Modern Slavery Statement
Introduction
This statement sets out Gooch & Housego plc’s actions to understand all 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 and its supply chains.
As a global leader in Photonics technologies, the organization recognizes that it has a responsibility to take 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.
Organizational structure and supply chains
Gooch & Housego (G&H) research and manufacture in twelve sites across the USA, UK and China and are experts across a broad range of photonic technologies which, when combined with the company’s optical, mechanical, electronic and software design capabilities, also enable the supply of complete optical system design services.
Its products are deployed across a broad range of applications in Industrial, Aerospace & Defense, Life Sciences markets as well as Scientific Research.
Countries of operation and supply
The organization operates in the following countries:
- United Kingdom, United States and China ( 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 suppliers to work to a code of conduct, which requires the following: no forced labor, no child labor, living wages paid, provision of safe working conditions where necessary, workers are treated with dignity and respect, and suppliers must act ethically and within the law in their use of labor.
- G&H monitors compliance 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 initiatives is as follows:
- Policies: G&H Executive team are responsible for the approval and maintenance of the Group’s Modern Slavery policy.
- Risk assessments: The Group’s Chief Operating Officer has overall responsibility, supported by Global Supply Chain, Human Resources and Global Quality.
- Investigations/due diligence: The Group’s Global Supply Chain function are responsible for Due Diligence investigations of new suppliers. Any reports of potential non-compliance with Group policies and the Supplier Code of Conduct are investigated by Global Supply Chain, Human Resources and/or Global Quality.
- Training and Raising Awareness: The organization plans to run training sessions for relevant employees and regularly communicates risks associated with this area.
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 organization. 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 are accessible 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 behavior expected of them when representing the organization. The organization strives to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing its supply chain.
- Supplier code of conduct: The organization is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they comply to these standards. Gooch & Housego will work with suppliers to ensure that they meet the standards of the code. However, 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.
◦ China : a protocol is being developed for completion by July, 2019 - 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.
