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Introduction

Fine Organics’ will not tolerate forced, bonded or compulsory labour, human trafficking and other kinds of slavery or servitude within its own organisation or within its supply chain.

This statement sets out Fine Organics' actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there isn’t any slavery or human trafficking in our business nor in our supply chain.

This statement relates to actions and activities during the financial year 1 January to 31 December 2018.

As part of the global Chemical Industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensure that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Fine Organics who are a leading European contract manufacturer of high-quality fine chemicals.

Countries of operation and supply

The organisation currently operates in the following countries:

  • The United Kingdom

Our Supply Chain

  • Our Supply Chains include suppliers of raw materials from across the globe, suppliers of engineering parts and services from the UK and Europe, suppliers of professional services from the UK, Europe and the rest of the world.  We are reviewing the risks that these supply chains can present.

We expect our suppliers and contractors to demonstrate a zero tolerance approach to exploitation.  To this end, we will be inserting a clause into our contracts requiring that they will comply with the provisions of the Act and granting us with the right to terminate in the event of their failure to do so.

Responsibility for the organisation's anti-slavery initiatives is as follows:

  • Policies: The Board of Fine Organics is responsible for ensuring this policy is implemented.  The Supply Chain Manager and the HR Director are responsible for monitoring the compliance of this policy.
  • Investigations/due diligence: The Supply Chain Manager is responsible for ensuring suppliers comply with this policy and for investigating any suspected instances of slavery or human trafficking.  The HR Director is responsible for ensuring employment practices in Fine Organics comply with this policy and for investigating any suspected instances of slavery or human trafficking.
  • Training: The Commercial, Supply Chain and HR department have been trained in their responsibilities under this policy.

Relevant policies

The organisation operates the following policies and takes the following steps to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy

The organisation encourages all its employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Fine Organics’ whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

  • Staff Handbook

Fine Organics’ values and behaviours as laid out in the Staff Handbook make clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

  • Supplier code of conduct

Fine Organics’ is committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with our suppliers to ensure they meet the standards of the code and improve worker's working conditions as appropriate. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship. 

  • Agency workers policy

The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. 

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:

  1. mapping the supply chain broadly to assess a particular product or geographical risks of modern slavery and human trafficking;
  2. evaluating modern slavery and human trafficking risks of each new supplier as part of our assessment.

Over the next few years we will;

  1. Conduct supplier audits or assessments where we have assessed the need for a greater degree of focus on slavery and human trafficking;
  2. Participate in industry appropriate collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
  3. Assess whether ethical supplier databases could be used to strengthen our compliance, 
  4. Invoke sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation:

  • Requires the Commercial, Supply Chain and HR teams to be trained on modern slavery;
  • Has developed a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain;

Training

All staff working in Commercial, HR and Supply Chain have been trained on the Modern Slavery Policy.

Awareness-raising programme

As well as training staff, the organisation will be raising awareness of modern slavery issues by putting up posters across the organisation's premises, circulating a series of emails to staff and including information in the Company Newsletter.

The communication explains to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • how Fine Organics can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.

Board approval

This statement has been approved by the organisation's board of directors, who will review and update it annually.