Modern Slavery Act 2015 Policy Statement – Financial Year ending 31st December 2023
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.
Slavery is an umbrella term for activities where one person obtains or holds another in compelled service. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Knauf Insulation Limited has a zero-tolerance approach to any form of modern slavery. Modern slavery occurs throughout the UK, but due to the secret nature, many people are unaware of what it looks like, or what action can be taken should they encounter it.
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.
Our Business
Part of the Knauf group, 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.
Knauf Insulation is 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, Knauf has 3 manufacturing plants, in St Helens, Cwmbran and Queensferry with our UK Head Office in St Helens.
Our Internal Policies
Knauf Insulation operates through several internal policies to ensure that we are conducting business ethically and transparently. These include:
Recruitment Policy
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 2023, 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; most of our suppliers are based in the UK, but some operate from other parts of the world including mainland Europe and the USA.
We continue to maintain and develop tools and processes to identify and mitigate any risk of instances of slavery or human trafficking occurring in our supply chain, some of these are outlined below.
Supplier Code of Conduct
Our Supplier Code of Conduct for existing and prospective suppliers sets out, amongst other requirements, 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. Before and after allowing them to become a preferred Knauf Insulation supplier. This due diligence can include desk or field-based audits, self-disclosure questionnaires and collation of any accreditations and standards held. Plus, their own company policy for Modern Slavery where applicable.
Trading Arrangements
In our latest standard Terms of Purchase and Supply Agreement, the company reserves the right to terminate a supplier contract at any time should any instances of modern slavery become known.
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), 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), ISO 45001 (Occupational Health & Safety Management).
BES6001 Accreditation and Responsible Sourcing Policy
Knauf Insulation holds the BES6001 Accreditation for all glass and rock mineral wool products manufactured at our three UK manufacturing facilities, which was supported by and helped to develop our Responsible Sourcing Policy.
Training on Modern Slavery and Human Trafficking during 2023
We have a dedicated member of the procurement team to keep up to date with legislation and manage the communication of key policies in relation to modern slavery.
Whistleblowing and Modern Slavery helpline posters have been placed in communal areas and noticed boards across the four UK sites.
Internal communication in relation to Knauf and the part we all play in the reporting of instances was published via our internal communication platforms.
Plans for combating Slavery and Human Trafficking during 2024
We will continue to develop and inform anti-slavery initiatives into our business, existing supply chain and new suppliers during 2024. Initiatives will include:
- Ensure that details of the Modern Slavery helpline and other related organisations who can assist are maintained on notice boards across the business.
- Working with the internal communications to team to introduce the several types of Modern Slavery and what actions to take if someone spots the signs.
- We will continue to use internal platforms Viva Engage, Teams and Microsoft 365 applications, to communicate updates and news about Modern Slavery.
- 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 SEDEX, Global Slavery Index and the Supply Chain Sustainability School.
- Continue to target key suppliers to obtain up to date compliance documents including Modern Slavery statements.
- 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
