ANTI-SLAVERY &
HUMAN TRAFFICKING
POLICY

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps we have taken to ensure that our business as well as our supply chains are free from slavery and human trafficking.

Introduction

Terberg RosRoca Group Limited and its subsidiaries are committed to preventing slavery and human trafficking occurring in any of its corporate activities, as well as seeking to ensure that our supply chains are also free from such practices. We ensure that our suppliers are aware of our procedures and take appropriate measures to ensure that our suppliers adhere to the same high standards.

Our Organisational Structure and Operations

Terberg RosRoca Group Limited and its subsidiaries, have manufactured automotive related products for over 100 years. Our collective experience and expertise allows us to produce pioneering products and solutions that are fully tailored to the needs of our clients. We manufacture and also carry out service and maintenance work in numerous locations throughout the world. We employ around 2,500 people across Europe and the Rest of the World with an annual turnover of €820m.

Nature of our Supply Chains

As a group we have over 500 suppliers across our operation. Our key suppliers are based predominately in the UK and mainland Europe along with a small percentage in China/Far East.
We purchase components and materials including engine and drivetrain, steel fabrications & castings, lighting, electrical & electrical wiring, hydraulics and plastics/rubber.

Due Diligence

Terberg RosRoca Group Limited and its subsidiaries undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. We carry out financial checks using respected services such as Dun & Bradstreet and we ask every potential new supplier to complete a Quality Control Plan Questionnaire which in summary assesses the quality and environmental procedures and accreditations in place. We also visit suppliers in person who we anticipate will be fundamental to our operations and who will supply in large quantities. We aim to ensure that all of our suppliers have agreed to and signed a Service Level Agreement (SLA) document which states the following: ‘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 Procedures reflect 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 also provide each supplier with a copy of this statement. If suppliers are found to have substandard practices we will take steps to ensure improvement including providing advice to suppliers and requiring them to implement action plans. We will invoke sanctions against suppliers that fail to improve their performance in line with an action plan or who seriously violate our SLA, including the termination of the business relationship.

Recruitment and Agency Workers Policy

Our Recruitment Policy details our procedures for bringing employees into the business in line with all relevant legislation and our internal Equality Policy. We only use specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from them.

Our HR team continues to ensure that we comply with all applicable laws in the areas in which we are based. The Company always aims to pay above the local living wage or the legally authorised rates for training apprentices in that region.

Employee Training

We have provided specific Anti-Slavery and Human Trafficking training for our HR and Purchasing Managers. We also ensure that we perform ongoing training within the HR, Purchasing, Supply Chain and Supplier Quality departments in order to train key staff to ensure that they understand the risks of modern slavery and human trafficking infiltrating our business or supply chains and in order to effectively operate our procedures aimed at mitigating this risk. This statement is also published internally to raise awareness of this issue and the Terberg RosRoca Group Limited and its subsidiaries commitment to preventing any instances occurring. Employees are encouraged to contact HR in confidence should they have any concerns to raise in relation to Modern Slavery or Human Trafficking.

Future Action

During 2017 we plan to  take the following actions in order to continue to improve our efforts to ensure that modern slavery and human trafficking does not occur in any of our corporate activities. Our initiatives will include:

  • Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
  • Evaluating the modern slavery and human trafficking risks of each new supplier
  • Incorporating our training requirements into our SLA to require our key suppliers to provide necessary awareness training to their own employees
  • Considering the use of an ethical supplier database.

We aim through these initiatives to identify which operations are at highest risk of infiltration in relation to slavery and human trafficking and to implement corrective action if necessary.

This statement has been approved by the Terberg RosRoca Group Limited board of directors who will review and update it annually.

Copyright © Terberg RosRoca Group 2017

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