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Romold Arrow

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 adopted a zero-tolerance attitude to slavery or human trafficking, and we expect all our supplier’s and contractors to support and abide by this value. We have never been involved in any form of slavery and human trafficking and to the best of our knowledge no supplier we use has been involved in slavery and human trafficking. Where we find evidence that a supplier is involved in and such act, we will immediately cease trading with them and file a report with the appropriate government agency.

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 ensures there is no 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
  • Uses 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.
  • Carrying out comprehensive system 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.
  • Auditing and visiting supplier’s and contractors to ensure their understanding and compliance with our commitment to prevent slavery or human trafficking.

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: Jim McLeary

On behalf of the board of directors

End of Last Financial Year 31stOctober 2018

Approved by the Board 8th March 2019

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