Modern slavery and human trafficking statement

Transcription

1 Tradelink WOOD PRODUCTS LTD Tradelink Huse 25 Beethven Street Lndn, W10 4LG United Kingdm Tel: Fax: Mdern slavery and human trafficking statement Intrductin Sectin 54 f the UK Mdern Slavery Act impses a legal bligatin n cmmercial rganisatins t publish an annual slavery and human trafficking statement. This statement sets ut the Tradelink Grup ( Tradelink ) actins and steps it has taken t understand and address any ptential mdern slavery and human trafficking risks related t its business peratins and supply chains. This statement relates t actins and activities during the 2016 financial year. As part f the glbal timber sectr where instances f mdern slavery have been identified and published by the media and NGOs, the rganisatin recgnises that it has a respnsibility t take a rbust apprach t tackling mdern slavery and human trafficking. Tradelink is cmmitted t preventing slavery and human trafficking in its crprate activities, and t ensuring that its supply chains are free frm slavery and human trafficking. Organisatinal structure Tradelink Grup is a multinatinal business, specialising in prcuring, machining, shipping and marketing hardwds. Tradelink undertakes the fllwing activities: Supplying a selected range f timber prducts frm the timber prducing regins arund the wrld. These prducts include sawn lumber, decking, flring, laminated prducts, plywd and railway sleepers Prviding a range f wd species in standard sizes and grades as well as specific cut t rder bespke specificatins Hlding stcks f key standard prducts in strategically placed warehuses arund the wrld Manufacturing f slid hardwd flring and ther wd prducts at ur wn factry in Brazil Cuntries f peratin and supply The rganisatin currently perates in the fllwing cuntries: Cuntry Lcatin Scpe U.S.A. Greensbr, NC Imprt, Sales & Prcurement Canada Burlingtn, Ontari Imprt, Sales & Prcurement China Shanghai Imprt and Sales France Nantes Imprt and Sales Prtugal Lisbn Imprt and Sales

2 Suth Africa Durban, Cape Twn & Jhannesburg Imprt and Sales Brazil Belém, Pará Manufacturing, Exprt & Prcurement U.K. Lndn Head Office, Imprt and Sales Singapre Singapre Prcurement frm S.E. Asia regin Supply regins include: Nrth America, Suth America, Malaysia, Indnesia and West Africa Assessing and managing risk Tradelink fllws the EUTR and Timber Trade Federatin due diligence prcedures. Its apprach t assessing mdern slavery risk in the supply chain builds n the risk assessment prcedures that currently exist within the cmpany. Tradelink s risk assessment f mdern slavery includes the fllwing prcesses: We check bth the Transparency Internatinal Crruptin Index f each surce cuntry where the lgs are harvested, and the UN Security Cuncil and Cuncil f the EU t see if sanctins exist t help us assess the risk f slavery We use resurces such as the Glbal Slavery Index Cuntry guidance t get infrmatin n pssible risks identified in the regins we surce in. We assess the respnses f each new supplier cmpleted Respnsible Purchasing Plicy (RPP) and attached frms We have an nging evaluatin risk assessment f ur current suppliers The supply chain fr each prduct/species underges a detailed Risk Assessment Analysis we require additinal infrmatin and verificatin frm the supplier where the assessment highlights the risk f pssible slavery in the supply chain Gvernance The develpment, annual review and versight f ur plicies and prcedures in relatin t anti slavery initiatives is the respnsibility f the Grup Cmpliance Officer and apprved by the bard f directrs, Our emplyees have been rientated n the benefits f develping stringent measures t tackle slavery and human trafficking, as well as the cnsequences f failing t eradicate slavery and human trafficking frm ur business and supply chains. Our plicies Tradelink is aware that the risk f mdern slavery impacts acrss a range f plicies. Tradelink perates the fllwing plicies that describe its apprach t the identificatin f mdern slavery risks and steps t be taken t prevent slavery and human trafficking in its peratins: 2

