1.0 OBJECTIVE
1.1 The overall objective of the Modern Slavery Policy is to ensure that ATS Plastics Ltd are conducting business in a manner which drives out acts of modern slavery from within its own business and its supply chain.
1.2 We enforce the highest possible ethical standards and expect our suppliers of goods and services to also enforce these standards. We reserve the right to check the ethical standing of all our suppliers in relation to any of the principles expressed in this policy.
2.0 MODERN SLAVERY STATEMENT
2.1 We are committed to driving out acts of modern slavery from within its own business and from that of subcontractors. This also includes the suppliers or services which make up the supply chain.
2.2 This policy applies to all employees of ATS and subsidiary companies.
3.0 WORKING COMMITMENTS
3.1 ATS Plastics Ltd acknowledges responsibility to the Modern Slavery Act 2015 and will ensure
transparency within the organisation and with all suppliers and services used directly by the organisation.
3.2 ATS Plastics Ltd will only do business with organisations that share our commitment to methods of working which drive out acts of modern slavery.
3.3 ATS Plastics Ltd hold several internal policies to ensure that we are conducting business in an ethical and transparent manner. The following are applicable to the commitments made about Modern Slavery:
- Our Recruitment& Retention Procedure (HR002) ensures that we check eligibility to work in the UK for all new employees.
- We operate a Whistleblowing Policy (EM025), so that all employees know that they can raise concerns about how colleagues are being treated, or practices within the organisation or supply chain, without the fear of reprisals.
- We ensure all our supply chain are assessed and sign up to the requirements of this policy and additionally operate a Code of Conduct HS009 - that all LOSC & Bona Fide Sub-Contractors who work on our sites are required to read, sign to confirm agreement and return to us before commencement of works. This explains the way we expect subcontractors to behave whilst working for Air Technology Systems Ltd / ATS Plastics Ltd.
- We operate within accordance to our Ethical Procurement Policy (ATSP005), This outlines the commitment and steps that ATS Plastics Ltd take to ensure that procurement is carried out in an ethical and transparent manner that there are no breaches to the Modern Slavery Act 2015
- We operate employment and HR practices that ensure:
- All employees are of minimum working age for full-time employment.
- All employees are paid at least the minimum wage.
- All employees are issued with contracts of employment and sign to give their consent.
- All employees are given correct breaks according to their age.
4.0 VENDOR ASSESSMENT PROCEDURE
4.1 We maintain an Approved Vendor Database (AVD) and follow a procedure (QU001) to assess our supply
chain, prior to use. This includes an online search to ensure the organisation has never been convicted of offenses relating to modern slavery.
4.2 This Policy forms part of our contract with all suppliers and they are required to confirm that no part of their business contradicts this statement.
4.3 In addition to the above, as part of our contract with suppliers, we require that they confirm the
following:
- They have taken steps to eradicate modern slavery within their business in accordance with the Modern Slavery Act 2015.
- They hold their own suppliers to account over modern slavery.
- They operate employment and HR practices that ensure:
- All employees are of minimum working age for full-time employment.
- All employees are paid at least the minimum wage.
- All employees are issued with contracts of employment and sign to give their consent.
- All employees are given correct breaks according to their age.
- We may terminate the contract at any time should there be any instances of modern slavery.
Air Plastics Ltd will not support or trade with any companies which are knowingly involved in slavery or human trafficking.
The Managing Director shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources and investment to ensure that slavery and human trafficking is not taking place within the organisation, or within its supply chain.
This policy statement will be reviewed annually and re-published.
Signed:
Stephen Boon
Managing Director
Date: 18.07.2022