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 it (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 2019.
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 as at 31 December 2019 was CC 1 (2011) Limited, with its head office in England. Our parent company arrangements changed with effect from 9 January 2020, leaving Persimmon Midco LLC, registered in Delaware USA, with its head office in South Carolina, USA, (a former intermediate holding company) as our parent company. As at 31 December 2019, the Group had approximately 1,172 employees worldwide and carried out manufacturing operations in the UK, USA and Germany with sales and marketing operations in North America, South America, Europe, Asia, Australia and New Zealand. The Group’s global annual turnover during the year to 31 December 2019 was (subject to audit) approximately €315m. We are organised in regional business units (Americas, EMEA and Asia-Pacific) 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. With reference to this policy:
- any Modern Slavery issues raised would be investigated at a senior level and brought to the attention of the board of directors;
- the anonymity of whistle-blowers is protected; and
- there have not been any Modern Slavery related issues raised during the financial year ending 31 December 2019.
We continue to review our contractual arrangements and develop strategic business relationships with suppliers in key parts of our supply chains to help ensure that necessary standards are in place, and maintained, to prevent Modern Slavery in our supply chains.
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. These lasting business relationships with suppliers help to ensure a commitment to our values, standards and the way we work.
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.
We 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.
Supplier adherence to our values & ethics
We have a zero tolerance approach to Modern Slavery and expect those in our supply chains and our contractors to comply with our values and ethics. This is reinforced by contractual controls and periodic supplier visits or assessments by sourcing, quality or engineering teams and 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 supplier visits and assessments;
- the development of lasting strategic business relationships in high risk geographic areas;
- 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 2020. As part of our review in relation to the financial year ending 31 December 2019, we will be revamping our supply chain compliance and staff training programmes.
This statement has been approved by the board of directors of Britax Group Limited and will be reviewed and updated annually.
30 June 2020
Britax Group Limited