Modern Slavery Statement 2018/19

Safety First Manufacturing Co Ltd (incorporating Tusker Industrial Safety), as a global corporate citizen, recognises its responsibility to address and mitigate the risk of modern slavery and human trafficking in its operation and supply chain. This statement sets out our commitment and actions taken to do our part to eradicate these abhorrent practices and meets the requirements of the UK Modern Slavery Act 2015.

Our Business and Supply Chains
Safety First Manufacturing (incorporating Tusker Industrial Safety) is the UKs  leading manufacturer of industrial safety equipment, including welding safety products, PPE, industrial work wear, construction safety products and more. On top of selling our products directly to a global client base of end users across a range of industries, we supply a network of over 250 distributors.

We believe that our trade with the people we source from should have a positive impact, creating jobs and opportunities for people all over the world. We have dozens of direct and indirect suppliers who manufacture and move a wide range of intermediary products and raw materials across global supply chains. These suppliers range from large listed companies to small, independent local manufacturing enterprises. We also work with a number of other partners who help keep our office and manufacturing facility clean, provide logistics services, provide IT support and more.

Starting with our own business operations and service providers, and then increasing the visibility we have of our global supply chains, we have worked to identify actual or potential risks of modern slavery and taken steps to ensure that we are not supporting these practices indirectly.

Policies in Relation to Modern Slavery
At the heart of our approach to human rights are a number of important internationally recognised declarations, standards and codes. These are the foundations for how and where we work and include:

The UN Universal Declaration of Human Rights
The International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work
The UN Guiding Principles on Business and Human Rights
The UN Global Compact
The Base Code of the Ethical Trading Initiative

Our approach to addressing modern slavery sits within our wider human rights and social responsibility agenda, which is supported by our Environmental Policy, Health and Safety Policy, CSR policy and Service Guarantee. These documents set out our obligations to customers, colleagues and communities in our operations and supply chain. We take any breech of our policies extremely seriously.

We are committed to ongoing and continual improvement, training and capability building in the area of ethical trade, with measurable targets set annually as a part of our broader performance review.

We expect all suppliers we engage with to ensure that their goods, materials and labour related supply chains are:

• Fully compliant with the Modern Slavery Act 2015
• And are transparent, accountable and auditable.

Individuals involved in our supply chain, with evidence of non-compliance within their organisation are encouraged to make use of our Whistleblowing Policy outlined in our supplier engagement contract if they feel unable to speak with their line manager.

Staff Training
All of our management staff have been provided training and guidance on what constitutes modern slavery and human trafficking. All management staff are able to:

• Identify and provide examples of red flags in our supply chain.
• Explain Safety First Manufacturing reporting procedures for suspected cases of modern slavery.
• Promote a company wide sense of responsibility to prevent modern slavery within both our business and our supply chain.

Steps Taken
Management Responsibility and Governance
We Have:
1. Agreed management responsibility for this statement with our Board of Directors and Audit Committee .
2. Reviewed this statement and report against our plans annually.
3. Raised organisational awareness through specific learning and development training for all relevant new and current colleagues in regards to modern day slavery and human trafficking.
4. Included the Modern Slavery Act 2015 within our risk compliance regime to ensure the risk continues to be assessed and appropriately addressed.

Assessing Risk
We Will:
1. Continue to undertake assessments using our business risk, procurement teams and ethical partners to determine our risk exposure.
2. Continue to assess inherent risk of our extended supply chain to include our complete vendor base to determine the most effective way to ensure we meet our obligations under the Modern Slavery Act 2015.
3. Write to all distributors and suppliers to raise awareness of the Modern Slavery Act. This will state our zero tolerance to human rights abuses, encourage our suppliers to establish their own processes and state that we will undertake compliance checks.

Risk Mitigation
We Require:
1. All suppliers to sign up to terms which confirm they comply with and have not been convicted of an offence under section 1, 2 or 4 of the Modern Slavery Act 2015 and will terminate contracts for failure to comply.
2. All high risk suppliers to complete a supplier assessment questionnaire (SAQ) and mandatory modern slavery training module to raise awareness of the issue within our supply chain.

Management Due Diligence
We continue to:
1. Report progress in delivering our plan to the Board of Directors and Audit Committee for review.
2. Undertake activity in our supply chain to minimise the risk of modern slavery. New suppliers will be subject to due diligence checks and as appropriate SAQ’s or ethical compliance audits conducted by Safety First Manufacturing or a 3rd party on our behalf. We will also regularly continue to undertake such audits for existing suppliers.

Assessing Risk
We continue to:
1. Review our policies and activities and establish whether the approach we have taken follows best practice by:
• Assessing and interpreting any recent or emerging prosecutions or best practice guidance.
• Benchmarking our activities against statements and action plans undertaken by similar organisations.
2. Prioritise suppliers based on the inherent risk in the industry and country they operate in for further assessment where required.
3. Ensure compliance with our supplier requirements outlined in our ethical statement to suppliers via additional spot checks, SAQs and/or independent audits.

Risk Mitigation
We will always:
1. Act promptly where a compliance breach has been identified or flagged.
2. Continue to feed-back lessons learned into our compliance risk management process.
3. Raise market awareness of modern slavery issues via proactively working with our industry bodies, customers, suppliers and partners in campaigns.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Safety First Manufacturing’s slavery and human trafficking statement for the reporting year ending 31st June 2019.

A signed version of this statement is available upon request.

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