Modern slavery statement

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Policy purpose

This is the Modern Slavery and Human Trafficking Statement for Chesterfield Special Cylinders. This statement is made pursuant to s.54(1) of the UK Modern Slavery Act 2015 (the “Act”).

The business is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and will impose the same high standards on its suppliers. The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Act.

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Policies

As part of the Company’s commitment to combating modern slavery, it has implemented the following policies:

• Recruitment Policy – the policy includes 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.
• Whistleblowing Policy – this ensures all employees know they can raise concerns about how colleagues are being treated, or practices within the business or supply chain, without fear of reprisals.
• Ethical Principles – these explain the manner in which the business behaves as an organisation and how it expects its employees and suppliers to act.

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Due diligence

As part of the Company’s efforts to monitor and reduce the risk of slavery and human trafficking occurring within its supply chains, it has the following due diligence procedures:

• the business builds long standing relationships with both local and international suppliers. They make clear its expectations of business behaviour and requires all suppliers to recognise the standards laid out in its Ethical Principles .
• the business has systems in place to encourage employees to report concerns.
• it is not practical for the business to have a direct relationship with all suppliers within the supply chain. The Company will expect every entity to adopt a minimum protocol of ‘one-up’ due diligence within the next link of the supply chain.
• the business periodically visits and audits its principal suppliers.

These procedures are designed to:

• establish and assess areas of potential risk in the business and supply chains
• monitor potential risk areas in the business and supply chains
• reduce the risk of slavery and human trafficking occurring in the business and supply chains
• provide adequate protection for whistleblowers

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Risk and compliance

The Company has begun to evaluate its exposure to the risk of modern slavery occurring in its supply chain.

The Company does not consider that it operates in high risk sectors or locations.

The Company has a zero tolerance approach to slavery and human trafficking in its business and its supply chain and will endeavour to introduce policies and procedures to ensure it both complies with the Act and reduces its exposure to the risk of modern slavery occurring in its supply chain . The business will not work with any supplier organisation that has been found to have knowingly been involved in slavery or human trafficking. As part of the Company’s contracting processes it intends to include specific prohibitions against any form of slavery or human trafficking. The business expects its suppliers to adhere to the same high standards, and take steps to ensure this approach is reflected in their supply chains.

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Training

In order to ensure proper understanding of the risks posed by modern slavery in the context of our organisation and supply chain, representatives of Chesterfield Special Cylinders intend to provide training to employees as appropriate.

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Further actions

Following our review of our actions to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking.

• Undertake a business-wide training programme to educate our staff to recognise and report occurrences of modern slavery and human trafficking in our business and supply chains.
• Expand major supplier due diligence to specifically cover slavery and human trafficking and to prevent it occurring in the business and supply chains.