Modern Slavery Act Statement
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Britax Group Limited and other relevant companies controlled by its holding company, CC 1 (2011) Limited (the “Group”), to prevent modern slavery and human trafficking in its business and supply chain. This statement constitutes the Group’s slavery and human trafficking statement for the financial year ending 31 December 2017.
Slavery, servitude, forced labour and human trafficking (“Modern Slavery”) are global issues. We are committed to ensuring that there is no Modern Slavery in our supply chains or in any part of our business. We act ethically and with integrity in our business relationships and in developing, implementing and enforcing systems and controls to ensure Modern Slavery is not taking place anywhere in our supply chains.
Our business & supply chains
We are a global manufacturer and distributor of children’s car seats, strollers, bicycle seats, nursery products and related accessories. Our parent company is CC 1 (2011) Limited and has its head office in England. As at 31 December 2017, the Group had 1,826 employees worldwide and carried out manufacturing operations in the UK, USA, Germany, Australia and China with sales and marketing operations in North America, South America, Europe, Asia and Australia/New Zealand. The Group’s global annual turnover during the year to 31 December 2017 was approximately €388m. We are organised in regional business units (Americas, EMEA, Asia and Australia/New Zealand) and our supply chains include component suppliers and contract manufacturers.
Policies, Contractual Controls & Commitment
We are committed to ensuring that there is no Modern Slavery in our supply chains or in any part of our business.
We act ethically and with integrity in our business relationships and in implementing and enforcing systems and controls to ensure Modern Slavery is not taking place anywhere in our supply chain.
Under our global and regional codes of conduct we:
- respect and obey the laws, rules and regulations which apply to our
- businesses around the world; respect human rights and require our
- supply chain to do the same; compete ethically; and respect fair
- employment practices.
We also operate a whistleblowing policy which provides a framework within which individuals can openly or anonymously report any ethical concerns, including issues in connection with Modern Slavery. Any issues raised are thoroughly investigated and necessary actions are taken. The anonymity of whistle-blowers is protected.
Due diligence processes in relation to Modern Slavery
We operate a supply chain which includes suppliers we have worked with, visited and inspected over a number of years. We know that Modern Slavery can be most prevalent in the parts of a supply chain operating in certain high risk areas and among vulnerable groups. Therefore, before new suppliers are added, we carry out an approval and accreditation process. A key area of the formal audit before approving and adding any new supplier to our supply chains, involves an assessment of that supplier’s labour practices in relation to use of child labour, use of forced labour, payment of a minimum wage, employee working environments and protection against discrimination.
We have in place and/or are developing further systems to:
- identify and assess potential risk areas in our supply chains;
- mitigate the risk of Modern Slavery occurring in our supply chains; and
- monitor potential risk areas in our supply chains.
During 2016, we began to include more specific provisions in new or renewed contractual arrangements with key parts of our supply chains to address the prevention of Modern Slavery in our supply chains. This process continued during 2017.
Supplier adherence to our values & ethics
We have zero tolerance to Modern Slavery. As part of the steps taken to ensure all those in our supply chains and our contractors comply with our values and ethics we have in place a supply chain compliance programme. This consists of regular visits by our regional sourcing, quality and engineering teams, a periodic scorecard process and periodic visits by the Group’s general counsel.
Our effectiveness in combating Modern Slavery
In order to assess the effectiveness of our Modern Slavery measures we will be reviewing the following key performance indicators:
- staff training levels; and
- the number of slavery incidents reported in the supply chain.
Following a review of the effectiveness of the steps we have taken in the year ending 31 December 2017, we intend to take further steps during 2018 to improve our effectiveness in assessing and addressing issues and risks which are relevant to the prevention of Modern Slavery in our business and supply chains. These steps will include contractual provisions, visits and reviews of our audit documents and scorecards.
This statement has been approved by the board of directors of CC 1 (2011) Limited and Britax Group Limited and will be reviewed and updated annually.
Chief Executive Officer
Britax Group Limited
CC 1 (2011) Limited
30 June 2018