Slavery and Human Trafficking statement for Consolidated Timber Holdings Group Limited and all of its subsidiary companies (together the Group) made pursuant to Section (54)1 of the Modern Slavery Act 2015 for the financial year ending March 2019:
The Group is an importer, distributor of wood and wood based panel products and manufacturer of timber components selling primarily into the UK market. The Group’s head office is in Shepperton and has 10 trading operations spread across England. The Group companies covered by this statement comprises Consolidated Timber Holdings Limited (registered number 02295212), Compass Forest Products Limited (registered number 01893926) , Falcon Panel Products Limited (registered number 02013545), Hoffman Thornwood Limited (registered number 014511361), MBM Forest Products Limited (registered number 0882018), MBM Speciality Forest Products Limited (registered number 03359636) and Triesse Limited (registered number 01196158).
The Group imports timber and panel products from sustainable resources around the world including the Far East, China, South and North America, Scandinavia, Russia and Central Europe. The Group is a member of the Timber Trade Federation and complies with the laws on environment and chain of custody regulations
The Directors are cognisant of the Modern Slavery Act 2015 (“The Act”) and the Human Rights Convention determining whether a person is being held in slavery or servitude or required to perform forced or compulsory labour and condone all such arrangements. It is the Group’s policy to arrange the supply of goods and services for the products that are purchased from sources in the United Kingdom or imported from any other country either for its own consumption or for resale to its customers that meet the standards set out in The Act.
The CTH Group companies arrange supply of material and services with established and reputable producers who comply with the local laws of the country from where products are sourced. Where new sources of supply are identified then the appropriate enquiries into the governance and compliance with the law of the country are made to be assured there is no contravention of The Act.
The Directors and senior management team are not aware of any instances of slavery or human trafficking and are committed to ensuring the same on an on-going basis.
Our internal policies apply to all Group company employees. As detailed in our detailed employee handbook and contracts of employment any non-compliance with such policies may result in disciplinary action. The Group encourages employees to report any concerns, wrongdoing or danger in the workplace without fear of reprisal. The Group has a Whistleblowing Policy which provides an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. The Group also has a detailed Bribery, Anti-Corruption and Tax Evasion Policy and maintains on-line logs for all relevant employees to record hospitality given and received.
As part of our initiative to mitigate risk in our businesses and supply chain the Group purchase goods and services from third parties that we believe take the same stance as us against slavery and human trafficking. In the main the wood or wood based products that we purchase are from FSC® certified sources (www.fsc-uk.org/en-uk) and PEFC (www.pefc.co.uk) which include the key principle of protecting worker rights. Our procedures and practices across the Group are assessed annually by independent certification bodies to ensure that we meet FSC®, PEFC® and other similar chain of custody guidelines and the mills that supply us also complete annual audits. We are also compliant with the European Union Timber Regulation (EUTR), the UK Timber Trade Federations Responsible Purchasing Policy (RPP) as well as the Lacey Act, which imposes obligations on us to carry out due diligence into who our timber suppliers are.
We review this statement and progress against our plans annually at Board level.
Our senior management team is asked to confirm on an annual basis that it is not aware of any instances of slavery or human trafficking within any part of our business or supply chain. This team is responsible for all areas of our business including;
• Legal and Compliance
• Health, safety and Environment
• Human resources
• Sales and Marketing
• Finance, auditing and Risk
This annual confirmation took place in May 2019 and we retain records of the statements obtained.
We will review our policies and activities to establish whether the approach we have taken follows emerging best practice and benchmark our activities against statements and action plans undertaken by similar organisations.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff as appropriate. During the year we have provided training to all relevant staff members on Corporate Governance matters including Slavery and Human Trafficking. The training is augmented by seminars lead by specialist external lawyers. During the year we held two seminars, one in July 2018 which was attended by all of the senior managers and Directors and one in December 2018 which was attended by all those involved in sales and purchasing across the Group.
Our standard form contracts with our key business partners provide for their compliance with the Law and Regulation relating to the sale and purchase of goods.
The Board has also risk assessed our domestic supply chain and identified that hauliers, providers of agency labour and sub contract cleaning services to our Group are potentially more at risk of been in contravention of the Act. To mitigate this risk during the year we have written to all suppliers of these goods and services requesting that they provide written assurances that they are in compliance with international conventions regarding human rights, including those relating to slavery or human trafficking, and are not aware of any slavery or human trafficking in their supply chains.
Linked to the UK Timber Trade Federation Responsible Purchasing Policy (RPP) we visit overseas suppliers periodically and carry out detailed due diligence on them. We are in the process of reviewing and updating the procedures we use to check our risk assessed overseas suppliers and their supply chains in line with developing UK Timber Trade Federation RPP guidelines to incorporate due diligence to ensure they are in compliance with international conventions on human rights, specifically those relating to slavery or human trafficking. We envisage these new guidelines will be available during the course of 2019 and we will review and update our procedures as appropriate at that time
Approved by The Board of Directors
Consolidated Timber Holdings Group Limited
31st May 2019