Modern Slavery Act
Policy Statement – CLM Group
CLM Group recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Following the implementation of the Modern Slavery Act 2015, CLM Group and all subsidiaries is committed to maintaining and enforcing effective systems and controls to prevent slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking. Modern slavery is criminal activity and a violation of human rights. The deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain is unacceptable. CLM Group has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls, to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. CLM Group commits to taking all necessary steps to ensure the workforce we and our suppliers engage is free from effects associated with modern slavery, human trafficking, forced our bonded/imprisoned labour. CLM Group will conduct right to work checks on every employee within its employment at induction. We expect all our supply chain to perform the same checks in accordance with the Immigration, Asylum and Nationality Act 2006. This policy applies to all members, employees, agents, consultants and those parties in our supply chain, wherever in the world they operate. Any reported breach of this policy will be investigated and may lead to legal proceeding or disciplinary action, which subsequently could result in employee dismissal.
Due diligence processes and remediation processes: Our Procurement Team is responsible for the topic of supplier sustainability for direct materials. The function is responsible for ensuring that processes for supplier selection and supplier relationship management exist and are adhered to.
CLM Group and all subsidiaries are vigilant to ensure our business and supply chains are free of slavery, operate with integrity and in line with CLM’s corporate values and Code of Conduct. Since 2020, we have formally required each of our direct suppliers to commit to compliance with our Code of Conduct for Suppliers as well as pass a rigorous pre-qualification process. Both the Code of Conduct for Suppliers and the PQQ must be contractually agreed to before we embark on a business relationship. Alternatively, suppliers may have their own established principles or codes that meet our requirements. These include principles against bribery, corruption and the violation of human rights, and in favour of humane working conditions and minimum wages, as well as the correct handling of hazardous substances and environmental protection. In terms of specific human rights, our suppliers commit, for example, to eschew slave labour, servitude, forced or compulsory labour and human trafficking, to pay minimum wages and not to make use of child labour.
The CLM Group Code of Conduct, specifically the sections on human rights and the environment, as well as our Anti-Bribery Policy, must be obeyed when sourcing decisions are taken. Suppliers can expect CLM to abide by and actively live by the core values set out in its Code of Conduct which is mandatory for all CLM employees. Vice versa, CLM expects suppliers to abide by all applicable national and international laws and regulations as well as by the requirements of the Code of Conduct for Suppliers.
CLM Group ensures all employees involved in Hiring or People Management complete mandatory Modern Slavery Training.