INTRODUCTION

The International Labour Organisation (ILO) estimated that on any given day in 2016 there were at least 40 million people worldwide who were victims of modern slavery. We recognise our responsibility and the need to take a robust approach to slavery and human trafficking. We take a zero tolerance approach to non-compliance with the Modern Slavery Act in any part of our Business or our Supply Chain.

WHAT IS MODERN SLAVERY?

Modern slavery is a brutal form of organised crime in which people are treated as commodities and exploited for criminal gain.  This can take many forms including child labour, forced labour and human trafficking. The most widespread form of modern slavery is bonded labour (debt bondage) where people borrow money they cannot repay and are required to work to pay off the debt.

Someone is in slavery if they are:
• forced to work – through coercion, or mental or physical threat;
• owned or controlled by an ’employer’, through mental or physical abuse or the threat of abuse;
• dehumanised, treated as a commodity or bought and sold as ‘property’;
• physically constrained or have restrictions placed on their freedom of movement.

OUR POLICY ON SLAVERY AND HUMAN TRAFFICKING

LED ECO Lights remains committed to ensuring that there is no modern slavery or human trafficking in our supply chain, or in any party of our business, with a zero tolerance for non-compliance.  This statement reflects that 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 chain.

OUR SUPPLY CHAIN

Our supply chain includes :
• Plant, vehicles and equipment suppliers
• Suppliers of contingent labour
• Manufacturers and suppliers of materials and goods
• Subcontractors and service providers

Each supplier within our supply chain is assessed for acceptance and continuance on our Approved Supplier List in line with our UKAS-verified ISO9001:2015 quality management processes, which include a review of risks that may exist relating to Slavery and Human Trafficking.
LED Eco Lights undertakes a risk review and due diligence during our onboarding process with new suppliers. A copy of this policy is given to all suppliers before they start working with LED Eco Lights. The Purchasing team holds a programme of audits to periodically reassess existing suppliers. Re-audits may be planned with suppliers and may also include unannounced audits.  Audits include recruitment methods and processes. Consideration of new suppliers and audits of existing suppliers is completed under the guidance of the Managing Director.
LED Eco Lights has a zero-tolerance approach to Modern Slavery of any kind within our operations and supply chains. All suppliers MUST also operate a zero-tolerance approach to Modern Slavery of any kind within their operations and supply chains. Any supplier suspected of Modern Slavery or Human Trafficking shall be audited by LED Eco Lights.

STAFF TRAINING & AWARENESS

All management, supervisors and staff are trained to understand and be vigilant for signs or violations of modern slavery and human trafficking within their job roles and functions. Our staff are instructed to be vigilant and are able to report any modern slavery-related  concerns via our Action Improvement Request (AIR) System.  LED Eco Lights are committed at Senior Management level to act upon any such reports.

LED Eco Lights will not work with any suppliers suspected of Modern Slavery or Human Trafficking.