Introduction
At Whittan Industrial Ltd we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our manufacturing operations and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2022/23.
Our business and supply chains?
Who we are – Whittan Industrial Limited
What we do – We design, manufacture and install innovative shelving and pallet rack solutions
How we do it – We employee over 600 talented individuals across the group whose roles include Fulfilment, Sales, Manufacturing, Supply Chain, Technical, Finance, IT and HR.
Where we do it – We have 4 manufacturing sites across the UK, and are part of a wider group (The Whittan Group) with commercial offices in Spain and subsidiaries in Germany, Belgium, France and the Netherlands.
We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.
We have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and instigate our Modern Slavery action plan which may include reporting to the relevant authorities.
Policies
The Whittan Group operates the following policies for identifying and preventing slavery and human trafficking in our operations:
- Modern Slavery and Human Trafficking Policy – This policy supports our commitment across all business areas, divisions and subsidiaries within The Whittan Group, including Lion Steel Equipment Ltd, herein to limiting the risk of modern slavery occurring within our own business or infiltrating our supply chains or any other business relationship.
- Whistleblowing Policy – We encourage all our employees, workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Code of Conduct – Our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
- Supplier Code of Conduct – We have updated our supplier contracts to make explicit reference to slavery and human trafficking. We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers maybe required to demonstrate that they provide safe working conditions where necessary, treat workers 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 improve their worker's working conditions. However, serious violations of our supplier code of conduct can lead to the termination of the business relationship.
- Recruitment/Agency workers – We have highlighted in our Recruitment guidance for Managers policy that we use only specified, reputable employment agencies to source labour and always verify the practices of any new agency we are using before accepting workers from that agency. We have put in place the past year an action plan to address the requirement to undertake annual audits of the agencies who are providing us direct labour in our manufacturing sites.
Supplier due diligence
The Supply Chain at Whittan Industrial Ltd is complicated due to the number of suppliers we have, and the multi levels of country of origin.
Our suppliers form an integral part of our value chain and we expect our supply partners to meet specific standards.
Whittan Industrial Ltd conducts due diligence on all suppliers during approval and continuos evaluation existing suppliers at regular intervals. This includes:
- This policy document will be communicated to all our suppliers.
- All suppliers to sign up and to agree with this policy or use this policy to further develop their own supply chains to ensure compliance to UK Modern Slavery Act 2013
- Where risk deems it necessary, we will conduct audits of our suppliers to ensure no slavery, forced labour or human trafficking is being carried out by the supplier’s business.
- Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to attest that:
- They don't use any form of forced, compulsory or slave labour
- Their employees work voluntarily and are entitled to leave work
- They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
- They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons
They don't require employees to surrender their passports or work permits as a condition of employment.
Awareness
We have raised awareness of modern slavery issues by putting up posters across our manufacturing sites and communicating out to all our employees that explains:
- Our commitment in the fight against modern slavery
- Red flags for potential cases of slavery or human trafficking
- How employees should report suspicions of modern slavery
- Introduced the ‘Tackling Modern Slavery Action Plan’ to the business
Training
In addition to creating awareness internally, Whittan Industrial has rolled out e-learning courses to all new starters within the organisation, which highlights:
- The various forms of modern slavery in which people can be held and exploited
- The size of the problem and the risk to our organisation
- How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
- How employees should respond if they suspect slavery or human trafficking
- How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
- What external help is available for the victims of slavery
- What terms and guidance should be provided to suppliers in relation to slavery policies and controls
- What steps the Whittan Group will take if a supplier fails to implement anti-slavery policies or controls
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Measuring how we're performing?
We have defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:
- Number of modern slavery risks identified: We will track the number of potential modern slavery risks identified within our supply chain, including high-risk countries, industries, or suppliers.
- Supplier engagement and assessment: We will measure the percentage of suppliers engaged and assessed for modern slavery risks, including assessments of their policies, practices, and due diligence procedures.
- Modern slavery training: We will track the number of employees trained on modern slavery risks and how to identify and report potential instances of modern slavery.
- Incidents reported and addressed: We will track the number of incidents of modern slavery reported within our supply chain or business operations and demonstrate how effectively they were addressed and resolved.
- Third-party audits: We will measure the percentage of third-party audits conducted to verify that suppliers and other business partners are complying with modern slavery laws and regulations.
- Modern slavery policies and procedures: We will measure the number of policies and procedures we have in place to prevent and address modern slavery risks, including due diligence procedures, whistleblowing and ethical sourcing policies.
- Transparency and disclosure: We will track the level of transparency and disclosure around modern slavery risks within our business, including public reporting on our continued efforts to address modern slavery and our supply chain transparency.
Overall, these KPIs demonstrate our commitment to tackling modern slavery and monitor the effectiveness of our modern slavery initiatives over a period of time. By measuring and addressing modern slavery risks, we can continue to protect human rights, safeguard the businesses reputation, and build trust with our stakeholders.
This statement covers 1 April 2022 to 31 March 2023 and has been approved by the board of Directors for the Whittan Group and will be reviewed annually.
