Slavery and Human Trafficking Policy

Introduction:

Modern day slavery and human trafficking is a complex problem. The Modern Slavery Act integrates human rights and transparency within our global supply chains into the UK corporate regulatory framework. We have a responsibility to be alert to the risks in our business and wider supply chain.

Our Policies:

We operate under a code of conduct and associated polices that govern the integrity of our business relationships, and that recognise the values we set for of ethical trading and responsible sourcing, as well as commitments made under other aspects of our approach to corporate and social responsibility. Our colleagues are expected to adhere to these policies and report any concerns to our management who will act upon them.

Our Organisation and Business Structure:

The Darcy Spillcare Manufacture has its factory and head office in UK and is recognized as a leading provider of practical pollution control products and services.

Our Supply chains:

Our supply chains include the sourcing of raw materials and use of contractors for the activities of manufacturing, installation and service of spill response equipment.

Due Diligence Processes:

We adopt effective systems and controls to identify and mitigate risk, and to ensure that slavery and human trafficking is not taking place within our own direct employment and supply chains.

We seek to build long standing relationships with both local and international suppliers. We make clear our expectations of business behaviour and require all suppliers to recognise the standards laid out in our ethical trading, health, safety environmental and responsible sourcing policies.

We have systems in place to encourage the reporting of concerns and the protection of Whistle blowers.

It is not practical for us to have a direct relationship with all suppliers within the supply chain. We expect every entity to adopt a minimum protocol of ‘one up’ due diligence within the next link of the supply chain.

We periodically visit and audit our principal suppliers to ensure that slavery and human trafficking is not taking place within any part of our business.

Supplier and Contractor adherence to our values:

We have zero tolerance to slavery and human trafficking.

We expect all those in our supply chain and contractors to uphold our values.

The directors of each of our business units are responsible for managing their supplier relations and compliance requirements.

Training:

All Directors have been briefed on the requirements of the Modern Slavery Act. We have provided training to relevant members of our staff to ensure a high level understanding of the risks of modern slavery and human trafficking in our supply chains.

Our effectiveness in combating slavery and human trafficking:

We encourage communication and personal contact with suppliers to ensure their understanding of and compliance with our expectations

We undertake periodic surveys and audits of our suppliers

We review and audit our working time and payroll records

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015

Dated: February 2020

Richard Proctor

Managing Director