Modern Slavery Statement
Introduction
This statement sets out Gooch & Housego plc’s actions to identify potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business or its supply chains. As a global leader in photonics technologies, the organization takes a robust approach to slavery and human trafficking.
The organization is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Countries of operation and supply
The organization currently operates in the following countries:
- United Kingdom and United States (R&D, product design, manufacture and supply)
- G&H’s supply base operates out of Europe, North & South America and Asia.
- G&H requires its supplier to operate to a supplier code of conduct which specifies the minimum standards to which suppliers must operate under the terms of supply to G&H which include: no forced labor, no child labor, living wages paid, provision of safe working conditions, treating workers with dignity and respect, and acting ethically and within the law in their use of labor.
- G&H monitor compliances through its risk review process for suppliers.
High-risk activities
No activities are currently considered to be at high risk of slavery or human trafficking but the company will continuously review risk.
Responsibility
Responsibility for the organization’s anti-slavery activities is as follows:
- Policies: G&H Executive team are responsible for the approval and maintenance of this policy pertaining to Modern Slavery.
- Risk assessments: The CEO has overall responsibility, supported by Global Supply Chain, Human Resources and Global Quality.
- Investigations/due diligence: the Global supply chain function is responsible for due diligence on new suppliers. Depending on the nature of the incident or report of non-compliance, investigations will be conducted by Global Supply Chain, Human Resources and/or Global Quality.
- Training and Raising Awareness: The organization has run training sessions for relevant employees and appropriately publicizes these matters in its operations.
Relevant policies
The organization operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy: The Company encourages all its employees and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing policy is designed to make it easy for employees to make disclosures, without fear of retaliation. Full details of how to report a concern are available in Employee Handbooks, including who to contact in the event of any concern.
- Employee code of conduct: The organization’s code makes clear to employees the actions and behaviour expected of them when representing the organization. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
- Supplier code of conduct: The organisation is committed to ensuring that its suppliers adhere to the highest standards. Suppliers are required to demonstrate that they comply with these standards. G&H works with suppliers to ensure they meet the standards of the code. Serious violations of the organization’s supplier code of conduct will lead to the termination of the business relationship
- Recruitment/Agency workers policy: The organization uses only specified, reputable employment agencies to source labor and always verifies the practices of any new agency it is using before accepting workers from that agency. The following protocols are in place to minimize the risk of slavery and human trafficking in relation to agency workers:
UK: All agencies who supply agency staff operate to standards required by the Gangmasters Licensing Authority (GLA) and checks on agency licenses through the GLA are routinely undertaken.
US: Standard protocols are in place in compliance with State requirements.
- Sustainability Policy. All employment with G&H is voluntary. We do not use child or forced labor in any of our operations or facilities. We do not tolerate any form of unacceptable treatment of workers, including but not limited to the exploitation of children, physical punishment or abuse, or involuntary servitude. We fully respect all applicable laws establishing a minimum age for employment, in order to support the effective abolition of child labor.
- The organization undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organization’s due diligence and reviews include:
Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
Conducting supplier audits or assessments through the organisation’s own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified, as defined through the supply chain risk process;
Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans where necessary;
Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
A supplier manual has been developed and is on the group’s shared drives.
Refresher training for supply chain staff will be completed in June 2024.
Director sign off & Board approval
This statement was signed off by Charlie Peppiatt, Chief Executive Officer, on 29 May 2024 and subsequently approved by our Board of Directors in May 2024, who review and update it annually. It is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Gooch & Housego Plc’s slavery and human trafficking statement for the financial year ending 30th September, 2024.
