Modern Day Slavery
Director’s Statement – Modern Slavery Act 2015 (the ‘MSA Act’)
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Lincat’s slavery and human trafficking statement for the financial year ending December 2019.
Introduction
This statement sets out Lincat’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st January 2023 and December 2023
The Senior Management team at Lincat recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Lincat is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational Structure and Supply Chains
This statement covers the activities of Lincat Ltd.
We operate a close working relationship with our suppliers with regular communication and business visits where necessary.
Within our business, all those buying in goods or services have a responsibility to consider modern slavery and ethical trading practices.
Risk Assessment Process
The following is the process by which Lincat assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
Contracts with direct and indirect suppliers will include clauses on the Modern Slavery Act and risk factors. Zero tolerance for modern slavery and respect for human rights will be built into our procurement processes, supplier contracts and also represented in dialogue with sub-contractors, customers and other business partners.
Relevant Policies
Whistleblowing Policy – Lincat encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Lincat. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Whistleblowing Procedure is designed to make it easy for workers to make disclosures, without fear of retribution.
Anti-Bribery - It is the policy of the Company to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
Employee Code of Conduct – Lincat’s code makes clear to employees that their actions and behaviour expected of them when representing the company. The Company strives to maintain he highest standards of employee conduct and ethical behaviour when operating internally and within its supply chain.
Recruitment / Agency workers’ Policy
Lincat uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
Going forward over the course of the next 12 months Lincat will monitor the relationship with all agencies in accordance with the provisions of the Modern Slavery Act.
Due diligence
Lincat undertakes due diligence when considering taking on new indirect suppliers, and regularly reviews its existing indirect suppliers.
This process includes;
- Evaluating the modern slavery and human trafficking risks of each new indirect supplier by requesting they complete a Modern Slavery Act due diligence questionnaire via Lincat supply chain procurement platform.
- Create a risk profile for each indirect supplier, where appropriate, based on the response within the Modern Slavery Act due diligence questionnaire;
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan, including the termination of the business relationship;
- Insertion of a Modern Slavery Act clause in our supplier contracts. Contracts with suppliers will include clauses on the Act and risk factors. Zero tolerance for modern slavery and respect for human rights will be built into supplier contracts and also represented in dialogue with sub-contractors, customers and other business partners.
Training
Lincat commits to ensuring that individuals employed in the Supply Chain team will undergo training on Modern Slavery. All people involved with Supply Chain and Human Resources have undertaken training in this area. Anyone new coming into the business in Supply Chain or Human Resources roles will undergo this training.
Board Approval
This statement has been approved by Lincat’s board of directors, who will review and update it annually.
Mr. J. White
Managing Director, Lincat Ltd
Date: January 2023 (next review January 2024)