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Modern Slavery and Human Trafficking Statement

1. Introduction

Modern day slavery and human trafficking remains an abhorrence on local, national and global societies. Empteezy Group has a responsibility to recognise and combat the risks posed from slavery and human trafficking however small, within our business and in the wider supply chain. Staff are expected and encouraged to report concerns and management are expected to act upon them. This responsibility extends beyond the limits of our borders and includes our supply chains in those countries we deal with as part of our business. We have established and implemented internal processes with the aim to identify any instance of slavery or trafficking within our organisation before they become an issue and the steps to be taken should any potential issue occur, and we expect all our supplier’s and contractors to support this aim. We have never been involved in any form of slavery and human trafficking and to the best of our knowledge no supplier or contractor we use has been involved in slavery and human trafficking. Where we find evidence that a supplier or contractor has been prosecuted for any breach in modern day slavery legislation, we will take action that is proportionate to the seriousness of the breach including ceasing trading with the supplier or contractor.

2. Organisation and Structure

The Empteezy Group manufactures metal and plastic spill containment products used within all industry sectors. The Empteezy Group is the parent company of Empteezy Limited and Romold Limited both of which are located in Livingston, Scotland UK. The Group’s headquarters is in Livingston and has outlets in the UK, France, Germany, Italy, Spain and Belgium.

The Group has a turnover in excess of £36M.

3. Our Supply Chains

Our supply chain includes the sourcing of raw materials predominately used in the production of metal, plastic and other types of materials used in spill containment products from suppliers mainly within the UK and Europe.

4. Our Policies on Slavery and Human Trafficking

The owners and directors of Empteezy Group are committed to ensuring that there is no slavery or human trafficking in any part of our business or supply chains. We, have in place an Anti-Slavery and Human Trafficking Policy that reflects the Group’s commitment to act ethically and with integrity in all our business relationships and to establish, implement and enforce effective systems and controls that are designed to highlight potential instances of  slavery or human trafficking taking place in any part of our organisation or supply chain.

5. Due Diligence Process

As part of our commitment towards anti-slavery and human trafficking we have developed and established systems to identify and alleviate the risks, as follows:

  • All employees are provided with employment contracts.
  • We only employee person’s over the age of 16.
  • Use only properly registered employment agencies for the provision of temporary labour and ensure temporary workers are not penalised by the agency for providing temporary employment.
  • Comply with the Working Time Regulations.
  • Prospective employees must provide proof of residence and National Insurance Information.
  • Employees must provide bone-fide proof of home address and bank details for the payment of wages and any other communication deemed necessary.
  • Identify addresses being used by several employees as this could be a sign of slavery.
  • Where workers are foreign national’s or migrant workers, they must provide proof that they are legally entitled and eligible to work in the UK prior to engagement. Where proof in not forthcoming and we suspect that the individual is not eligible to work in the UK their details will be passed onto the appropriate agency.
  • Systems are in place to encourage reporting of concerns and protection of whistle blowers.

      6. Measurement of the effectiveness of preventing slavery and human trafficking

      We use key performance indicators (KPI’s) to measure how effective we have been to ensure slavery and human trafficking is not taking place within our organisation or our supply chain, such as:

      • The number of staff requiring to complete training in modern slavery.
      • Payroll and labour monitoring.
      • Ensuring that the degree of communication and personal contact with the next link in the supply chain to confirm that their understanding of and compliance with our values and expectations.
      • Undertaking audits within the organisation to ensure the adequacy of our systems and that staff are complying with the organisation’s policies on slavery and human trafficking.
      • Liaising with and visiting supplier’s and contractors where necessary to ensure their understanding and compliance with our commitment to prevent slavery or human trafficking.

      2021 Results

      • All staff trained in the company’s anti-slavery standards.
      • Weekly payroll monitoring and new starts did not highlight any issues.
      • No adverse reports on supplier breaches during the period.
      • No anti-slavery incidents involving employees reported to management during the period.
      • Annual audit did not throw up any issue that would give rise to the presence of any anti-slavery practice.
      • Last review of risk assessment found that the RA did not require any amendment.

          7. Training

          As part of our on-going commitment to continual improvement and to ensure the understanding of the risks of slavery and human trafficking to our organisation and supply chains we provide training on how to deal with instances of slavery and human trafficking to relevant key staff. All our directors have been briefed on the subject and are committed to the ideal that modern day slavery and human trafficking must not be allowed to take place within the organisation or supply chain.

          This statement is the Empteezy Group’s commitment to operating within the law and is made in pursuant of section 54(1) of the Modern Slavery Act 2015 and represents Empteezy Group’s slavery and human trafficking statement for the current financial year.

          Signed: Susan Fraser

          On behalf of the board of directors

          End of Last Financial Year 31st October 2023

          Approved by the Board 5th July 2024