Modern Slavery And Human Trafficking Policy
Modern Slavery is a real and growing problem throughout the world—including in all areas where USL is actively engaged in business. It exists in many forms, including forced labour, involuntary servitude, debt bondage, human trafficking, and child labour. USL Group (“USL”, “irs”, “we”, or “our”) takes its responsibility to remain alert to the risks posed by this modern day blight very seriously and we are committed to driving out any acts of slavery and human trafficking within our business and that from within our supply chains, including sub-contractors, partners and vendors.
Modern Slavery is recognized as a major problem in most countries, and each country often has protective legislation aimed at eradicating the problem. Examples include the Modern Slavery Act 2015 (as amended from time to time) in the UK, and California’s Transparency in Supply Chains Act of 2010. Even where legislation does not yet exist, we recognize that we have an ethical duty to be vigilant and act responsibly by pursuing a zero-tolerance policy towards acts of Slavery and Human Trafficking.
We acknowledge our responsibilities and will ensure transparency throughout USL and with suppliers of goods and services to USL and its operating divisions, USL Ekspan, Pmb International, Applied Polymerics Inc, Logiball Inc, Fibrecrete Preservation Technologies Inc, Prime Resins Inc, Nufins, and Fibergrid Limited.
Modern slavery is a criminal offence under the various legislations. As outlined above, modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Consistent with the values and expectations of the Code of Business Conduct (Values & Expectations of 168 (2018 revision)) of our ultimate parent, RPM International Inc., this document sets out the Policy of USL with the aim of the prevention of opportunities for modern slavery to occur within its business or supply chain. This Policy’s use of the term “modern slavery” has the meaning given in the Modern Slavery Act from the UK.
Imported goods from sources outside the US, Canada, UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored. USL will not support or deal with any business knowingly involved in slavery or human trafficking of any kind. USL’s Directors and senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (e.g., personnel, training, financial investment etc.) to ensure that slavery and human trafficking is not taking place within the USL Group nor within its supply chain.
As part of the company’s third party due diligence processes (see USL Group Third Party Due Diligence Policy as amended) with reference to slavery and human trafficking, the supplier approval process will incorporate a review of the controls undertaken by all suppliers.
This policy sets forth those practices and gives insight into the supply chain and business processes of the company.
Any concerns from any member of staff regarding a likely risk of, or actual, breach of our policy or the legislation must be raised to our Compliance Officer at the earliest opportunity.
Responsibility
Our Human Resources Managers in the UK and USA will liaise with relevant departments such as that of Quality, Environmental, Safety and Training Department (QEST) and the Legal/Compliance Department to ensure that risk analysis and investigations/due diligence in relation to modern slavery and human trafficking is carried out as required.
The Human Resources and Legal/Compliance Department will ensure that employees are given adequate and regular training on the issue of modern slavery so that everyone understands and complies with this Policy.
Due Diligence Processes For Slavery and Human Trafficking
Forming part of our initiative to identify and mitigate risk we have in place systems to identify and assess potential risk areas in our supply chain. In addition USL’s Whistleblower Policy through the RPM Hotline encourages all of its workers, customers and other business partners to report any concerns related to the direct activities of the organisation or its supply chain without any retaliation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
USL’s Whistleblower Policy is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees who have concerns can refer to the Whistleblower Policy, which is available on the Company intranet. The nature of the complaint will determine the next course of action.
We endeavour to carry-out our own recruitment activities and/or to only use reputable employment agencies to source labour and complete appropriate background checks. Personnel responsible for the recruitment activities in any of our business divisions are advised to adhere to this Policy by ensuring that strict verification of the potential employee’s right to work is carried-out before any offer of employment is made.
USL Group expects its subsidiaries, sub-contractors and supply chain vendors to adhere to recruitment practices that ensure that all terms of employment are voluntary. Where necessary and if required, we may request demonstration of compliance with this Policy.
Supply Chain
USL has a long history of working with partner organisations and associates. Our business operating model relies on an integrated and seamless service to clients, regardless of which mix of resources is delivering the service. Our supply chain includes the sourcing of raw materials principally relevant to the manufacture, supply and installation of specialist construction products including bridge expansion joints, bridge deck waterproofing membranes, Polyurethane Grouts, Protective coatings and concrete repair mortars.
Our supply chain is underpinned by a rigorous contractual process which means that every Sub-contracted Partner has the appropriate Partner Agreement in place.
All Sub-contractors have a distinct obligation to comply with our Anti-Slavery and Human Trafficking Policy.
Supplier Adherence To Our Values And Ethics
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have audit rights built into our Partner and Associate Contracts.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, training will be provided to our staff. We also require our partners to provide training to their staff and suppliers and providers in their respective supply chain.
Awareness & Performance Indicators
As well as training employees, we will raise awareness of modern slavery issues by displaying this Policy on QEST Notice boards and via the intranet. USL will strive to ensure that all of its employees will be as well-informed as possible regarding this Policy.
Our policy on modern slavery will be communicated to all suppliers, Sub-contractors, vendors and other business partners at appropriate points during our business relationship with them and reinforced as appropriate thereafter.
Whilst this policy is appropriate for use in our Worldwide operations, this statement is made pursuant to section 54(1) of the UK’s Modern Slavery Act 2015 (as may be amended from time to time) and constitutes our slavery and human trafficking statement for the financial year ending 31st May 2021.
Signed on behalf of the USL Group Board of Directors.
Date: 28th September 2021
Group Finance Director: Kelly Hewitson