2M Holdings Ltd: Modern Slavery Policy Statement – October 201609-Dec-2016
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking.
The 2M Group has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships. 2M Group companies are implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.
2M expects the same high standards from all of its staff, suppliers, contractors and other business partners and expects that their suppliers will in turn apply the same standards along their supply chains.
Action Taken/To be Taken
As a group purchasing speciality chemical products from a number of countries around the world, transparency from the manufacturers of these products and subsequent supply chains is vital in our fight against Modern Slavery. It is within these supply chains that there may be a risk of slavery and human trafficking.
2M accepts that it has a responsibility through its own due diligence processes to ensure that employees are not being exploited, are not subjected to poor labour practices, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
As part of our initiative to identify and mitigate risk the 2M Group is currently undertaking a review of its procedures to ensure there is no slavery or trafficking in its supply chain and its own business and will ensure that it has in place, employment contracts which make specific reference to the prohibition of Modern Slavery , appropriate and relevant company policies including a Health and Safety and Social Accountability Policy and guidelines to demonstrate its commitment to safe, lawful and ethical standards with its own employees.
2M will ensure that questionnaires are sent to supply chains to ascertain what ethical trading practices are in place. This is to be further developed to include a statement specifically requesting a commitment to anti-slavery and human trafficking.
Where a 2M Group company uses a 3rd party employment agency for overseas employees, they shall ensure employment is not subject to modern slavery and all health and safety and human rights laws and standards are being adhered to.
As we are committed to ensuring the group’s compliance with the Modern Slavery Act 2015 the effect of our procedures will be monitored by way of audit where it is warranted.
Responsibility for the Policy
The 2M Group Compliance Director, David Dalton, will have overall responsibility for ensuring that this policy complies with the Group’s legal and ethical obligations.
Purchasing Departments are responsible for monitoring supply chain compliance with ethical, anti-slavery and human trafficking policies. The Purchasing Director and company senior management are responsible for investigating allegations of modern slavery within the Company’s supply chain.
Training and communication
As part of 2M’s commitment to ensure compliance with their obligations under the Modern Slavery Act 2015 the 2M Modern Slavery Policy will be circulated to all staff. Training will also be conducted so that staff are aware of how to identify exploitation and modern slavery and how to report suspected cases.
2M’s zero tolerance approach to modern slavery will also be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for the current financial year.