Innovative PVCu extrusions
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Slavery Statement

FLAMSTEAD HOLDINGS LIMITED

(the “Organisation”)

Slavery and Human Trafficking Statement for Financial Year 2015 / 2016

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps the Organisation has taken and plans to take in the future to ensure that slavery and human trafficking is not occurring within our supply chains or in any part of our business.

Respecting Human Rights issues is a key consideration throughout our Organisation and we expect our suppliers to act with integrity throughout their organisations. We have zero tolerance to slavery and human trafficking and expect all those in our supply chain to comply with these values.

Organisational Structure

This statement is published on behalf of Flamstead Holdings Limited in line with the Modern Slavery Act 2015, and references to “we”, “us”, “our” or the “Organisation” are to Flamstead Holdings Limited and its wholly owned subsidiaries.  HL Plastics Limited, a wholly owned subsidiary of Flamstead Holdings Limited, manufactures vinyl products for the fenestration and leisure industries.  In addition to HL Plastics, Flamstead Holdings also owns Avantek Machinery, which provides specialist machinery to the fenestration industry; and Vintage Windows, which manufactures fenestration products and provides testing services to both of the above.

Flamstead Holdings has an annual turnover in  of c £80m with a combined workforce of approximately 470, all located within the United Kingdom.

Supply Chain Overview

The Organisation’s supply chain encompasses the supply of both raw materials and finished goods, primarily from the USA and Europe with a small amount of goods purchased from China.

The Organisation’s primary raw materials include resin materials and compounds, steel, aluminium, hardware, machinery and accessories relating to the window industry.

Policies relating to Human Trafficking and Slavery

We are committed to reducing the risk of modern slavery and human trafficking in our supply chains and related dealings.

This Statement and our corporate policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing systems and controls that are both effective and reasonable in scope given our risk level, in order to ensure slavery and human trafficking is not taking place within our supply chain.

We have instituted an Anti-Bribery Policy, Employee Codes of Conduct and other internal policies concerning ethical behaviours, which highlight our commitment to ensuring we continue to operate in a principled manner, with the aim that our Organisation and supply chain remain free of slavery and human trafficking. We also have extensive Corporate and local systems in place to encourage the reporting of concerns, both by our employees and by third parties, and to ensure the protection of whistle blowers.

Risk Assessment and Due Diligence

In the future, we aim to regularly assess risk related to modern slavery and human trafficking associated with our supply chain and institute supply chain diligence procedures that are reasonable and appropriate in light of our business and risk levels.

During fiscal 2017, we plan to complete an initial assessment of our global supply chain risk based upon geography, by selecting and utilizing an appropriate Risk Index to serve as an indicator of countries where a higher degree of slavery and human trafficking abuses may be more prevalent.  Based on the results of that assessment, we plan to focus our compliance and certification efforts on those suppliers located in the highest risk countries.  At present, we believe that the nature of our business and the geographic location of most our supply chain partners generally reduces our risk related to slavery and human trafficking.

The Organisation aims to build long standing relationships with all suppliers and make clear our expectations of business behaviour, including our stance with regard to modern slavery and ethical practises, to enable effective working relationships throughout our supply chain.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our Organisation, in the future we will also explore the potential for providing training to relevant members of staff, including but not limited to Procurement and Management staff across the Organisation.

Monitoring and Reporting

We maintain an Alert Line that allows both employees and third parties to report any violations of law or our codes of conduct.  That Alert Line is monitored by corporate compliance officer at our ultimate parent company, Quanex Building Products Corporation.  All reports submitted to the Alert Line are investigated by that compliance officer.  As we work in 2017 to develop additional procedures specifically related to modern slavery and human trafficking, we will establish and implement appropriate monitoring and reporting structures where necessary.

 

This Statement was approved by the Board of Flamstead Holdings Limited on February 27, 2017.

Kevin P. Delaney

Director