CC 1 GROUP & BRITAX GROUP
Modern Slavery Act Statement
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken Britax Group Limited, its holding company CC 1 (2011) Limited and other relevant companies controlled by them (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 2018.
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 2018, the Group had 1,784 employees worldwide and carried out manufacturing operations in the UK, USA, Germany 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 2018 was (subject to audit) approximately €348m. We are organised in regional business units (Americas, EMEA, Asia and Australia/New Zealand) and our supply chains include raw materials 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 handled at a senior level, brought to the attention of the board of directors and thoroughly investigated. Any 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 geographic 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 child or 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.
We continue to review contractual arrangements and form strategic business relationships with key parts of our supply chains to help ensure that necessary standards are in place to prevent Modern Slavery in our supply chains.
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 continue to operate a supply chain compliance programme. This includes visits by 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 review the following key performance indicators:
- the results of our supply chain compliance programme;
- the number of Modern Slavery allegations reported or uncovered in the supply chain; and
- staff training levels.
We periodically review the effectiveness of existing steps we have taken with a view to maintaining and further improving our effectiveness in assessing and addressing issues and risks which are relevant to the prevention of Modern Slavery in our business and supply chains. This review process will continue during 2019 as key supplier contracts become due for renewal and long term strategic supply chain relationships are developed.
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.
30 June 2019
CC 1 (2011) Limited
Chief Executive Officer
Britax Group Limited