Modern Slavery Statement
(for the financial year ending 31 December 2019)
Ideal Boilers Limited ("we" "us" "the Company") are committed to improving our practices to combat slavery and human trafficking and to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that human trafficking and slavery is not taking place anywhere in our own business or in any of our supply chains.
This statement details the steps taken by the Company during the financial year ending 31 December 2019 to prevent slavery and human trafficking occurring in any of our businesses or supply chain.
In preparing the statement we have considered the obligations placed on us as a result of the Modern Slavery Act 2015 and the risks the business is exposed to as a result of operations of its business.
It is expected that all personnel responsible for the sourcing and specification of materials for use in our boilers act with Integrity to ensure that no action taken by the business is likely to adversely impact the human rights of people working in our supply chain wherever they may be and however far down the supply chain they may be.
Organisation's Structure and Our Supply Chains
We are a market leading supplier of domestic and commercial boilers primarily to the UK market. We are a part of the Groupe Atlantic (Group), which is the ultimate parent company. The Group has its head office in France. The Group has over 9,400 employees and has 28 manufacturing sites worldwide.
The Company’s sales market continues to be UK focused with the supply market being global. Our critical suppliers are predominantly located in China, India, Vietnam and continental Europe as well as the UK. The Company has not entered into any new markets in the USA and Australia since the last financial year 1 January 2017 to 31 December 2017. When assessing any suppliers within the supply chain as to whether or not they are high risk the Company continues to rely on:
- The work of the Global Slavery Index (http://www.globalslaveryindex.org/) which identifies countries where there is a higher risk of exploited labour.
- The type of component being specified and purchased either directly or indirectly.
- The use of intelligence from professional organisations such as CIPS.
Our Policies on Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We also operate under a number of policies which are available internally with key policies placed on the Company's website. No new policies have been introduced during the financial year ending 31 December 2018. However, the existing policies listed below are reviewed on a regular basis to ensure compliance with relevant law.
- Anti-slavery Policy: The policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place any where in out supply chains.
- Anti-bribery and Corruption Policy: The policy sets out clear guidance in respect of prevention of bribery and corruption by or involving our workers and includes information on our workers' obligations and potential liabilities.
- Whistleblowing Policy: It encourages workers to report any concerns about wrongdoing or dangers internally through the proper channels. The Company continues to promote individuals to speak and raise concerns internally and disclose information which the individual believes to illustrate illegal unethical behaviour or other serious malpractice, including any matters relating to modern slavery.
- CSR Policy – an overarching policy describing how the business meets or exceeds its obligations on matters relating to the environment, ethical trading.
- Procurement policies: The policies set out our terms and conditions for the purchase of goods and services. We will only use reputable suppliers who act ethically and in accordance with the Modern Slavery Act 2015.
Due Diligence Processes for Slavery and Human Trafficking
The Company continues to maintain internal accountability standards and procedures for employees and contractors for failing to meet company standards regarding modern slavery and human trafficking. The following approaches are used by the Company to identify and mitigate risk and no other action has been implemented during the financial year ending 31 December 2018:
- Supplier Self-Assessment: This process involves a questionnaire containing questions in relation to slavery and human trafficking issued to suppliers with significant business turnover and critical component suppliers which they are required to complete.
- Site Audits & Business Reviews: From time to time Ideal Boilers personnel will visit new or existing suppliers to assess their capabilities.
- Third Party Auditing: For those suppliers which have been identified as higher risk in Asia and other remote parts of the globe, we use the resources of the Group organisation. The Group’s Shenzen offices are able to provide a support service across Asia which includes supplier visits at the request of Ideal Boilers. Additionally, Ideal Boilers are able to use Group Purchasing resource based in France to visit potential and current suppliers and assess their suitability across a range of criteria including CSR parameters.
- Eligibility for Working in the UK: When recruiting new employees in to the business and when using the services of agency personnel, the HR function ensures that all agency personnel and new permanent recruits have been correctly vetted and that their eligibility for employment in the UK has been established.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.
The Company is constantly re-evaluating its processes to ensure there is no slavery or human trafficking in its supply chain. Over the coming year, the Company will endeavour to
- Encourage greater involvement in modern slavery initiative from teams across the Company.
- Ensure we participate at external modern slavery events and workshops (where possible).
- Review our internal training available to our employees.
- Explore any additional online tools which would assist us in the assessment of our supply Base in relation to CSR obligations.
- Provide feedback to suppliers and guide them in addressing any areas of concern.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2019.
Shaun Edwards, Chief Executive Officer, Ideal Boilers GA – UK Division 31 December 2019