Modern Slavery Statement
Financial year ending March 2019
This statement sets out the actions CMS Enviro System Ltd. (the Company) has taken to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2018 to 31 March 2019.
The Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Company structure and supply chains
CMS Enviro Systems Ltd. is an industry leading building envelope contractor specialising in the design, manufacture and installation of PVCu and aluminium windows, doors and curtain walling systems. We have over 300 employees and operate throughout the United Kingdom. Our Head Office is located in Castlecary, Cumbernauld. We have regional sites in Kirkcaldy and East Kilbride.
To find out more about the nature of our business, please visit our website at www.cmswindows.com.
Our supply chains include the following:
- Recruitment/labour agencies;
- Suppliers of goods, services and materials
The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing Policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Supplier code of conduct: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the Company's supplier code of conduct will lead to the termination of the business relationship.
- Recruitment/Agency Workers: The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
- Anti-Bribery & Corruption Policy: The Company is committed to preventing and prohibiting bribery and corruption in all areas of the Company, including our supply chain.
- Equal Opportunities Policy: The Company is committed to equal opportunities and the avoidance of discrimination in all our working practices.
- Working Time Guidelines: The Company ensures our workers are not subjected to excessive working hours, overtime/night shift working is optional and encourages work/life balance.
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company's due diligence and reviews include:
- mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
- evaluating the modern slavery and human trafficking risks of each new supplier;
- conducting supplier audits, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
- participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular participation in "Stronger together" or "Ethical trading" initiatives;
- using an ethical supplier database, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
- invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
CMS Enviro Systems Ltd. has reviewed its key performance indicators (KPIs). As a result, the Company is:
- requiring supply chain employees and HR professionals to have completed training on modern slavery by March 2020.
- developing a system for supply chain verification, expected to be in place by March 2020, whereby the Company evaluates potential suppliers before they enter the supply chain; and
- reviewing its existing supply chains, expected to be completed by March 2020, whereby the Company evaluates all existing suppliers.
The Company's modern slavery training will cover:
- our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- how to identify the signs of slavery and human trafficking;
- what initial steps should be taken if slavery or human trafficking is suspected;
- how to escalate potential slavery or human trafficking issues to the relevant parties within the Company;
- what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;
- what steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chains.
As well as training staff, the Company will raise awareness of modern slavery issues by putting up posters across the Company's premises and circulating of emails to staff.
The posters and emails will explain to staff:
- the basic principles of the Modern Slavery Act 2015;
- how employers can identify and prevent slavery and human trafficking;
- what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Company; and
- what external help is available, for example through the Modern Slavery Helpline.
This statement was approved on 19 April 2019 by CMS Enviro Systems Ltd.’s board of directors who review and update it annually.
Signed: Date: 19 April 2019