Modern Slavery Statement 2018
FORGEFIX MODERN SLAVERY STATEMENT 2018
This Statement is produced in accordance with the Modern Slavery Act 2015.
Forgefix Limited is a member of a group of companies the ultimate holding company of which is Dormole Limited. There is attached a copy of the Dormole Limited Modern Slavery Statement 2017 (the “Dormole Group Statement”). In relation to its own employees and suppliers, Forgefix Limited complies with the points made in the Dormole Group Statement and has the same policies as contained in the Policy document attached to the Dormole Group Statement.
This Statement has been approved by the Board of Forgefix Limited.
DORMOLE MODERN SLAVERY STATEMENT 2018
Dormole Limited is the holding company of a number of companies which together with Dormole Limited are referred to in this statement as the “Dormole Group”. This statement is produced in accordance with the Modern Slavery Act 2015.
The companies within the Dormole Group act as distributors of hand tools, power tools and other related products. Our customers are trade merchants, including, but not limited to, DIY stores, engineering merchants, builders merchants, electrical merchants, plumbing merchants, garden centres and internet retailers. The products we supply to our customers are sourced from manufacturers and other suppliers in several different countries throughout the world.
We are aware that there may be some businesses around the world which have employees subjected to slavery or victims of human trafficking. Such practices are totally unacceptable to us both within our own business and also within the businesses of those with whom we deal.
The Dormole Group has a documented Ethical and Code of Standards Policy. A copy is set out later in this statement. The Policy makes clear our intolerance of slavery and human trafficking. In addition it includes our requirements in relation to other social, ethical and environmental matters. We take our Policy very seriously and take measures to ensure compliance with it, including:-
We ensure that all our suppliers are aware of the Policy and that they are required to comply with it.
In the last year we have surveyed all of our branded suppliers of which over 90% confirmed in writing their compliance with Ethical and Code of Standards Policy of the Dormole Group, as written. The remainder provided alternative assurances to the same effect.
Our exclusive ranges are sourced from factories in the EU and around the world. All of our current suppliers have been required to provide the same written confirmation that they meet the required policy standards. Factories in higher risk areas such as China and India are being audited by our sourcing team on a cyclical basis.
Confirmation of policy compliance now forms part of our supplier manual and is a pre-condition of all new supply arrangements.
Copies of the Policy are supplied to our senior and middle management and are also posted in conspicuous places in all of our business premises. Further reminders will be issued when appropriate.
All of our employees are instructed to read the Policy and are requested to raise any questions if there is anything they do not understand. They are also instructed that the principles and requirements contained in the Policy apply not only to our suppliers but also to our own business.
We have further publicised the Modern Slavery Act and our determination to comply with its objectives in our newsletter which is intended for distribution to all members of staff.
We have a whistle-blowing policy in order to encourage our employees to report any evidence or suspicions of violations of any human rights such as (but not limited to) slavery or human trafficking.
We have a dedicated Compliance Officer whose role is to respond to enquiries and concerns, to monitor the audit reports referred to in the Policy and to take appropriate follow up action. We have not had any concerns reported or brought to our attention since the last statement.
Our suppliers and our employees are encouraged to call the Modern Slavery helpline (0800 0121 700) if they have any concerns.
This Statement and the attached Policy have been approved by the Board of Dormole Limited.
A.J. T. Strong
Director and Chairman
Ethical and Code of Standards Policy of the Dormole Group
The Dormole Group is committed to ensuring that the suppliers in all countries from whom it buys goods treat their employees fairly and provide them with safe working conditions at all times, and that none of such employees is subject to slavery nor has been subject to human trafficking.
We are also keen to ensure that our suppliers are committed to minimising their impact on the global and local environment during the manufacturing process.
The Dormole Group will seek to ensure that our suppliers meet their social, ethical and environmental responsibilities in all respects. We also need to be satisfied that our suppliers have taken reasonable measures to ensure that those further down the supply chain also meet such responsibilities. Our particular requirements are:
Slavery and Human Trafficking – No employee shall be subject to slavery or have been the victim of human trafficking. Guidance issued by the U.K. Government explains what is meant by the terms “slavery” and “human trafficking” as follows:-
“Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/ she did own the person, which deprives the victim of their freedom.”
“An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation.”
Child Labour – All suppliers must hold accurate records of the ages and working hours of all employees who in all cases must not be less than the legal minimum age as required under the relevant national Law.
Hours of Work – All suppliers must hold accurate records of the working hours of all employees and such hours must not exceed the legal maximum. All employees must receive a reasonably acceptable number of breaks, days off and holidays.
Wages – All wages must meet or exceed legal minimum levels and any deductions must be reasonable, agreed and understood by the employees.
Employment – There must be no discrimination in the hiring of employees, who should all be provided with a written contract of employment and disciplinary rules in a language they can understand.
Abuse of Employees – There must be no physical or verbal abuse of employees.
Health and Safety and Hygiene – All suppliers must employ a Health and Safety Manager who is empowered to deliver a safe working environment, where all risks of injury through exposure to fire or flood, materials, power, equipment, machinery or hazardous activities has been assessed and minimised. All working conditions should be clean, hygienic and meet all legal standards and all employees should have ready access to clean drinking water at all times.
Environment – It is important that all suppliers are committed to reducing the impact of the production of their products on the environment. Where they are producing goods which incorporate raw materials in short supply (e.g. wood) it is important that they meet all required standards of care and can produce all necessary certification, if appropriate.
We or our agents will carry out Ethical and Environmental audits of all major supply partners to ensure compliance with the necessary standards. The Dormole Group will always seek to work with suppliers, who are committed to meeting the standards as set out in this Policy.
It is important to the Dormole Group that all its suppliers make themselves aware of our Ethical and Code of Standards Policy and ensure that they and those further down the supply chain comply with it at all times.
We shall take appropriate action in the case of any supplier who fails to comply or co-operate fully. Such action will almost inevitably include our ceasing to trade with the supplier.
The Company Secretary of Dormole Limited acts as the Dormole Group Ethical and Code of Standards Compliance Officer and all enquiries or concerns relating to this Policy should be addressed to him.