SLAVERY AND HUMAN TRAFFICKING COMPLIANCE STATEMENT – DECEMBER 2016
Consistent with our commitment to operate our business in an ethical manner and in compliance with all applicable laws and regulations, we are committed to improving our practices to combat slavery and human trafficking in our supply chain. While we have already taken positive steps to comply with these principles, we will continue to work with our suppliers and Elliott’s own people to ensure that slavery and human trafficking do not take place within our supply chain.
Elliott is a provider of relocatable accommodation including portable cabins, modular buildings, permanent buildings, secure storage, portable toilets, temporary fencing and related products and services in the UK. We are a part of the Algeco Scotsman group (Group), and our ultimate parent company is Algeco/Scotsman Holding S.à r.l.. Algeco Scotsman has its head office in the US. The Group has over 4,500 employees worldwide and operates in 25 countries across four continents.
Further details about the Group and its operations can be found at www.algecoscotsman.com.
Elliott provides buildings for hire, modular buildings for sale and rent, and off-site permanent buildings for sale throughout the UK for temporary, semi-permanent and permanent use across a wide range of sectors. Elliott has its head office in Peterborough and operates its business from a network of branches throughout England, Scotland and Wales.
OUR SUPPLY CHAINS
Our supply chains include: the manufacture of modular units; materials for buildings including steel components, walls and panels, insulation, electrical components, plumbing supplies and flooring; sub-contract services for certain delivery, installation, disassembly and repair/maintenance work; IT and other business support services.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. The Group’s Supplier Code of Conduct available at http://www.algecoscotsman.com/pdf/AS_Supplier_Code_of_Conduct_ENG.pdf reflects our commitment to acting ethically and with integrity in all our business relationships, we now further that commitment by implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chains.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk Elliott has considered the vendors currently forming its supply chain, where those vendors are located and the sectors they operate in.
We have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
SUPPLIER ADHERENCE TO OUR VALUES
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and our contractors comply with our values we require vendors to adhere to our Supplier Code of Conduct, including a commitment to not use slave labour or participate in human trafficking.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
During this year we received Elliott board approval for this statement. We have brought the preparation of this statement to the attention of those in our procurement organisation and given the opportunity to provide feedback, to raise queries and to have them answered. We have also involved our legal, risk and procurement teams in undertaking an assessment the risk of non-compliance in our supply chain.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have provided training to our staff with direct responsibility for our supply chain and will continue to provide this training to relevant new employees in our organisation.
Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains, we intend to review and, to the extent necessary based on legal advice, update our contracting processes to ensure that our suppliers are bound to comply with our policy against slavery and human trafficking and for us to have the ability to terminate relationships for any non-compliance.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2016.
Lee Jon Newman
Chief Executive Officer
Elliott Group Limited