Modern Slavery

Window Ware Limited Modern Slavery Act 2015 Policy Statement 2023

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Window Ware has a zero-tolerance approach to any form of modern slavery.  Integrity and mutual respect are cornerstones of our business values.  We are committed to acting ethically and transparently in all business dealings.  We are determined to have effective systems and controls in place to raise awareness of, and to safeguard against, any form of modern slavery taking place within Window Ware, to the best of our ability, and anywhere in our supply chain.

Our High Risk Areas

While we remain vigilant against potential issues within our own business, we have identified our supply chains as the area of most risk.  We recognise that exposure to modern slavery is likely to be more prevalent in low cost manufacturing regions and countries such as the Far East.  The majority of our own brand product supply comes from China.  There is a strong focus on trying to prevent modern slavery in any form, with regular communication with suppliers in addition to a structured programme of vendor audits and regular compliance testing.

Our Policies

We operate policies to ensure that we conduct business in an ethical and transparent manner. These include:

• Modern slavery policy. This policy and statement sets out our stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
• Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work checks for all employees which helps to safeguard against human trafficking or individuals being forced to work against their will.
• Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our businesses or supply chain, without fear of reprisals.
• Code of business conduct. This code explains the way we behave as an organisation and how we expect our employees and suppliers to act.

Our Suppliers

We operate a formal supplier management policy in the high risk territories described above, and as part of this, maintain an approved supplier list.  We conduct due diligence on all suppliers in these regions before allowing them to become an approved supplier.  This due diligence includes pre-approval audits and questionnaires, along with subsequent periodic on site audits which include a review of working conditions and cover health and safety and worker welfare generally as well as modern slavery in particular.

Over the last couple of years, a Statement of Expectations in Respect of Employment and Ethical Practices, Health & Safety, Environment and Quality, which incorporates sections on modern slavery and worker welfare.  To remain as an approved supplier needs to confirm that they are able to comply with the expectations for responsible and ethical behaviour from our suppliers.

In the first instance, we will work with our suppliers to help them address any concerns we might identify and will stop using suppliers should any instances of modern slavery come to light which are not rectified promptly.  We will not take on any new suppliers unless we have confidence in their ethical standards.

Training

We conduct appropriate training for our procurement/buying teams and senior managers, so that they understand the signs of modern slavery and what to do if they suspect that it is taking place.  A In December 2021 all UK employees in relevant roles, undertook training in the form of an online course and knowledge check to develop awareness and skills for spotting the signs of modern slavery.

Reporting

If an employee becomes aware of or suspects that there may be the possibility of any modern slavery abuses occurring within the business or its supply chain, this must be reported immediately to the employee’s line manager and/ or the Managing Director.  The claim will then be investigated immediately, and the findings reported to the Shareholders.  If the employee does not feel comfortable reporting the matter via this route or considers that it is not being investigated fully or dealt with appropriately, they can report the matter using the Window Ware Whistleblowing Policy procedures which are widely publicised internally.

Our Performance Indicators

We monitor the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain by reviewing at Senior Leadership level any reports that are received through supplier audits and from employees, the public, or law enforcement agencies indicating that modern slavery practices have been identified.

Approval of this Statement

This statement, which covers the Group’s financial year to 31 December 2022, was approved by the Directors of Window Ware Limited.  It will be reviewed annually and is pursuant to Section 54 of the Modern Slavery Act 2015.

Samantha Nuckey
Managing Director
01 January 2023