This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 and outlines the steps that Emtelle UK Ltd has taken and continues to take to ensure that modern slavery, child labour, or human trafficking is not occurring within our business or supply chains during the financial year 2023/2024.
Emtelle UK Ltd is a leading supplier to many global operators, known for our innovative, industry-leading pre-connectorised, blown fibre cable and ducted network solutions. We are a responsible and ethical employer with circa 800 directly employed employees across multiple manufacturing facilities, worldwide supplier and customer and have a code of conduct, business ethics policy and a sustainability vision and strategy, that delivers positive impacts economically, socially, and environmentally. We are committed to the elimination of Slavery in any form.
Although not defined in law The ILO (International Labour Organisation) defines Modern Slavery as the exploitation of a person where they cannot refuse or leave because of threats, violence, coercion, deception, and/or abuse of power.
The ILO defines Child Labour as ‘work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. It refers to work that is mentally, physically, socially or morally dangerous and harmful to children; and/or interferes with their schooling by: depriving them of the opportunity to attend school; obliging them to leave school prematurely; or requiring them to attempt to combine school attendance with excessively long and heavy work.
We have reviewed our recruitment practices and provided Front-Line Leader training on all aspects of due diligence in recruiting. In addition our HR Team have been trained to ensure face-to-face verification of original right-to-work documents, including how to identify fraudulent submissions, and we have implemented an annual right-to-work check.
Our updated Personal Details Form now includes bank account details, with expectations that these match the employee’s full name. We conduct manual verbal checks to identify and investigate any discrepancies. New start bank details and any changes are always checked verbally as a secondary check.
Our Senior Management Team, site managers, all recruiting managers and HR were invited to attend an education session with Scotland Against Modern Slavery where they were educated around the red flags to look for in both our workforce and supply chain. This was further enhanced with more guidance for our purchasing and supply chain team on the 7th of June 2024.
Emtelle is an equal opportunities employer and does not discriminate treatment between local and migrant employees. Emtelle has a stable workforce and enjoys high levels of employee retention, engagement, and development. We expect all our employees to operate in line with our Code of Conduct which requires employees to treat other people with respect and to comply with all laws and regulations.
The HR Team have been working closely with our local labour providers to ensure that Agency Worker Regulations and best practice is also maintained by our supply chain. We have reviewed the agencies in use and will continue to do so on an annual basis.
In this last year, our Wellbeing Ambassadors have rebranded to W.E. at Emtelle which is focused on Wellbeing and Engagement and raises awareness of the importance of looking after both self and others. This would hopefully help highlight any issues identified early. Emtelle look forward to reporting on progress next year.
We also have an EAP Scheme and a new Global Whistle Blowing Policy under which employees are encouraged to confidentially seek advice and report any suspected wrongdoing.
We are also committed to creating ‘the Emtelle Way’ through living our Values at Emtelle and ensuring the best experience for our business.
We have achieved various levels of Ecovadis Accreditation and have a live Sustainability Strategy requiring compliance with all applicable laws. Our suppliers must treat all their employees with respect, pay them a fair wage and comply with all local, national, and international legislation concerning working conditions, working age requirements, and any other relevant legislation.
Before engaging a new supplier, we complete due diligence on any potential supplier including health, safety, environmental and labour practices and will not engage with organisation’s who fall below the Group’s required standards. Our procurement processes contractually require our contractors and consultants to make a declaration of intent and comply with antislavery laws and notify us of any actual or potential breaches. As part of ensuring that there is no slavery in the supply chain suppliers must be able to demonstrate compliance with this policy. Emtelle UK Limited retain the right to audit our suppliers at any time at their discretion.
Emtelle is fully committed to preventing modern slavery and human trafficking in our supply chains and business. This statement reflects our commitment to ethical business relationships and effective systems to ensure no slavery or trafficking in our supply chains. To date, no issues have been identified.
We will apply due diligence processes across the supply chain to prevent modern slavery, human trafficking and child exploitation. Our assessment will include Identifying and assessing potential risk areas in our supply chains then Monitoring any potential high-risk areas in our supply chains and educating our workforce and supply chain that we will always protect whistle blowers.
Our supplier audit returns are monitored for red flags or risks identified. Our supply chain monitoring activities currently do not extend below the tier one supply base, we expect and rely on our supplier to monitor their supply base for compliance against our supply chain policies.
We are committed to preventing child labour exploitation in our business and supply chains. We commit to:
HR will play a key role in checking right to work documentation to ensure employees are of the appropriate age. In 2023, no Slavery issues related to operations, or the supply chain were reported.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Emtelle UK Ltd.’s Modern Slavery, Human trafficking, & Child Labour statement for the financial year ending April 2024. I confirm this is a true and accurate account of Emtelle UK Ltd.’s commitment and position.
Tony Rogers
Group Chief Executive Officer
Emtelle UK Ltd
03/06/2024
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Emtelle UK Limited
Haughhead
Hawick TD9 8LF
Scotland
© EMTELLE 2024
