MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE FINANCIAL YEAR 2020
As a SME trading below the threshold we are not required to make a formal statement.
However we do recognise that many of our clients will be seeking reassurance from
us about our compliance with the requirements of the Modern Slavery Act
Modern slavery is a crime and a violation of fundamental human rights. It takes various
forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of
which have in common the deprivation of a person's liberty by another in order to exploit
them for personal or commercial gain.
We are committed to improving our practices to combat slavery and human trafficking.
ORGANISATION
This statement applies to The DisceteHeat Company Limited. The information included in the
statement refers to the financial year 2020.
ORGANISATIONAL STRUCTURE
We are a privately owned business based at 1 Victoria Works Industrial Estate, Coal Pit Lane,
Atherton, Manchester. M46 0FY. The organisation is controlled by a Board of Directors.
We sell skirting heating and ancillary products in the UK and other parts of Europe. The sale
of these goods is via the website, social media and through marketing materials.
Demand for the product is throughout the year and is not seasonal.
The labour supplied to The DisceteHeat Company Limited in pursuance of its operation is
carried out throughout the United Kingdom.
DEFINITIONS
The DisceteHeat Company Limited 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 DisceteHeat Company Limited acknowledges its responsibilities in relation to tackling
modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.
The DisceteHeat Company Limited understands that this requires an ongoing review of both
its internal practices in relation to its labour force and, additionally, its supply chains.
The DisceteHeat Company Limited does not enter into business with any other organisation,
in the United 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 DisceteHeat Company Limited in the pursuance of the provision of
its own services is obtained by means of slavery or human trafficking. The DisceteHeat
Company Limited strictly adheres to the minimum standards required in relation to its
responsibilities under relevant employment legislation in the United Kingdom and Europe.
SUPPLY CHAINS
In order to fulfil its activities, The DisceteHeat Company Limited’s main supply chains include
those related to various manufacturing companies who supply the skirting heating panes and
the various ancilarys that go with it.
We have conducted a risk assessment as part of our supplier approval process.
POTENTIAL EXPOSURE
In general, The DisceteHeat Company Limited considers its exposure to slavery/human
trafficking to be relatively low, nevertheless 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.
STEPS
The DisceteHeat Company Limited 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 DisceteHeat Company Limited 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 DisceteHeat Company
Limited has taken the following steps to ensure that modern slavery is not taking place:
We have in place policies and systems across our business; our trading partners; and our
supply chains to:-
•
•
•
• Protect whistleblowers; and
• Investigate reports of Modern Slavery.
- Identify inappropriate employment practices;
- Identify, assess and monitor other potential risk areas;
- Mitigate the risk of slavery and human trafficking occurring;
- Protect whistleblowers and Investigate reports of Modern Slavery.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply
chain and contractors comply with our values we operate in line with principles of responsible
sourcing, including paying employees at the prevailing minimum wage applicable within their
relevant country of operations. We have in place a Supplier Code of Conduct which outlines
our expectations. The relevant account managers will monitor and enforce compliance of the
Supplier Code of Conduct.
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking
in our business, in our supply chains and in our business partners, we provide relevant training
to our colleagues. Under our Supplier Code of Conduct we also require our business partners
to provide regular and relevant training to their staff and suppliers and providers.
SLAVERY COMPLIANCE OFFICER
The DisceteHeat Company Limited has a Slavery Compliance Officer, to whom all concerns
regarding modern slavery should be addressed, and who will then undertake relevant action
with regard to The DisceteHeat Company Limited obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will
be reviewed for each financial year.
Russ Hamer - Operations Director
03/03/2021