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Modern Slavery Statement

Modern Slavery and Human Trafficking Policy Statement 2024

We have a zero tolerance to any form of slavery, human trafficking and unlawful child labour, and are committed to enforcing effective systems and controls to ensure neither is taking place in any part of our business or supply chains.  Senior leaders are accountable and committed to ensuring we do what is right for our customers, members and the communities that we operate in. 

 

Our commitment

 

Pall-Ex Group LTD* (Pall-Ex) is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”). It also strongly believes that it has a responsibility for promoting ethical and lawful employment practices.

Accordingly, Pall-Ex will not knowingly use unlawful child labour or forced labour in any of the utilities and/or other commodities, products and/or services it provides, nor will it accept commodities, products and/or services from suppliers employing or utilising child labour or forced labour.

 

Human trafficking and slavery are crimes under UK and international law. This policy statement thus defines Pall-Ex`s commitment to ensuring that human trafficking and slavery do not exist within its own business, but also provides how Pall-Ex will make efforts to eradicate the same from other businesses with whom it maintains a relationship (and especially from within its supply chain).

Definitions

 

  • Human Trafficking

The recruitment, transportation, transfer, harbouring or receipt of persons, by means of  threat or use of force or other forms of coercion, abduction, fraud, deception, the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

 

  • Forced Labour

All work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty.

 

  • Harmful Child Labour

Consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

 

 

Accountability

 

All our leaders will take appropriate steps in their business areas to ensure compliance but also that these requirements are followed by its suppliers, subcontractors and/or business partners (collectively by it “Suppliers”) worldwide.

 

Training

 

All new employees will be introduced and guidance provided in the induction programme. It includes information on the process if they have concerns.  Staff are also encouraged to report any concerns or suspicions regarding the presence of modern slavery within the supply chain or within member operations.

 

Our Group HR Director, Recruitment Manager and HR Manager ensure right to work checks and processes are robust and audited to ensure compliance at all times.

 

In 2024 we are launching a new educational programme to all employees to support the compliance of our commitment.

 

Pall-Ex and Supply Chains’ responsibilities 

 

  • Will not use forced or compulsory labour, ie any work or service that a worker performs involuntarily, under threat of penalty;

  • Will ensure that the overall terms of employment are voluntary;

  • Will comply with the minimum age requirements prescribed by applicable laws;

  • Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements;

  • Will abide by applicable law concerning the maximum hours of daily labour;

  • Will not engage in any practice of slavery, servitude, forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK; and

  • Will ensure that any sub-contractors or suppliers also adhere to these requirements.

  • Certify compliance with this Policy and their adherence to relevant human trafficking and slavery laws in each of the relevant countries in which they operate.

 

Upon request, Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of Pall-Ex. Pall-Ex may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit.  We aim this year to conduct a full audit of our Suppliers and conduct a risk assessment.

 

Reporting

Any breach of this Policy (including by a Supplier) can be reported in confidence, by contacting the Group HR Director in confidence. 

 

A whistleblowing policy within the employee handbook ensures all employees know how to raise concerns about how colleagues are treated or regarding practices within our business or supply chain, without fear or reprisal. 

 

Violation & Consequences

Pall-Ex takes any breach of this Policy extremely seriously.

 

Suppliers who are found to be or have been engaging in human trafficking and slavery, or who refuse to co-operate with any audit to verify compliance with this Policy, will be liable to have any supply agreement, arrangement or other contract terminated immediately, without compensation.

 

If a Supplier to Pall-Ex is found in violation of this policy, Pall-Ex will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such other (remedial) steps as the Group Chief Executive Officer shall determine to be necessary to address the violation and seek to prevent its reoccurrence.

 

This Modern Slavery and Human Trafficking statement will be regularly updated as necessary.  There have been no reported Modern Slavery instances since the last statement.

 

This statement is reviewed annually.

 

The Pall-Ex Group endorses this statement and is fully committed to its implementation. 

 

This Modern Salary and Human Trafficking Statement has been approved and authorised by the Pall-Ex Group Board.

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