EFI
 
Slavery and Human Trafficking Statement for the financial year 1st November 2017 to 31st October 2018 – Applies to EBC Holdings Limited and its subsidiaries (Freeman Automotive (UK) Ltd, European Friction Industries Ltd, EBC Brakes Direct and ACFI)
 

Introduction

This statement is made in accordance with Section 54, Part 6 of the Modern Slavery Act 2015. This statement sets out the organisation’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring 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 1st November 2017 to 31st October 2018.

The organisation manufactures brake pads and brake discs and distributes these parts worldwide. The organisation recognises that it has a responsibility to take a robust approach to modern 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.

Policies

The organisation 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 organisation encourages its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation

  • Employee code of conduct – The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

  • Supplier code of conduct – The organisation 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 within the law in their use of labour.

  • Agency workers policy – The organisation uses only reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Training

The organisation intends provide training for HR professionals, all managers and supervisors in relation to:

  • 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 organisation;

  • what external help is available, for example through the Modern Slavery Helpline and Gangmasters and Labour Abuse Authority

Awareness-raising programme

As well as training HR professionals, managers and supervisors, the organisation intends to implement an awareness-raising of modern slavery issues programme during 2018/19 financial year by putting up posters across its premises to 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 organisation; and

  • what external help is available, for example through the Modern Slavery Helpline

Director approval

This statement was approved on 31st December 2018 by the organisation’s Chief Executive Officer, who reviews and updates it annually.

James Hallett

Chief Executive Office

Date: 31st December 2018