Slavery and Human Trafficking Policy

Slavery and Human Trafficking Statement

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 2018:

Organisations Structure

The Group is an importer distributor of wood based product and manufacturer of timber components selling primarily into the UK market. The head office is in Shepperton and trading operations are in 6 locations spread across England.

Our Business

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

Our Policy on Slavery and Human trafficking.

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 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. 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.

Processes for Mitigating Slavery and Human Trafficking

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 out timber suppliers are.

Supplier and Customer Adherence to Our Values

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
• Procurement
• Manufacturing
• Sales and Marketing
• Finance, auditing and Risk

Our standard form contracts with our key business partners provide for their compliance with law and regulation relating to the sale and purchase of goods

As part of our ongoing due diligence we request, where possible that new suppliers complete a declaration which states 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.

Training

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.

The Directors

Consolidated Timber Holdings Group Limited
March 2018