Slavery and Human Trafficking Policy

Modern Slavery and Human Trafficking Statement

Company Policy

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes the Company’s Anti-Slavery and Human trafficking statement for the current financial year.

Introduction

This document sets out BCB International Ltd.’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed to ensure that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to BCB’s ongoing actions and activities.

As part of the manufacturing and import industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensure that its supply chains are free from slavery and human trafficking.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that modern slavery or trafficking plays no part in our supply chain or in any part of the business.

We are committed to acting ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to, as far as practical, ensure slavery and human trafficking is not taking place anywhere in the organisation or supply chain.

Our Supply Chain

Our supply chain comprises the engagement of subcontractor organisations to carry out works and services on our construction sites and the sourcing of materials and manufactured products.

Supplier Adherence

We have zero tolerance to slavery and human trafficking and we expect all those in our supply chain and contractors to comply with in our values. ‘with’

Responsibilities

Responsibility for organisation’s anti-slavery initiatives is as follows;

Risk Assessments

Where a risk is considered, e.g. due to location of supplier (Tier 1), an assessment will take place to ensure compliance with the Act. In addition, in certain industries where there is a high risk of slavery (e.g. forestry), the Company shall put measures in place to ensure sustainable resourcing is achieved (e.g. FSC timber product only)

Investigations/Due Diligence

When a risk has been identified the Health, Safety, Quality and Environment (HSQE) team will assess and investigate any potential breach to the legislation.

Employment and Training

We operate a robust recruitment process in line with UK employment laws, including: ‘right to work’ document checks, contracts of employment and checks to ensure everyone employed is age 16 and above. We expect our supply chain to operate a similar policy and be able to demonstrate similar checks are in place.

We reward our staff to at least market-related pay levels, which are reviewed annually.

Staff involved in the selection of suppliers and subcontractors are trained in their responsibilities and briefed as to the requirements of this policy.

Due Diligence & the Supply Chain

The organisation undertakes due diligence when considering taking on new suppliers and regularly reviews our existing suppliers.

Supply Chain

We operate a supplier policy and maintain a preferred supplier/subcontractor list. We endeavour to place contract/orders with local companies where practicable. We conduct due diligence on all suppliers before allowing them to become a preferred supplier, this includes them completing a questionnaire and supplying details which relate to the Modern Slavery Act. We have a zero-tolerance approach to slavery and human trafficking and expect our suppliers and contractors to uphold the same values. We will not conduct business knowingly with anyone engaged in slavery and human trafficking practices, our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operation is in breach of this policy.

Further Steps

We shall undertake an annual review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains with a view to identifying further steps that we can take.

This statement has been approved by the organisation’s Directors whom will review and update it annually.

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