Anti Slavery and Human Trafficking Policy

Anti Slavery and Human Trafficking Policy

This statement is made in pursuant to s.54 of the Modern Slavery Act 2015 and set out the steps that Nassau Industrial Doors Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Nassau Industrial Doors Limited has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or supply chain.

Our Business

Nassau Industrial Doors Limited supply a wide range of industrial doors to all industries in the UK. The company is based in Stoke on Trent in the UK and is part of the ASSA ABLOY group. We offer a range of sustainable and innovative product solutions that complement our standard package of products and services. Our supply chains supply door assemblies and ancillary parts related to the provision of industrial doors.

Our Policies

We are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. We operate a number of internal policies that ensure that we are conducting business in an ethical and transparent manner. These include a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

Nassau Industrial Doors ensures that all employees and subcontract labour are paid above the local government minimum wage guidelines and ensure that all employees are treated fairly and awarded appropriately for their endeavours and not exploited in any way.

Our Suppliers

We are committed to ensuring that we and our suppliers act ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere within our supply chains. As part of our initiative to identify and mitigate risk we build long-standing relationships with local supplier and contractors and make clear our expectations of business behaviour. This involves operating a supplier policy and maintaining a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier which can include an online search to ensure that the particular organisation has never been convicted of offences relating to modern slavery and on site audits to review working conditions. Our Anti-Slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

  1. They have taken steps to eradicate modern slavery within their business
  2. They hold their own suppliers to account over modern slavery
  3. For suppliers based in the UK, they pay their employees at least the national minimum wage.
  4. For international suppliers, they pay their employees any prevailing minimum wage application within their country of operations.
  5. We may terminate the contract at any time should any instance of modern slavery come to light.

Training

We conduct training so that employees understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our Performance Indicators

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chain:

  • Completion of premises audits by competent managers
  • Use of labour monitoring and payroll systems to check eligibility of employees in the UK.
  • Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.

Responsibility for the policy

The Nassau Industrial Doors Limited Management team has overall responsibility for ensuring this policy complies with Nassau’s legal and ethical obligations and for all those under our control comply with it. The Nassau Industrial Doors Limited General Manager has primary responsibility for implementing this policy and is supported in doing this by the ASSA ABLOY Entrance Systems Ltd Management Team. This includes responsibility for the monitoring of its use and effectiveness, auditing of internal control systems and procedures. The ASSA ABLOY Entrance Systems HR Country Manager is responsible for updating the policy to reflect any changes in legislation.

Management at all levels of Nassau Industrial Doors Limited are responsible for ensuring those reporting to them understand and comply with this policy, and, where appropriate, are given adequate and regular training on Modern Slavery.

Nassau Industrial Doors Limited employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to your manager or the HR Department.

Compliance with the Policy

All employees, contractors and suppliers must ensure that they read, understand and comply with this policy. All Nassau Industrial Doors Limited employees are responsible for the prevention, detection and reporting of Modern Slavery in any part of our business or supply chain. Employees are required to avoid any activity that might lead to a breach of this policy, and the Modern Slavery Act 2015. You must notify your manager as soon as possible if you believe or suspect that, a conflict with, a breach of, this policy has occurred, or may occur, in the future.

You can also report any suspected breach by following the Whistleblowing Policy. Employees are encouraged to raise concerns about suspicions of Modern Slavery in any parts of our business or supply chains at the earliest possible stage. If you are unsure whether a particular act, the treatment of worker more generally, or their working conditions within any tier of our supply chains constitutes any, or all of, the various forms of Modern Slavery please advise your manager or the HR Department.

Communication and awareness of this policy

This policy is available on the Nassau Industrial Doors Limited Website. Modern Slavery awareness forms part of the induction process for employees. Refresher training will also be provided as necessary. Our zero-tolerance approach to Modern Slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them. Suppliers are asked to comply with our Anti-Slavery and Human Trafficking policy from the onset of the relationship. Suppliers who are unwilling to comply will not be on-boarded.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action. This could result in action up to dismissal in accordance with the Nassau Industrial Doors Limited Disciplinary Policy. We may terminate our relationship with other employees, suppliers, and any other associates working with Nassau Industrial Doors Limited if they breach this policy.

Approval for this Statement

This statement was approved by the General Manager in January 2021

Name:           Shaun Smith

Date:             January 2021

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