3 Emplyee cde f cnduct Our cde makes clear t emplyees the actins and behaviur expected f them when representing Tradelink. We strive t maintain the highest standards f emplyee cnduct and ethical behaviur when perating abrad and managing its supply chain. Tradelink s plicy is t treat all its wn emplyees with dignity and respect. Supplier/Prcurement plicy: Tradelink is cmmitted t ensuring that its suppliers adhere t the highest standards f ethics. Suppliers are required t demnstrate that they prvide safe wrking cnditins where necessary, treat wrkers with dignity and respect, and act ethically and within the law in their use f labur. Tradelink requires that suppliers meet the requirements f its purchasing plicy. Recruitment plicy We use nly specified, reputable emplyment agencies t surce labur and always verify the practices f any new agency we are using befre accepting staff frm that agency. The plicy is being reviewed t ensure that specific references are made t cmbatting the risk f mdern slavery in 2017 Due diligence, mnitring and auditing Tradelink undertakes due diligence when taking n new suppliers and it carries ut annual reviews f its existing suppliers, r mre regularly as required.. Tradelink s due diligence apprach t Prcurement is clearly utlined in ur Due Diligence Prcedure fr Surcing f Timber prducts. Our due diligence prcesses include: Scheduling a high level risk mapping f the supply chain bradly t assess mdern slavery and human trafficking risks f particular prduct r in particular gegraphical areas. Evaluating the mdern slavery and human trafficking risks f each new supplier via CSR feedback and nsite visits. Onging reviews f ur supply chain based n ur current supply chain mapping f ur prducts/species Cnducting supplier audits r assessments, when pssible thrugh visits cnducted by senir management r an appinted agent. Our suppliers Our suppliers have t underg a supplier apprval prcess by cmpleting ur Respnsible Purchasing Plicy)(RPP) and having their supply chain mapped and apprved prir t any initial rders being placed. In additin t this requirement fr new suppliers we undertake the fllwing actins: creating an annual risk prfile fr each supplier (including current suppliers); taking steps t imprve substandard suppliers' practices, including prviding advice t suppliers and requiring them t implement actin plans; 3

4 invking sanctins against suppliers that fail t imprve their perfrmance in line with an actin plan r seriusly vilate ur supplier prcurement plicy, including the terminatin f the business relatinship as a last resrt. Perfrmance indicatrs We have reviewed ur key perfrmance indicatrs (KPIs) in light f the intrductin f the Mdern Slavery Act As a result, Tradelink will intrduce and mnitr the fllwing KPIs during % actin taken n any reprted instances f breaches t the Tradelink supplier cde 100% f all staff (including supply chain managers and HR prfessinals) wrking in identified high risk areas t cmplete awareness, t have training n mdern slavery by watching Mdern Slavery is clser than yu think as part f their inductin Training and Capacity building Training will be develped and delivered t relevant staff, including the senir management team with a particular fcus n buying practices, recruitment, wages and deadlines fr prduct delivery. We have been raising awareness f mdern slavery issues in the rganisatin by circulating a series f s and publicatins. These s have included infrmatin n the fllwing issues related t Mdern Slavery: the basic principles f the Mdern Slavery Act 2015; hw emplyers can identify and prevent slavery and human trafficking; what emplyees can d t flag up ptential slavery r human trafficking issues t the relevant parties within the rganisatin; and what external help is available, fr example thrugh the Mdern Slavery Helpline. Next steps We have undertaken a detailed CSR/ mdern slavery gap analysis audit with an external expert prvider t help identify ther areas where we require capacity building and supprt prgrammes t als include mdern slavery issues. Tradelink is cmmitted t imprve its plicies and prcedures t ensure that any risk f mdern slavery in the business r supply chains is identified and prperly addressed. During the current year we will be: reviewing ur existing supply chains with fcus n mdern slavery risk Prviding training n key issues t ur senir and middle management team ver the next 18 mnths Reviewing ur plicies and prcedures and risk assessments t incrprate apprpriate references t mdern slavery Develp best practice requirements in relatin t mdern slavery issues 4

5 Bard apprval This statement has been apprved by Tradelink s bard f directrs, wh will review and update it annually Date: 29 June, 2017 Managing Directr: HERMAN P. SCHEY 5