ANTI-MODERN SLAVERY STATEMENT
Introduction
This Anti-Modern Slavery Statement explains how we comply with our obligations to act lawfully, including compliance with our obligations under the Modern Slavery Act 2015.
Our Statement on Modern Slavery
We are fully dedicated to eradicating slavery and human trafficking from all aspects of our corporate operations, as well as ensuring that our supply chains remain free from such practices. As a participant in the UK public and other sectors, we acknowledge our responsibility to engage in ethical business activities, which include upholding a supply chain that is entirely free from slavery.
This statement serves to reaffirm our unwavering stance of zero tolerance towards modern slavery. It outlines our commitment to proactively identify and address any potential risks of modern slavery associated with our business operations, as well as the measures we have implemented to prevent such practices from occurring.
Relevant Policies:
Employee Code of Conduct: Our code of conduct highlights to employees the actions and behaviour expected of them whilst representing our company. When operating and managing our supply chain, we endeavour to uphold the highest standards of employee conduct and ethical behaviour.
Whistleblowing policy: In line with our whistleblowing policy, we encourage all our employees, customers, and other business partners to report any concerns to our Senior Management. This includes any circumstances that may give rise to an enhanced risk of human trafficking or slavery. Our whistleblowing procedure allows employees, customers, or others to raise any concerns without fear of retaliation.
Due diligence investigations
We recognise that Ottomater has due diligence to carry out investigations on new suppliers and review its existing suppliers. Our due diligence report encompasses the following key elements:
- Identification of Risks: Our due diligence process involves an assessment of the risks related to modern slavery and human trafficking for products, services and geographical areas. This assessment applies to all new suppliers. In cases where high-risk suppliers are identified, they are promptly flagged for further attention and action.
- Ongoing Risk Assessment: We conduct an annual evaluation of the risks associated with modern slavery and human trafficking for all current suppliers. This assessment ensures that we remain vigilant in monitoring and addressing any evolving risks within our supply chain.
- Supplier Assessments: As part of our commitment to upholding human rights, particularly concerning slavery and human trafficking, we conduct thorough supplier assessments. These assessments specifically focus on the identification and mitigation of risks associated with these issues, based on general risk factors.
- Sanctions for Ethical Improvements: In cases where suppliers fail to demonstrate satisfactory ethical standards regarding slavery and human trafficking, appropriate sanctions are invoked. These sanctions are designed to encourage and enforce the improvement of ethical standards within our supply chain. Through these measures, we aim to proactively address the risks of modern slavery and human trafficking, promote responsible sourcing, and hold suppliers accountable for maintaining high ethical standards.
Training
To help maintain a supply chain free from modern slavery, we require our staff to complete in-house training on modern slavery. Our training covers:
- The Modern Slavery Act 2015
- How to assess the risk of slavery and human trafficking about our suppliers, and business
- How to identify the signs of slavery and human trafficking
- How to report any suspected slavery or human trafficking
- The steps our organisation should take if suppliers do not implement anti-slavery policies within high-risk scenarios. This includes removing them from the Ottomater supply chain
Approved: Marcel Horst, Managing Director
Publication date: 1 May 2024
Date of next review: 1 May 2025