Hydratight Limited (“Company”) - Slavery and Human Trafficking Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 31st August 2017.
Modern slavery is a crime and a violation of human rights. It takes various forms, including slavery, servitude, compulsory labour and human trafficking for exploitation and can have a significant adverse impact on individuals, families and communities across the world.
The Company is a wholly owned subsidiary of Actuant Corporation, a listed company in the United States, and has three UK offices in Walsall, Morpeth and Aberdeen, as well as branch offices in Kazakhstan and Azerbaijan.
The Company is a global provider of flange joint integrity, flange management, onsite controlled bolting and machining services; training & competency assessment services for bolting personnel; and an innovative manufacturer of bolting tightening, portable machining and mechanical piping connection products.
The Company has approximately three hundred employees, with an annual turnover of over £36m.
The Company has a zero-tolerance approach to modern slavery, and has adopted a modern slavery policy (”Policy”). A copy of the Policy can be viewed by the following link.
The Company’s legal team and UK purchasing manager have overall responsibility for ensuring compliance with the Company’s legal and ethical obligations and that the Policy is implemented effectively.
As the Company operates from the UK there is a low risk of exposure to slavery and human trafficking.
The Company’s key area of risk lies in the relationships with non-UK supply chains - suppliers, contractors and business partners. However, the Company also recognise their responsibilities as an employer of staff.
The Company’s zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
The Company undertakes appropriate due diligence when considering taking on new suppliers, contractors and business partners, and regularly review our existing suppliers, contractors and business partners.
In addition, the Company has conducted due diligence in respect of its current supply chain and has identified suppliers in India, South Korea, Romania and Pakistan who have been subject to enhanced due diligence and who will be required to confirm in writing their compliance with the Modern Slavery Act 2015 and include relevant clauses in any contracts or agreements.
The Company sends to all of its suppliers its supplier’s guide which includes anti- slavery language and its general terms and conditions. All suppliers are required to agree in writing to the supplier’s guide.
A standard supplier contract clause has been drafted requiring compliance with the Modern Slavery Act 2015 and shall be included in the Company’s general terms and conditions of purchase. In higher risk cases this will include enhanced audit/termination rights to ensure more vigilant monitoring of high risk.
Serious breaches of the supplier guide will result in the termination of the business relationship.
The Company only uses reputable employment agencies and we will always verify the practices of any new agency before engaging staff from it.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in the Company’s supply chain and business, the Company shall provide training to relevant member of staff. All directors have been briefed on the subject.
The board of directors of the Company delegated approval of this statement on its behalf to Nicholas James Gemmell at its board meeting on 28 February 2017.
Nicholas James Gemmell
For and on behalf of