Modern Slavery & Human Trafficking Policy
Garland Group
Introduction
The Garland Company UK Limited (“Garland UK”) and its corporate group (including its parent company Garland Industries Inc.) (“Garland Group”) are committed to keeping the business and supply chain of the group free from modern-day slavery and human trafficking. The Garland Group are committed to taking the necessary steps to ensure transparency within the organisation and within its chain of suppliers of goods and services to the organisation.
Audit Processes & Risk Assessment
As part of the Garland Group’s due diligence processes into slavery and human trafficking, the supplier approval process will incorporate a review of the controls undertaken by the supplier.
Goods, services and human resources from sources from outside of the UK, USA and the European Union entail a potentially greater risk of slavery/human trafficking issues. The level of management control required for these sources will be continually monitored, identifying in particular links to any of those countries and regions where the Global Slavery Index (GSI) has found there to be a higher level of risk.
The Garland Group will not support or deal with any business where it is aware that business is knowingly involved in slavery or human trafficking. It must be willing to terminate its relationship with any business which it is aware has links to reported modern slavery and human trafficking practices (although we may, where appropriate, wish to give the supplier the opportunity to put right the problem in the first instance).
The Garland Group will conduct a risk assessment of modern slavery and human trafficking issues and set out to audit suppliers as appropriate and in a manner consistent with that assessment in order to ensure that these organisations are not exposed to any form of modern slavery or human trafficking. Our values and requirements must be communicated to all new and ongoing suppliers, contractors and business partners.
At the outset of our business relationship with suppliers, the Garland Group wishes to clarify with them our expectations from them as trading partners and reinforce this over time as appropriate. To that end, we must reinforce to suppliers that we will not tolerate any use of labour that has not been freely chosen by the workers concerned.
Implementing this Policy
As of November 2020, the disclosure obligation under Section 54 of the Modern Slavery Act 2015 applies to Garland Industries Inc. Garland Company UK Limited is not subject to the disclosure requirement but its presence in the UK market triggers the disclosure requirement for Garland Industries Inc.
In practice, all of Garland Industries’ UK-facing activities are conducted through Garland UK. It is therefore appropriate for Garland UK to lead in taking the appropriate steps to ensure compliance with the Modern Slavery Act 2015 as well as good practice with regard to mitigating the risk of exposure to modern slavery or human trafficking.
These steps may include providing personnel training, guides and readily accessible information in the form of posters and online materials etc. as well as investment to ensure that slavery and human trafficking is not taking place within the organisation or within its supply chains.
The Role of Garland UK Employees
The Garland Group have set out this policy with a view to providing guidance on the expectations from all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
Employees must ensure that they read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Employees outside the UK should notify Jan Manning or Brooke Bautista of the Garland Group legal team.
UK employees must notify Managing Director Tim Jones, or Operations Manager Nikki Burton, or make a report in accordance with our Whistle Blowing Policy as soon as possible if they believe or suspect that a breach of this policy has occurred, or may occur in the future.
Employees are encouraged to raise concerns about any issue or suspicion of modern slavery or human trafficking practices in any part of our business or supply chains of any supplier tier at the earliest possible stage.
If an employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitute any of the various forms of modern slavery, he or she must raise their concern with Mr Jones or the Garland UK Operations Department.
A full copy of this policy and a copy of the Modern Slavery Act 2015 will be accessible to all employees electronically and can be obtained from the Operations department upon request. As mentioned above, employees will be expected to comply with this policy.
Reporting & Review
The Garland Group aims to encourage openness and will support anyone within the organisation who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery or human trafficking in whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. Any of our employees who believe they have suffered any such treatment should immediately inform the Operations Department or make a report in accordance with our whistleblowing policy. If the matter is not remedied the employee should raise it formally using our Grievance Policy.
Formal procedures concerning slavery and human trafficking, including a whistle-blowing hotline for reporting suspected malpractices, have been established or will be established in the 2021 financial year, including disciplinary procedures where they are breached. Additional procedures ensure that this policy is understood and communicated to all levels of the company and that it is regularly reviewed by the Directors to ensure its continuing suitability and relevance to the company activities.
