Modern Slavery Act Statement
1. Introduction
Alamo Group Europe (and all entities controlled and/or affiliated with Alamo Group Europe) have a strong commitment to prohibiting human trafficking and slavery by any of its business entities, employees, and other associated parties. In compliance with the law, and to underline Alamo Group Europe’s commitment to prohibiting these practices, this anti-slavery and human trafficking statement serves to ensure a work environment that is free from human trafficking, forced labour and unlawful child labour. Alamo Group Europe strongly believes it is responsible for promoting ethical and lawful employment practices amongst the Alamo Group Europe companies. These practices are also required to be followed by our suppliers, subcontractors or business partners. Alamo Group Europe strongly opposes any use of slavery or human trafficking in the distribution of its own products and fully supports the promotion of ethical and lawful business practice within the workplace.
2. Organisational Structure
Alamo Group Europe is a limited company registered in the UK (registered company number 02649656). Established in 1991, with some member companies having been in business for more than 100 years, we are a designer, manufacturer and supplier of high quality equipment for infrastructure maintenance, agriculture and other applications in the industrial and agricultural sector. The group is currently comprised of 8 distinct companies located in the UK and France employing approximately 1,000 people (McConnel Limited, Spearhead Machinery Limited, Bomford-Turner Limited, Alamo Manufacturing Services Limited, Rivard, SMA Fauchaux, Force Gorge, Rousseau)
We are a part of the Alamo Group Inc. (Group), founded in 1969, which has its head office in United States of America. The Group has over 3,300 employees worldwide and operates in 4 regions of the world; Australia, Europe, North America and South America.
3. Our Supply Chains
Our supply chains consist of over 350 suppliers, 70% of which are based in the UK. In addition to our key suppliers for components and raw material, our suppliers also include, professional services (accountants, legal advisors, recruitment agencies); cleaning services, IT and Communications systems, Office Suppliers etc.
Suppliers paid over £100,000 per year make up 98% of our supplier spend and of these the majority have an annual turnover of >36m and are, therefore, themselves covered by the Modern Slavery Act requirements.
4. 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. Our anti-slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
We have adopted the following policies within our business to help us identify and combat unethical and inappropriate practices within our business and business relationships. These policies apply to all our workforce.
- Code of Business Conduct and Ethics Procedure
- Corporate Anti-Corruption Policy
- Health and Safety Policy
- Social Responsibility Policy
- Equal Opportunities and Diversity Statement
- Whistleblowing policy
5. Due Diligence Processes for Slavery and Human Trafficking
Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationship and implementing and enforcing effective systems and controls to prevent slavery and human trafficking practices in our supply chains.
To help identify any potential risks within our supply chains (including in respect of new suppliers and commercial arrangements), we undertake a due diligence assessment taking into consideration the following factors:
- Geographical location of the business or manufacture/supply of goods;
- Industry sector – we recognise that certain sectors suffer greater exposure to slavery and human trafficking practices;
- Value of the contract/commercial arrangement;
- Supplier’s dependency upon our business;
- Scope of the suppliers’ supply chain e.g. does the supplier manufacture or provide goods themselves or supply them from a third party;
In the event that any supplier/commercial arrangement is considered to be a potential risk, we will undertake further due diligence until we are satisfied that we have achieved compliance with the law and ethical practices.
We have also put in place system, procedures and best practices to help combat anti-ethical practices and modern slavery within our supply chains and general business operations. For example, we:
- Continually monitor potential risk areas in our supply chains using the services of Transparency International UK.
- Protect whistle blowers to ensure that they are not discouraged from raising any concerns relating to unethical or illegal practices;
- Adopt robust recruitment processes in line with UK employment laws, including: ‘right to work’ document checks; contracts of employment and checks to ensure everyone employed is 16 and above;
- Engage with reputable businesses and individual with a proven track record of legal compliance and good ethical standards;
- Have robust policies in place to ensure a new employee has the Right to Work in the UK and have confirmed their identity prior to the commencement of employment or placement.
- Train our staff and business partners on their obligations under the applicable laws and regulations. Completion of our Code of Ethics training module for all employees.
- Pay and reward our staff in accordance with legal requirements and reviewed annually and benchmarked;
6. Supplier Adherence to Our Values and Ethics
We have zero tolerance to slavery and human trafficking. We have a dedicated compliance team, which is responsible for ensuring that we comply with the principles and commitments set out in this statement. Our compliance team consists of members of Finance, HR, Purchasing and Sales, and are supported by our external professional advisors to ensure we act in accordance with the law.
7. Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. This is enshrined within our Code of Business Conduct and Ethics Procedure.
Our effectiveness in combating slavery and human trafficking within our organisation and supply chain is measured by reference to the number of reports received from employees, the public or law enforcement agencies to indicate that modern slavery practices have been identified.
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 31st December 2017.
