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Modern slavery statement


Organisation

This statement applies to Zehnder Group UK Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2021-2022.

Organisational structure

We are a manufacturer in the Heating, Cooling and Ventilation sector. Zehnder Group UK Ltd is part of the parent company Zehnder. The UK group employs approx. 130 people, with a turnover of approx. £50m. Zehnder has its head office in Switzerland. The Group has over 3,000 employees worldwide and operates in 15 countries. Zehnder Group UK Ltd is based across 3 separate locations, with Head Office being in Camberley, our production and warehouse in Lenham and a showroom in London.

Definitions

The Organisation considers that modern slavery encompasses:
• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse of
the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as
property
• being physically constrained or to have restriction placed on freedom of
movement.

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains. The Organisation does not enter into business with any other organisation, in theUnited Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, and in many cases exceeds those minimums in relation to its employees.

Supply chains

In order to fulfil its activities, the main supply chains of the Organisation include those related in the procurement and fulfilment of goods and services relevant to our business sector from both domestic and international suppliers. Typically, these suppliers are 1st Tier and we understand that they, in turn, procure goods and services from suppliers downstream of the supply chains.

Potential exposure

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in its international markets, particularly those in Asia (EG China & India) but clearly realise that Slavery is not limited to these higher risk areas alone. In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Impact of COVID-19

During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the Organisation, as it did for others across the nation. The Organisation welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty. Despite the permitted, delay, the Organisation remains in a position to publish its statement for the financial year 2019/2020 in line with the original publishing requirements.

The Organisation concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above. The organisation feels that our risk DID NOT increase significantly due to the impact of Covid-19. As a UK company we had already increased inventory in preparation for Brexit, we did not engage any new suppliers and the suppliers we were using were either closed or providing Covid risk assessments which included home working, social distancing and sanitisation. We were unable to conduct physical audits, due to Covid restrictions, but felt that our historical relationships and processes are trustworthy and reliable and engender trust.

During the pandemic, the Organisation’s employees still had access to the grievance procedure to raise any concerns that they may have had. In line with emergency legislation passed by the Government, employees have been paid Statutory Sick Pay during periods of self isolation where it has not been possible to agree a temporary period of homeworking. The Organisation took the decision from the outset of the pandemic to ensure that all of the workforce who were required to self-isolate in accordance with public health guidelines continued to receive full pay during their absence. The Organisation’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers. The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery. In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

Zehnder group has already (2019) added additional questions relating to Slavery and Human trafficking in its Ethical & Social responsibility (ESR) section of our vendor assessment questionnaire. Vendors making a positive declaration are assessed on potential risk and physical audits planned where necessary. Vendors without a suitable policy are also risk assessed and physical audits conducted where necessary. Zehnder group will also offer support to vendors in developing, training & identifying slavery and human trafficking to help develop an ESR policy. Vendors not replying will be contacted and put “at risk” status. We will seek potential alternative vendors of similar products and services who may have a lower risk profile During 2021/22 Zehnder Group will review our vendor contracts and assessment questionnaires to clearly state a zero tolerance of Modern Slavery. The implementation of potential immediate Contract termination terms where Modern Slavery and human trafficking is identified will be added as a clause.

We will check that all vendors with turnover >£36m have Modern Slavery statements. Copies of these will be filed electronically as evidence the check has been conducted. Purchasing staff have undergone internal awareness training and are able to identify signs, conduct staff interviews and understand the risks and threats of Modern Slavery. Due to Covid-19 and use of the Furlough scheme, purchasing staff will have refresher training by 28.02.2022. Key performance indicators The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

All vendors

• Vendor assessment questionnaires are refreshed every 3 years and
documented.
• The number of returned, positive responses will be logged and measured.
• The percentage of “at risk” vendors will be measured.
• The number of physical audits will be reported and documented.
• Instances of Modern Slavery to be stored, measured and actions taken
documented.

Policies

The Organisation has the following policies which further define its stance on modern slavery. We have a code of conduct policy and a recruitment and selection policy.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Modern slavery statement
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