Modern Slavery Act 2015
1. Modern Slavery and Human Trafficking 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 are committed to reviewing all of our practices to combat slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year from April 2020 to March 2021..
2. Organisation
This statement applies to Ricor Group Limited (referred to in this statement as 'the Organisation'). The information included in the statement refers to the financial year April 2020 to March 2021.
The Organisation is a producer of metal pressings and welded assemblies to the automotive industry worldwide. The Organisation has its head office based in Studley, Warwickshire (UK) and operates from three sites in the UK - West Bromwich, Arlington and Walsall. Poland (Starczanowo) and Slovakia (Nitra). The Organisation employs just over 550 people across its UK and European sites. The Organisation has a global annual turnover of €84 million.
3. Organisational Structure
The Organisation is controlled by a Steering Committee. The Group Managing Director has ultimate overall responsibility for the implementation of company policies and procedures and to ensure provision of competent persons to manage their execution.
Definitions of modern slavery
• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as property
• being physically constrained or to have restriction placed on freedom of movement
4. Our Supply Chains
Our supply chains include suppliers of raw materials such as steel and bought out parts, packaging materials, press tool manufacture, painting & finishing, consumable materials, etc. Around 95% of our suppliers are UK based or have UK based agents, 5% of our bought-in parts are imported directly from within the EU. The organisation does purchase power press tooling from China. Agency workers are supplied as needed by local agencies.
5. 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.
In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have put in place a designated Anti-Slavery and Human Trafficking Policy.
Our Anti-Slavery and Human Trafficking Policy demonstrates 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.
6. Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk we:
• Ensure that our employees have a right to work in the UK, we require proof of ID on induction which normally requires the individual to provide their passport.
• We ensure that the employee has a bank account in their own name to which their wages/salary is paid into.
• Employees are given training in our policies and our Code of Conduct.
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.
7. Potential Exposure and Risk Assessment
In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited, nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
8. Our Performance Indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
9. Supplier Adherence to Our Values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme.
Our new Supplier Questionnaire Self-Assessment and Product Audit has a whole section dedicated to compliance with Modern Slavery Legislation. The audit requires the Supplier to provide evidence and documentation, procedures, policies and risk assessments on their approach and due diligence to modern slavery.
We communicate our code of conduct, anti-bribery policy and anti-slavery and human trafficking policy to all our suppliers and inform them that we expect them to work in accordance with our policies and procedures. Suppliers must then acknowledge this by signing and returning our Code of Conduct letter.
10. 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. We also will require our business partners to provide training to their staff and suppliers and providers.
Richard Smith
Managing Director
