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Modern Slavery and Human Trafficking Statement 2021 for EEF Ltd (t/a Make UK)

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps we have taken to minimise the risk of modern slavery in our business and supply chains.

Introduction    

Make UK is committed to preventing slavery and human trafficking occurring in any of its corporate activities. As a membership and professional services organisation, our services are delivered to our member companies and clients. Our commitment is to ensure that those organisations that we actually contract with to receive goods and services are aware of our policies in order to comply with the Modern Slavery Act.

This commitment is evident through our company policies, which aim to uphold the highest ethical and professional standards. We ensure the adherence to policy commitments and compliance of current Government legislation and regulations

Our organisational structure and operations

Make UK is a manufacturing support service provider, working across a range of services from industry leaders, managers and professionals, to young people, apprentices, policy-makers and the media. 

Make UK is made up of: Make Business, Make Venues, UK Steel, and Make UK Defence  employing between them just over 300 staff nationally.

The vast majority of our suppliers and contractors are based in the UK.

Our commitment to the principles of the Modern Slavery Act 2015

Make UK is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.

As an equal opportunities employer, we are committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves and as such the company has an established whistleblowing policy which all staff can access alongside all other company policies on the staff intranet.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK, and where applicable subject to DBS checks in order to safeguard employees and apprentices from any abuse or coercion.

We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Our contracts with our members & customers allow us to terminate for convenience under a wide ranging all encompassing reputational damage contract clause which covers those to be found in breach of the modern slavery act.

Much of the supply chain is engaged on their terms & conditions, although modern slavery and anti-bribery elements are incorporated into the award of new or renewing contracts.

Policies relating to slavery and human trafficking

Our Anti-slavery policy is posted on the staff intranet together with all other company policies and procedures.  It is an annual agenda item for discussion and consultation with our National Staff Forum. It reflects our commitment to implementing and enforcing effective procedures and controls to minimise the risks of human trafficking and other modern slavery practices infiltrating our business operations and acting ethically and with integrity in all our business activities and relationships.

Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains.

Previous  action

Make UK introduced an anti-slavery policy to all our staff following consultation with staff representatives and this was incorporated into our Employee Handbook.

During last year key staff underwent e-learning training in order to increase awareness of the signs and risks related to modern slavery and the ability to identify where such cases might be occurring.

Current action

We aim to take the following further steps over the course of the next financial year ending December 2022: 

  • Ensure that our largest suppliers which cover circa 80% of our spend have an up to date modern slavery statement
  • Sample check a number of smaller suppliers based on risk identification to ensure adherence to the Modern Slavery Act
  • Ensure all company policies are reviewed to ensure where appropriate cross reference to the company anti-slavery policy
  • Specifically include modern slavery act adherence and anti-bribery into supplier selection assessment
  • Establish a supplier (and any other relevant) code of conduct to include among other things an expectation of compliance with the Modern Slavery act

This statement has been approved by the Executive Board of Directors and the actions contained herein.

This statement has been approved by Richard Greenway, Finance Director for the financial year ending 31 December 2021.

This statement will be reviewed and updated every year.