Modern Slavery
Version number 2.0 Type of Document Policy
Audience Millbrook (UK) Ltd Employees, Suppliers, Contractors, Agents & Customers
Approved by Group Managing Director Date Approved 04 February 2023
Policy Author Commercial Director
Review period Annually in line with Financial Year End Review Due date 30 June 2023
Forms / Further Information
Millbrook (UK) Ltd is a privately-owned company that operates in two distinct sectors:
Manufacture of mattresses, beds and furniture in the UK, selling to retailers, wholesalers, hotels and public sector bodies.
Provision of industrial contracting services to the Defence sector across the world.
The manufacturing operations of the company are all based in the Southampton area of the UK, along with the Head Office. This part of the business employs circa 100 people.
The defence contracting division of the business operates in various countries, mainly in the EU. The top level management of this division is based at Head Office in the UK. This division has varying numbers of employees at different times due to the nature of the contracts, many of which are short term.
Our Statement
Modern slavery encompasses slavery, servitude, forced labour and human trafficking. These are issues of increasing global concern, affecting all sectors, regions and economies.
Modern slavery is fundamentally unacceptable within our business and supply chains and is an important element in our overall approach to business and human rights.
Millbrook, as a family owned business, is committed to respecting, protecting and championing the human rights of all those who work within our operations, including; employees, stock and non-stock supply chain workers, customers and local communities.
We accept our responsibility to support transparency and honesty, to find and resolve problems, and to work with others to protect the rights of workers, particularly those who are most vulnerable to abuses such as modern slavery.
Millbrook recognises the importance of its obligation to prevent slavery and human trafficking in the modern world and we operate a zero-tolerance approach to any contravention of this policy, throughout all our business operations.
Any breaches or concerns identified will be dealt with immediately and with positive action. Millbrook expects the same high standards from all our suppliers and contractors.
Our Supply Chain
Millbrook sources materials and services from both the UK and globally using established manufacturers, wholesalers and distributors.
Whilst working globally ensures we have access to the widest range of commercially priced materials and services, we acknowledge there is an increased potential exposure to modern slavery within these global supply networks.
We recognise materials sourced from certain global regions (e.g. the Far East) have higher potential to pose greater risk of modern slavery within our supply chain, both through their sourcing of raw materials, the manufacturing process itself and the shipping to the UK.
We monitor the Global Slavery Index to highlight regions and specific countries where the risk is greater so we can focus our efforts on diligence in those areas if we are doing (or intend to do) trade with them.
We operate our own fleet of delivery vehicles, delivering from our UK factory. However, we also utilise respected third party logistics contractors for delivering direct to customers in some instances.
We outsource some of our support services (e.g. IT support and Payroll Services) and we always use highly regarded service providers, with whom we largely have long standing working relationships.
Millbrook is working towards full transparency across all tiers of our supply chain to mitigate the risk of slavery and human trafficking within our business.
Our Policies
All personnel within Millbrook, its suppliers and contractors (existing and new), are briefed on this policy and our expectations of full compliance to the requirements set out in the Modern Slavery Act.
We are continuously developing our product and service offering, whilst being mindful of the UN Global four pillars which include; human rights, labour standards, environmental and anti-corruption standards.
To ensure we achieve this we have developed the following policies:
Bullying & Harassment Policy
Dignity at Work Policy
Equality & Diversity Policy
Whistleblowing Policy
Learning & Development Policy
Anti-Bribery Policy
Health & Safety Policy
Environmental Policy
These policies ensure robust procedures are in place within our organisation so the risk of modern slavery is minimal internally. However, we recognise the risk is far greater externally, within our supply chain. Therefore, we carry out assessments of these risks and put in place measures to reduce or eliminate them.
Risk Assessment
As an organisation we recognise there is a risk of modern slavery in any area of our business where there are high levels of the following in the countries/regions being dealt with:
Migrant labour (country to country or within a country)
High presence of refugees
Young workers and risk of child labour
Contract and agency workers
Female workers
To mitigate and reduce the risk to Millbrook, as far as is reasonably practical, we are implementing the following measures in relation to our supply chain:
Modern Slavery Risk Issue Steps to be taken Status
Migrant Labour Migrant workers paying recruitment fees may be trapped in bonded labour and be subjected to inferior employment terms.
Labour recruiters create an additional layer between employers and workers, leaving workers exposed to deceptive or coercive recruitment practices.
