Modern Slavery Act
Introduction
This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and it relates to actions and activities for the financial year ending 31 December 2023.
Fleming Windows and Doors UK Limited, trading as Fleming Windows and Doors Limited, (‘the Company’, ‘we’, ‘us’, or ‘our’) is committed to continually improving our practices to prevent slavery and human trafficking violations with the Company, in its operations, supply chain, or products. We have a zero-tolerance policy towards slavery and require our supply chain, our staff, and any third-party representatives of the business to comply with our values.
This policy statement sets out the steps taken by the Company to identify areas of risk within the business and any steps taken to eliminate or reduce such risks.
Organisation Structure
Fleming Windows and Doors UK Limited, trading as Fleming Windows and Doors Limited, is a window and door installation business with operations in the United Kingdom. The Company operates in the construction sector. The Company has one office based in Wolverhampton that is staffed by our administration staff. The Company has two employees and operates solely within the Midlands region of the United Kingdom.
We work with a number of UK-based suppliers who provide us with materials and other products required to provide our services to our customers. We also work with a number of suppliers who provide us with equipment and services that are necessary to complete our administrative requirements, such as outsourced business support, IT software and hardware, and marketing services.
Supply Chain
The Company recognises that we have a responsibility to take a robust approach to tackling slavery and human trafficking violations within its supply chain, and we are committed to preventing slavery and human trafficking within its supply chain.
The nature of the Company’s supply chain is as follows:
- Office space proprietor, including cleaning and caretaking services.
- IT hardware suppliers.
- IT software suppliers.
- Telecommunications providers.
- Office equipment suppliers.
- Office furnishings suppliers.
- Materials suppliers and manufacturers.
- Professional Services, including accountancy, business support, and legal services.
Our policies on Slavery and Human Trafficking
We are committed to ensuring there is no modern slavery or human trafficking taking place in any part of our business, or any of our supply chains. Our Anti-Slavery Policy reflects our commitment to act ethically and with integrity in all our business relationships, as well as to implementing and enforcing effective systems and controls to ensure that slavery and/or human trafficking is not taking place anywhere in our supply chains.
Policies
We operate a number of policies to ensure that we are conducting business in an ethical and transparent manner.
These include the following:
Recruitment and selection policy
We conduct checks on all prospective employees to verify that they are eligible to work in the UK. Certain roles require a Disclosure and Barring Service (DBS) check where employees may be working with vulnerable people or have access to business accounts.
Whistleblowing policy
We operate this policy so that employees are able to raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal.
Staff Code of Conduct policy
We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.
Safeguarding policy
This policy highlights the potential risks of modern slavery and human trafficking, including how to identify signs of exploitation and how to report concerns.
Procurement policy
We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and checks undertaken to help verify this.
Supplier Code of Conduct policy
Due Diligence
In accordance with our commitment to identify and mitigate the risk of modern slavery and human trafficking in our business or our supply chains, we have examined our own practices together with our suppliers of goods and services as detailed above to determine where and how we could ensure there is no slavery and human trafficking affecting any of our suppliers. We have adopted the following due diligence procedures:
- Internal supplier audits.
These procedures aim to:
- Identify and action potential risks in our business and supply chains.
- Monitor potential risks in our business and supply chains.
- Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
- Provide protection for whistleblowers
Our director and senior management have examined the risks of modern slavery and human trafficking within the business and have determined that the risks are low. We operate solely and exclusively within the Midlands region and do not have any presence outside of the UK, or in the major metropolitan areas. The Company checks every prospective employee’s right to work status before making any offer of employment, and any employee with access to business accounts or that may work with vulnerable people is required to have a Disclosure and Barring Service (DBS) check.
Our director and senior management have examined the risk of modern slavery and human trafficking within our suppliers of goods (such as the suppliers of materials and equipment) and services (such as professional services) and we have concluded that the risk here is low. The businesses used in our supply chain are large, reputable organisations with established, significant online presences, and are often based in, or have registered offices, in the UK. We only engage with and purchase services or materials from such companies, which we believe limits our potential for encouraging or interacting with modern slavery or human trafficking.
We continually seek to improve our practices and develop processes that will:
- Assess and identify potential risks in our supply chain.
- Mitigate these risks in our supply chains.
- Monitor potential risk areas.
- Protect any whistle-blowers.
We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with the supplier immediately.
Training
We ensure that all staff within the Company have a high level of understanding of the risks posed by modern slavery and human trafficking to our business, and to our supply chain, and we ensure this is retained with regular training.