Modern Slavery Statement for Financial Year Ended 30.09.17
This statement is made pursuant the Modern Slavery Act 2015 and sets out the steps that Willerby has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. Willerby recognises Modern Slavery encompasses slavery, servitude, human trafficking and forced labour. Willerby has a zero tolerance approach to any form of modern slavery. Willerby is committed to acting ethically and with integrity and transparency in all business dealings and to putting effective and proportionate systems and controls in place to safeguard against modern slavery taking place within the business or our supply chain.
Willerby is the UK’s leading manufacturer of static holiday homes, manufacturing only in the UK, selling and distributing the homes mainly in the UK through a number of dealers and directly to holiday parks. Most components are bought directly from UK suppliers with who we have a long relationship although some are sourced from overseas, mainly from Europe. New suppliers are engaged when circumstances merit and subject to appropriate due diligence. The Board and Senior managers considered our supply chain during a series of presentations on our responsibilities under the Modern Slavery Act 2015 during 2017 by the Company’s lawyers and an initial assessment concluded Willerby did not appear to have any clearly identifiable high risk areas, although this matter is to be kept under regular review by our procurement and purchasing personnel.
We have a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- All Willerby Board Members have received a briefing paper on Modern Slavery.
- Willerby has a written Anti-Slavery and Human Trafficking Policy which sets out the organisation’s stance on modern slavery and explains how employees who identify any instances of this can report the same. It also explains the manner in which we behave as an organisation and how we expect our employees to behave.
- We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. Contact details for the HR team, the Finance director and Public Concern at Work (an independent whistleblowing charity) are detailed in this policy.
- Willerby operates a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- If appropriate posters will be positioned in procurement offices reminding those staff our responsibilities under the Modern Slavery act 201
- Our suppliers should take this statement as notice of Willerby’s policy against any Modern Slavery practices within their own organisation or own supply chain
In common with many manufacturers Willerby has a number of long established suppliers and a number of preferred suppliers Willerby intends to conduct proportionate due diligence on suppliers before allowing them to supply and/or become a preferred supplier. This due diligence includes:
- We will conduct online searches to ensure that particular organisation has never been convicted of offenses relating to modern slavery.
- Managers visiting suppliers’ premises are instructed to informally monitor working conditions. Procurement teams are to be instructed to report purchases offered at unrealistically low prices, the use of labour engaged on unrealistically low wages and provision of products by an unrealistic deadline.
- We will send a standard enquiry letter to certain nominated suppliers each year enquiring as to what steps they have taken to eradicate slavery within their own business and how the hold their own suppliers to account over modern slavery. Additional enquiries will be made to check they pay at least the national minimum wage in the UK. For any international suppliers we will ask that they pay their employees any prevailing minimum wage applicable within their country of operations.
- Our standard terms and conditions of supply will be reviewed at an appropriate time to see if additional termination clauses have to be included to allow termination if a supplier is in contravention of the Modern Slavery Act 2015. In the meantime we always reserve the right to terminate any contract at any time should any instances of Modern Slavery come to light.
Willerby has conducted training sessions during 2017 for senior managers and our procurement and buying teams so that they understand the implications of the Modern Slavery Act 2015 and are to be instructed on what to do if they suspect that it is taking place within our supply chain.
Our Key Performance Indicators
Whilst Willerby cannot guarantee our entire supply chain is entirely free of all aspects of Modern Slavery we nevertheless have a zero tolerance of the same if it is ever discovered. Willerby will know how effective the steps taken to ensure that slavery and/or human trafficking is not taking place within our business or supply chain by reviewing the number of reports being received from employees, the public, or law enforcement agencies that indicate that modern slavery practices have been identified. No decision has been taken on whether any Key Performance Indicators need to be developed with regard to the Modern Slavery Act 2015 and that matter will be kept under review.
Approval for this Statement
This statement was approved by the Board of Directors on 30 October 2017.
Susan Allan (Finance Director)