1. Policy statement

    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 have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.


    We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery and Human trafficking is the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013. We expect the same high standards from all of our contractors, suppliers and other business partners and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

    We make a clear annual statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees, people working within our supply chain and our clients seriously. We make this statement on our website.

  2. About this policy

     

    The purpose of this policy is to:

    (a) set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and
    (b) provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.

    This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives and business partners.

    This policy does not form part of any employee’s contract of employment and wemay amend it at any time.

  3. Responsibility for the policy

     

    The CEO has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.The Operations Director (OD) has primary and day-to day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

    Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

    You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Operations Director.

  4. Your responsibilities and how to raise a concern

     

    You must ensure that you read, understand and comply with this policy.

    The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a
    breach of this policy.You must notify the OD as soon as possible, if you believe or suspect that a breach of this policy has occurred, or may occur in the future.

    You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

    If you believe or suspect that a breach of this policy has occurred or that it may occur, you must notify your manager or OD as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.

    If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or OD.

    We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the employee handbook.

  5. Training and communication


    Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who are involved in managing recruitment and our supply chains.

    Our zero-tolerance approach to modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate on an ongoing basis.

  6. Breaches of this policy


    Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

    We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

  7. Supply Chains


    We thoroughly check supply chains for material suppliers to ensure the potential for slavery and human trafficking is significantly reduced.

    We tell the companies we do business with that we are not prepared to accept any form of exploitation.

    All our material supplier contracts contain an anti slavery clause. This clause, which flows down through all layers of our supply chain, prohibits suppliers and their employees from engaging in slavery or human trafficking.

  8. Recruitment


    Our recruitment team follows firm policy and only uses agreed specified reputable recruitment agencies. To ensure the potential for slavery and human trafficking is reduced as far as possible, we thoroughly check recruitment agencies before adding them to our list of approved agencies. This includes:

    • conducting background checks
    • investigating reputation
    • ensuring the staff an employment agency provides have the appropriate paperwork (eg work visas)
    • ensuring that Employment agencies provides assurances that the appropriate checks have been made on the person they are supplying

    We always ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work.

    We always ensure staff are legally able to work in the republic of Ireland. We check the names and addresses of our staff (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited).

    We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.

    If, through our recruitment process, we suspect someone is being exploited, the HR department will follow our reporting procedures.

— 28TH TO 30TH MAY IN HAMBURG, GERMANY —​

Future Plastics Takes Flight at the Aircraft Interiors Expo 2024 in Hamburg