Modern Slavery Act 2015 Policy Statement – Financial Year ending 31st December 2020
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Knauf Insulation Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Knauf Insulation Limited has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically, with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
Part of the Knauf group (http://www.knauf.com), a family-owned multi-national manufacturer with 40 years of experience in the insulation industry, we are leading the change in smarter insulation solutions for a better world.
We are one of the fastest growing and most respected names in insulation worldwide and are committed to helping our customers meet the increasing demand for energy efficiency and sustainability in buildings.
In the UK we have 3 manufacturing plants in St Helens, Cwmbran and Queensferry with our UK Head Office in St Helens.
Our mission is to challenge conventional thinking and create innovative insulation solutions that shape the way we live and build in the future, with care for the people who make them, the people who use them and the world we all depend on.
We challenge ourselves, regulators and our industry to develop new concepts and new ways of thinking about insulation and buildings;
We create innovative solutions that change the way we work and set new standards of quality, performance and sustainability;
We care about what really matters: our people, our customers, our communities and ultimately, our planet.
We lead the change in smarter insulation solutions for a better world. Our aspiration is to be the world’s most trusted insulation partner providing high performing and smart insulation solutions and services for a better world.
For further information please visit our website http://www.knaufinsulation.co.uk/
Our Internal Policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
Reporting a Breach of Company Rules or Policies – including Whistleblowing policy
Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains. If an employee suspects any employee, regardless of their seniority, or the Company of committing a serious breach of this policy, they have a duty to report their concerns to a director and should do so without delay. The information will be treated in confidence.
Our Employee Handbook and Knauf Group Code of Conduct (Code of Conduct)
These explain the manner in which we behave as an organisation, the rules we all follow, the policies we have in place and how we expect our employees and businesses to act.
External Policies and Suppliers
Knauf Insulation will never knowingly tolerate slavery or forced labour. During 2020 we have not been made aware of any allegations of modern slavery activities against any of our suppliers, but if we were, then we would act immediately and where appropriate work with our supplier and any necessary authorities to rectify the situation.
We continue to have a complex supply chain providing services and goods to our UK manufacturing sites; the majority of our suppliers are based in the UK but some operate from other parts of the world including mainland Europe and USA.
We continue to maintain and develop tools and processes to identify and mitigate any risk of instances of slavery human trafficking occurring in our supply chain, some of these are outlined below.
Supplier Code of Conduct
Available here, a code for existing and prospective suppliers that, amongst other requirements, sets out expected standards of working conditions for staff employed by the supplier – including free choice of employment, no child labour, remuneration and benefits, hours of work and non-discrimination.
Preferred supplier list
We follow a defined on-boarding process for any new suppliers and due diligence is carried out on suppliers before and after allowing them to become a preferred Knauf Insulation supplier. This due diligence can include desk or field-based audits including self-disclosure questionnaires and collation of any accreditations and standards held.
In our latest standard Terms of Purchase and Supply Agreement (available here), the company reserves the right to terminate a supplier contract at any time should any instances of modern slavery come to light.
As part of Knauf Insulation’s trading arrangements, new and existing suppliers are required to demonstrate that:
- They confirm compliance with the Knauf Insulation Code of Conduct for Suppliers
- They have taken steps to eradicate any modern slavery within their business
- They shall notify Knauf Insulation promptly if they become aware, or has reason to believe, that their organisation or any of its agents or subcontractors have breached or potentially breached the Modern Slavery Act 2015
- They hold their own suppliers to account over modern slavery
- They pay their employees at least the regional minimum wage / national living wage (as appropriate).
Relevant memberships and Accreditations
Knauf Insulation is a voluntary member of SEDEX (Supplier Ethical Data Exchange), an affiliate member of TISC (Transparency In Supply Chains) Report and a member of the Supply Chain Sustainability School.
All our production facilities are certified for four of the most important International Management Standards: ISO 9001 (Quality Management), ISO 14001 (Environmental Management), ISO 50001 (Energy Management), OHSAS 18001 (Occupational Health & Safety Management).
BES6001 accreditation and Responsible Sourcing Policy
Knauf Insulation hold BES6001 Accreditation (see here) across both our Glass and Wood Wool businesses which was supported by and helped the development of our Responsible Sourcing Policy (available here).
The BES 6001 Accreditation was valid until Febrary 2021 and was successfully renewed until February 2024.
Training on Modern Slavery and Human Trafficking during 2020
Further awareness and policy training has been undertaken by our Pocurement team during 2020 through wider research on the subject through, for example, the Global Slavery Index and Supply Chain Sustainability School. During 2021 we hope to use our new resources and knowledge to further inform the wider business through various platforms.
Combating Slavery and Human Trafficking during 2021
We will continue to develop and inform anti-slavery initiatives into our business, existing supply chain and new suppliers during 2021. Initiatives will include:
- Further promotion of our Supplier Code of Conduct, this statement and the Modern Slavery Act into the supply chain and within our own business utilising additional resources and knowledge obtained during 2020
- Internally, we will use newly introduced communication tools (e.g. Microsoft Yammer, Microsoft Teams) to reach the right audience in the right format at the right times to inform our colleagues and receive appropriate feedback
- Video content will be the prime source of communication to the business; this content will be appropriately sourced from the relevant organisations to ensure a consistent and accurate message(s)
- Externally, we will further develop any other relevant tools we feel are appropriate to communicate with and monitor our suppliers
- Continue to review our options for undertaking ethical audits of our supply chain, which may include desk-based audits or third party assessments and make use of the tools available from places such as TISC, SEDEX, Global Slavery Index and the Supply Chain Sustainability School
- Further develop the process and tools by which we identify, measure and manage any modern slavery risks making use of resources and tools available from relevant third parties such as those listed above
- Develop Key Performance Indicators to help monitor and measure how we are performing in some key areas of this statement
- This statement and any relevant policies will be reviewed regularly and at a minimum frequency of once per year by end of June
Neil Hargreaves – Managing Director
Neil Hargreaves – Managing Director