Modern Slavery Act 2015 – Slavery & Human Trafficking Statement
Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.
FlushKING has a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2021.
Our business and supply chains
FlushKING establishes a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.
We have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.
Our business and supply chains
In the past year, we conducted a risk assessment of our supply chain by considering:
- The risk profile of individual countries based on the Global Slavery Index
- The business services rendered by the suppliers
- The presence of vulnerable demographic groups
- A news analysis and the insights of labour and human rights groups
This assessment will determine our response and the risk controls that we implement.
FlushKING operates the following policies for identifying and preventing slavery and human trafficking in our operations:
- Whistleblowing Policy - we encourage all employees, customers, and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.
- Code of Conduct - our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
- Purchasing Code - we have updated our Purchasing Code and supplier contracts to make explicit reference to slavery and human trafficking.
Supplier due diligence
We conduct due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:
- Assessing risks in the provision of services
- Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
- Requiring improvements to substandard employment practices
- Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to attest that:
- They do not use any form of forced compulsory or slave labour
- Their employees work voluntarily and are entitled to leave work
- They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
- They do not require employees to post a deposit/bond and do not withhold their salaries for any reasons
- They do not require employees to surrender their passports or work permits as a condition of employment
Supplier Code of Conduct
FlushKING has issued suppliers our Supplier Code of Conduct. This Code formalises our company practices and makes clear that, recognising differences in cultures and legal requirements, we expect that wherever our suppliers are located, producing products for us, or delivering services for us, that they are produced and/or provided in a manner compatible with the high standards that contribute to the reputation of our company.
Suppliers are required to comply with this Code and to have and maintain practices like those in our company. We are committed to helping its suppliers comply with these standards. In turn, we expect its suppliers to apply these standards to the suppliers they work with in providing goods and services to the company. We strongly encourage suppliers to exceed the requirements of this Code and promote best practices and continuous improvement throughout their operations.
Awareness & Training
We have raised awareness of modern slavery issues by putting up posters across our facilities and sending an email that is focused specifically on modern slavery to all our colleagues, which explains:
- Our commitment in the fight against modern slavery
- Red flags for potential cases of slavery or human trafficking
- How employees should report suspicions of modern slavery