Modern Slavery

CMS Group is a trading name of CMS Enviro Systems Ltd

Modern Slavery Statement

Financial year ending March 2020

 

Introduction

This statement sets out the actions CMS Enviro System Ltd (the Company) has taken 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. This statement relates to actions and activities during the financial year 1 April 2019 to 31 March 2020.

The Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking and 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.

 

Company structure and supply chains

CMS Enviro Systems Ltd is an industry leading building envelope provider specialising in the design, manufacture, installation and aftercare of aluminium façades and PVCu windows, doors and curtain walling.  At CMS Enviro Systems Ltd we have over 250 employees and operate throughout the United Kingdom. Our Head Office and main manufacturing site is located in Castlecary, Cumbernauld. We have an additional factory in East Kilbride and a regional site in Kirkcaldy.

To find out more about the nature of our business, please visit our website at www.thecmsgroup.com.

Our supply chains include the following:

  • Subcontractors;
  • Recruitment/labour agencies;
  • Suppliers of goods, services and materials

 

Relevant policies

The Company 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 workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Supplier code of conduct: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the Company’s supplier code of conduct will lead to the termination of the business relationship.
  • Recruitment/Agency Workers: The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
  • Anti-Bribery & Corruption Policy: The Company is committed to preventing and prohibiting bribery and corruption in all areas of the Company, including our supply chain.
  • Equal Opportunities Policy: The Company is committed to equal opportunities and the avoidance of discrimination in all our working practices.
  • Working Time Guidelines: The Company ensures our workers are not subjected to excessive working hours, overtime/night shift working is optional and encourages work/life balance.

 

Due diligence

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • conducting supplier audits, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular participation in “Stronger together” or “Ethical trading” initiatives;
  • using an ethical supplier database, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
  • 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.

 

Performance indicators

CMS Enviro Systems Ltd has reviewed its key performance indicators (KPIs). As a result, the Company:

  • required supply chain employees and HR professionals to have completed training on modern slavery by March 2020.
  • developed a system for supply chain verification, whereby the Company evaluates potential suppliers before they enter the supply chain.
  • reviewed its existing supply chains and has evaluated all existing suppliers.

 

Training

The Company’s modern slavery training covers:

  • our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the Company;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
  • what steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company’s supply chains.

 

Awareness-raising programme

As well as training staff, the Company raises awareness of modern slavery issues by putting up posters across the Company’s premises and circulating emails to staff.

The posters and emails explain to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Company; and
  • what external help is available, for example through the Modern Slavery Helpline.

 

Board approval

This statement was approved on 09 November 2020 by CMS Enviro Systems Ltd’s board of directors who review and update it annually.

 

Signed:                                                             Date: 09 November 2020

Stephen Anderson, Joint MD

 

Signed:                                                             Date: 09 November 2020

Martin McCrimmon, Joint MD