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Version: May 2011
Modern Slavery and Human Trafficking Statement and Policy
alfer® aluminium Gesellschaft mbH ("the Company") based in Wutoeschingen, Germany, which also has operations in France, Italy, Switzerland, UK and Austria.
The Company’s supply chain is complex and encompasses purchases from its parent organisation and other alfer® trading partners and international suppliers.
Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking - all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and control to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations in the Modern Slavery Act 2015.
We expect the same high standards from all our suppliers, contractors and other business partners. We include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, and expect our suppliers will hold their suppliers to the same high standards.
Our policy applies to all persons working for us or on our behalf in any capacity, including all employees, directors, officers, agency workers, contractors and consultants.
The Company is committed to ensuring that its business dealings are carried out in compliance with applicable law and, in doing so, we endorse the implementation and promotion of ethical business practices to protect workers from being abused and exploited.
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps we have taken and continue to take to ensure that modern slavery - or human trafficking - is not taking place within our business or supply chains.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. We have a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our business and/or our supply chain.
The Company operates the following policies which together describe our approach to the identification of modern slavery risks and the steps to be taken to prevent slavery and human trafficking in our operations:
- Whistleblowing: the Company encourages all staff, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns are assured of confidentiality.
- Employee code of conduct: The Company’s code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when managing its supply chain.
- Supplier code of conduct: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers can be 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. Serious violations of the Company’s supplier code of conduct will lead to the termination of the business relationship. Any supplier found in breach of the code of conduct in relation to slavery and human trafficking will be requested to stop the procedure immediately and failure to do so will result in immediate termination of supply of goods.
- Supplier Information & Assessment Audit: The Company plans to put in place a supplier assessment programme to ensure that suppliers can demonstrate compliance with all relevant legislation and our supplier code of conduct.
- Corporate Social Responsibility: The Company recognises that good corporate social responsibility encompasses all aspects of sustainable development and the way we affect people through our business operations, including ethical trading, human rights, corporate responsibility and environmental responsibility.
- Ethical Strategy: The Company approach to purchasing could, potentially, have a direct effect on the lives of people anywhere in the world and we are therefore committed to doing business in a way which ensure that everyone in our supply chains benefits from trading with us.
The Company operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all potential suppliers before appointment. This due diligence may include an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery and (where relevant and considered necessary) on-site audits including a review of working conditions. Suppliers can if deemed necessary be required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our relationship with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business;
- They hold their own suppliers to account over modern slavery;
- That UK-based suppliers pay their employees at least the national minimum wage / national living wage (as appropriate and applicable from time to time);
- That international suppliers pay their employees any prevailing minimum wage applicable within their jurisdiction.
Our performance indicators To date no reports have been received from employees, suppliers, third parties or law enforcement agencies to indicate that modern slavery practices have been identified among our suppliers. Our overall aim is to ensure this remains the position.
Responsibility for the Company’s anti-slavery initiatives is as follows: Policies: The Company's Office/Health & Safety Manager is responsible for putting in place and reviewing policies. The Operations Teams is responsible for implementation and for investigating known or suspected incidences of slavery and human trafficking. Risk Assessment: The senior manager (reporting direct to Germany) is responsible for analysis of the risks of human rights and modern slavery.
Everyone issued with the policy must they have read and understood it. It is each individual's responsibility to ensure the prevention, detection and reporting of modern slavery either in the business or supply chain. Individuals are responsible for ensuring that they avoid any activity that my breach or lead to a breach of this policy and should raise any concerns with their line manager as soon as possible. The Company is committed to ensuring that everyone can feel comfortable raising concerns without risk of any detrimental treatment.