identify, understand and address all risk of modern slavery and human trafficking in our own business and in our supply chains during the last financial year. It also sets out the steps we have put in place aimed at ensuring that there is no slavery or human trafficking in our own business or our supply chains.
Organisational Structure and Supply Chains
GDHA is a manufacturer of large white goods, cooking appliances and water boilers. We manufacture free-standing, built-in and range cookers, as well as both gas and electric hobs. The organisation has manufacturing and warehousing facilities in the UK and we operate from sites in Prescot on Merseyside, Buckley in Flintshire and Trentham Lakes in Stoke-on-Trent.
In addition to our operations in the UK, we also purchase many other large kitchen appliances from third party suppliers overseas, including but not limited to fridges, freezers, dishwashers and washing machines, for distribution to customers in the UK. We also buy components for use at our UK manufacturing sites. Our current supply chains operate in Western Europe, Eastern Europe and Asia.
Responsibility for our anti-slavery initiatives is as follows:
- Overall: Our HR Director has been appointed as the key contact for issues relating to modern slavery and human trafficking within our UK operation. Our Purchasing Director has been appointed as the key contact for modern slavery and human trafficking issues within our supply chains.
- Policies: It is the responsibility of the HR, Purchasing and Quality Departments to ensure that relevant policies are in place for the areas of the business that are at risk of coming into contact with slavery or human trafficking. They are also responsible for ensuring that the policies are periodically reviewed and, when appropriate, updated.
- Risk assessments: For our supply chains, the Purchasing Department are responsible for carrying out the modern slavery and human trafficking risk analysis.
- Training: All managers within our business who have responsibility for recruiting labour have received awareness training on modern slavery and human trafficking and are aware of this risk this brings to our business. They are also trained on the actions the Company takes to minimise this risk.
GDHA has in place the following policies that set out our approach to the identification and prevention of modern slavery and human trafficking in our own business and our supply chains.
- Modern Slavery Policy: Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
- Whistleblowing Policy: We encourage all our employees, workers, customers and other business partners to report any concerns related to activities within our business or in our supply chains. This includes any circumstances that may give rise to an increased risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Anyone who has a concern can contact our HR Director on a direct number which is included in the Employee Handbook.
- Purchasing Code of Conduct: We are committed to ensuring that our suppliers adhere to the highest ethical standards. Suppliers are required to demonstrate that they provide their workers with safe working conditions, treat them with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and, where necessary, work with them to improve their worker's working conditions. Serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship (as described in the “Code of Business Ethics and Conduct”).
- GDHA Code of Business Ethics and Conduct: The Code sets out the standard of ethical conduct we expect from our suppliers. All suppliers are expected to sign up to the Code and to ensure that they comply with it. The Code also sets out the implications for a supplier of acting in breach, including termination of the business relationship.
- Anti-Bribery Policy: We act in accordance with our obligation under the Bribery Act 2010 to prevent and prohibit bribery and to ensuring that the highest standards of professional ethical conduct are maintained.
- Agency Workers: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. Suppliers of Agency labour in the UK Operations are Gangmasters Licensing Authority ("GLA") registered.
Due Diligence and Compliance
As part of our initiative to identify and mitigate risk, we undertake due diligence when considering taking on new suppliers and regularly review our existing suppliers against the same criteria. Our due diligence and reviews include:
- Assessing whether or not particular activities, countries or regions are high risk in relation to slavery or human trafficking by conducting supplier audits or assessments through our own staff. As part of the routine audit we take into account a number of factors, including the ages of the workers employed by the supplier and their working conditions;
- We consider any supplier from Eastern Europe or Asia, be they supplying components or finished goods, to be at high risk and the auditing or assessment of suppliers from those regions will have a greater degree of focus on slavery and human trafficking;
- Taking steps to improve substandard suppliers' practices, including providing advice to suppliers through the audit process and face to face meetings on their premises;
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship;
- In addition, the company directors of the supplier are asked to sign up to our Code of Business Ethics and Conduct.
We have reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015 to measure how effective we have been in ensuring that modern slavery and human trafficking is not taking place in our business or supply chains. As a result, we are:
- Reviewing the training programmes which are being undertaken within the Supply Chain
- Requiring all managers in the UK Operation to complete training on Human Slavery by December 2017;
- Developing a system for supply chain verification, in place since April 2016, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
- Conducting a review of its existing supply chains, expected to be completed by March 2017, whereby the organisation evaluates all existing suppliers.
Training and Raising Awareness
We require all managers within our own business to complete training on modern slavery.
The organisation requires all staff working in the supply chain to have been trained in accordance with the Glen Dimplex Code of Business Ethics and Conduct.
The organisation's modern slavery training covers the list below:
- our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline.
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
- how to identify the signs of slavery and human trafficking.
- what initial steps should be taken if slavery or human trafficking is suspected.
- how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.
- what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and "Stronger together" initiative.
- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.
- what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.
In addition to the above, the HR Director and Purchasing Director have attended "Tackling Modern Slavery in UK Businesses and Supply Chains" training.
As well as training staff, the organisation has raised awareness of modern slavery issues by putting up posters across the organisation's premises and circulating a series of emails to staff. The posters and emails explain to staff what external help is available, for example through the Modern Slavery Helpline.
This statement has been approved by the organisation's Management Team who will review and update it annually.