Modern Slavery & Human Trafficking Statement

This statement sets out the steps that Warm Glass UK has taken to ensure that modern slavery and human trafficking is not occurring in our organisation or in our supply chains.

Organisational Structure and Activities

Warm Glass UK is based at a head office in Wrington, North Somerset. All employees work at the main site. The organisation is managed by an experienced management team who are regularly on site managing primarily permanent employees working similar hours each week in accordance with their employment contract.

Definitions

Modern Slavery is a term which encompasses slavery, servitude and forced or compulsory labour. The organisation considers that modern slavery encompasses:

• Human trafficking
• Forced work, through mental or physical threat
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• Being dehumanised, treated as a commodity or being bought or sold as property
• Being physically constrained or to have restriction placed on freedom of movement.

Human trafficking is defined as arranging or facilitating the travel of another person with a view to that person being exploited.

Commitments

Warm Glass UK acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. We understand that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Warm Glass UK does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Warm Glass UK is obtained by means of slavery or human trafficking.

Warm Glass UK strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and in many cases exceeds those minimums in relation to its employees, workers and contractors.

Labour is usually employed directly by the organisation at its aforementioned offices or provided on a self-employed basis. The Company operates solely from the UK.

Supply Chains

The supply chain of Warm Glass UK includes various providers who supply raw materials ready for redistribution and manufacture. All products are sourced directly by ourselves. Materials are purchased from a variety of suppliers and we follow strict procurement processes to ensure ethical standards are met in accordance with this policy.

Where possible, we build long-standing relationships with suppliers and make clear our expectations of business behaviour. We will assess any instances of non-compliance on a case-by-case basis and will then tailor remedial action appropriately. We will only trade with those who fully comply with this policy or those who are taking verifiable steps towards compliance. Where our first-tier suppliers are intermediary traders we ask that they ensure lower-tier suppliers are compliant with this policy.

Potential Exposure

The Company has considered where/whether there is a risk in the organisation, or its supply chain, of slavery and human trafficking taking place. In general, the Organisation considers its exposure to slavery/human trafficking to be low.

Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it as noted below:

• Warm Glass Ltd is committed to employing directly and not via third party agencies to ensure there is visibility of the employment relationship, and no risk of inadvertently acquiring persons from a third party which engaged in slavery or Human Trafficking.
• In rare instances where there is a business need to recruit via a third party (i.e. from a recruitment or temporary agency) only reputably service providers are engaged and our expectations in relation to this policy are communicated to them.
• Employees are paid directly to their individual bank accounts, and no identification or travel documents are held by the Company.
• All members of the supply chain are asked to produce a modern Slavery and Human Trafficking Statement to ensure there is a shared and joined up approach to avoiding acts of trafficking or slavery.
• Working practices of suppliers will be audited from time to time to include the commitments made in the supplier’s modern Slavery and Human Trafficking Statement.
• We do not source from high-risk countries where modern forms of slavery are prevalent.

Steps

Warm Glass UK carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

We have not, to our knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
 In accordance with section 54(4) of the Modern Slavery Act 2015, we have taken the following steps to ensure that modern slavery is not taking place:

• Reviewed its supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
• Put measures in place to identify and assess the potential risks in its supply chains
• Undertaken impact assessments of its services upon potential instances of slavery
• Created an action plans to address risk to modern slavery
• Taken steps to embed a zero-tolerance policy towards modern slavery
• Provided training to relevant parties on modern slavery
• Sought evidence from our suppliers of the steps they have taken to ensure modern slavery has not taken place.

Approval

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and will be reviewed for each financial year.

This statement has been approved by the Company’s Directors and Ellie Moss has been appointed as the Director with overall responsibility for compliance with the Modern Slavery Act 2015.