Migrant workers often do not understand their rights in the destination country and the terms of their employment.
Map and carry out a risk assessment of migrant labour across Millbrook’s Supply Chain.
Develop a Migrant and Contract Labour policy and share with our higher risk suppliers.
To be completed by End of March 2020.
Refugees Refugees are particularly vulnerable to human trafficking and forced, bonded and compulsory labour.
Refugees may not have access to legal means of employment, therefore increasing vulnerability.
Any supplier identified as having a relationship with any of the high-risk countries to develop, implement and confirm a robust approach to the eradication of exploitation of refugees. To be commenced by End of March 2020.
Young/Child Labour Children and young workers are more vulnerable to forms of modern slavery such as compulsory and forced labour as well as human trafficking.
Insufficient HR processes mean that young workers may be employed and enter the work place without enough checks to confirm their age, ability and safety in the work place.
Any supplier identified as having a relationship with any of the high-risk countries to develop, implement and confirm a robust approach to the eradication of exploitation of young/child labour. To be commenced by End of March 2020.
Contract & Agency Workers Contract workers are often less secure in their employment, may have less rights in the workplace and are therefore more vulnerable to exploitation.
Labour recruiters create an additional layer between employers and workers, leaving workers exposed to deceptive or coercive recruitment practices.
Review risk-assessment of supply chain to understand where key risks of contract and agency workers exist by region, product area and type of factory. To be commenced by End of March 2020.
Female Workers Women are particularly vulnerable to exploitation, human trafficking and bonded labour. Confirm with our supply chain what gender empowerment programmes they have in place. To be commenced by End of March 2020.
Supplier Awareness & Engagement Suppliers need to be aware of our commitment under this Policy and under the Modern Slavery Act and they need to be aware of their responsibilities.
Smaller companies and overseas companies pose a higher risk of lack of awareness.
Annually we will ensure all suppliers are fully aware of our commitment to removing risks of Modern Slavery from our supply chain and will raise their awareness of their responsibilities.
We will conduct an annual survey of our suppliers to ascertain their awareness and actions they are taking in relation to Modern Slavery.
To be completed by end of March 2020
Supplier Agreements Whilst we have a stable supplier base, we acknowledge there may be circumstances where our suppliers may need to review their resourcing from other countries. Once findings of the mapping are confirmed, consideration to be given to re-issuing of supplier agreements where required. To be commenced by End of March 2020.
Due Diligence
Manufacturing Location Risk Assessment
We are in the process of completing a full supplier risk assessment based on the original location of product manufacturing.
The assessment will provide an indication of the potential level of slavery exposure associated with that location and determine the level of visibility or additional control measures which will be required for further scrutiny.
Working With Our Suppliers and Maintaining Relationships
Our supply base is ever changing in line with current business needs, but we have had very long-standing relationships with many of our suppliers, with whom we share the same commitment to ensuring modern slavery does not exist within the supply chain.
We regularly communicate our business ethics with our suppliers and share with them our policies such as this one.
Our Directors and Senior Management teams regularly visit our major suppliers (especially those overseas where the risk is greater) and reviews of working practices are undertaken. During these visits, it is re-iterated that their support to adhering to the Modern Slavery Act is of paramount importance.
Employee Awareness and Training
We recognise the need to train our personnel and we have actively provided all personnel with an awareness and training of the Modern Slavery Act and have developed the training to provide direct access to supplementary training resources via a Learning Management System. In addition to this, when joining the business, all new employees will be required to undertake compulsory training modules which includes one that provides an awareness of the Modern Slavery Act and their responsibilities.
Whistleblowing
Millbrook has a Whistleblowing Policy which facilitates personnel to report any unethical practices in a confidential and structured manner and for those reports to be dealt with effectively.
Effectiveness
We will continue to monitor the effectiveness of this Policy on a regular basis, through supplier engagement and relationship management, as well as internal auditing. The speed and effectiveness of any corrective actions being taken because of issues raised is also key, along with a continued commitment to increasing awareness and training throughout all the supply chain.
Summary
We have identified clear next steps we need to take to confirm our full compliance with the requirements of the Modern Slavery Act and will continue to develop appropriate measures to ensure adherence throughout the supply chain and identify areas for improvement as appropriate.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of Directors. This policy constitutes as our Modern Slavery Statement for the financial year ending 30th June 2020.
