Introduction
At Whittan Industrial Ltd we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking across all areas of our business. 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 2023/2024.
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 540 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 will include reporting to the relevant authorities.
Policies
The Whittan Group (including Lion Steel Equipment Limited) operates the following policies for identifying and preventing slavery and human trafficking in our operations and ensuring we are conducting our business in an ethical and transparent manner:
- 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 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.
- Employee 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 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.
- Bribery & Anti-Corruption Policy – Whittan values its reputation for both financial integrity and for its ethical manner of working. It recognises that any involvement in bribery/corruption is a criminal offence and will also have a detrimental effect of its reputation and image. We encourage our employees to report suspicions of bribery/corruption, providing them with suitable channels of communication and ensuring that sensitive information is treated confidentially and appropriately.
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 continuous 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
Assessing & Managing Risk
Whittan Industrial Ltd are aware that there may be a risk of modern slavery or human trafficking within our organisation and supply chains. We will manage these risks through:
- Regular audits of our suppliers and recruitment agencies to ensure that they continue to meet the high standards expected at the point they were approved to supply Whittan Industrial Ltd
- We will ensure when undertaking a further review of relevant people policies they include the consideration and prevention of risks of engagement of people or groups through Modern Slavery.
Training
Whittan Industrial Ltd requires all new starters to complete training on Modern Slavery as part of their induction programme. This training is refreshed for all employees every two years from date of completion.
Awareness
As well as training, Whittan Industrial Ltd continues to raise awareness of modern slavery issues by placing posters across our site that set out:
- 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
In addition, we have previously introduced the ‘Tackling Modern Slavery Action Plan’ to the business.
Measuring how we're performing
We will continue to measure our performance against our key performance indicators to ensure we are effective in combatting and controlling 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.
During the period 1st April 2023 to 31st March 2024 there were no reported incidents of whistle-blowing, modern slavery or bribery and corruption within Whittan Industrial.
We will continue to monitor our 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.
Action Taken
During the period 1st April 2023 – 31st March 2024, Whittan Industrial took the following actions to help tackle Modern Slavery & Human Trafficking within our organisation and supply chains:
- Mandatory assessment issued to all suppliers regarding ethical trading, human rights and modern slavery with the assessments reviewed by an employee of Whittan Industrial Ltd
- Modern Slavery e-learning issued to all existing employees with a mandatory refresher every two years and is part of the induction for new joiners and must be completed within four weeks of joining the Company.
- HR & Payroll audit of employee bank accounts to ensure that each employee has their own bank account and is not paid into an account of which they have no control of.
Next Steps
Actions to be taken in the financial year ending 31st March 2025:
- Ensure 100% completion rate for Modern Slavery training
- Perform onsite audit visit for all temporary agency labour providers, including their new starter inductions, payroll system processes and actions in identifying their employees are protected from modern slavery and human trafficking.
- To complete the Stronger Together ‘Employer Good Practice Implementation Checklist’ to identify further modern slavery risks within Whittan Industrial Ltd
This statement covers 1 April 2023 to 31 March 2024 and has been approved by the board of Directors for the Whittan Group and will be reviewed annually.