Modern Slavery Act Statement
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Britax Group Limited and other relevant companies controlled by it (the “Group”), to prevent modern slavery and human trafficking in its business and supply chain. This statement constitutes the Group’s slavery and human trafficking statement for the financial year ending 31 December 2020.
Slavery, servitude, forced labour and human trafficking (“Modern Slavery”) are global issues. We are committed to ensuring that there is no Modern Slavery in our supply chains or in any part of our business. We act ethically and with integrity in our business relationships and in developing, implementing and enforcing systems and controls to ensure Modern Slavery is not taking place anywhere in our supply chains.
Our business & supply chains
We are a global manufacturer and distributor of children’s car seats, strollers, bicycle seats, nursery products and related accessories. Our parent company as at 31 December 2020 was Persimmon Midco LLC, a Delaware limited liability company, with its head office in South Carolina. As at 31 December 2020, the Group had 938 employees worldwide and carried out manufacturing operations in the UK, USA, Germany and China with sales and marketing operations in North America, South America, Europe, Asia, Australia and New Zealand. The Group’s global annual turnover during the year to 31 December 2020 was (subject to audit) approximately €294.4m. We are organised in regional business units (Americas, EMEA and Asia-Pacific regions) and our supply chains include raw materials suppliers and contract manufacturers.
Policies, Contractual Controls & Commitment
We are committed to ensuring that there is no Modern Slavery in our supply chains or in any part of our business. We act ethically and with integrity in our business relationships and in implementing and enforcing systems and controls to ensure Modern Slavery is not taking place anywhere in our supply chain.
Under our global and regional codes of conduct we:
• respect and obey the laws, rules and regulations which apply to our businesses around the world;
• respect human rights and require our supply chain to do the same;
• compete ethically; and
• respect fair employment practices.
We also operate a whistleblowing policy which provides a framework within which individuals can openly or anonymously report any ethical concerns, including issues in connection with Modern Slavery. Any issues raised are handled at a senior level, brought to the attention of the board of directors and thoroughly investigated. Any necessary actions are taken. The anonymity of whistle-blowers is protected.
Due diligence processes in relation to Modern Slavery
We operate a supply chain which includes suppliers we have worked with, visited and inspected over several years. We know that Modern Slavery can be most prevalent in the parts of a supply chain operating in certain high risk geographic areas and among vulnerable groups. Therefore, before new suppliers are added, we carry out an approval and accreditation process. A key area of this process, before approving and adding any new supplier to our supply chains, involves an assessment of that supplier’s labour practices, including practices in relation to child or forced labour, payment of a minimum wage, employee working environments and protection against discrimination.
We have in place and/or are continuing to develop further systems to identify and assess potential risk areas in our supply chains, mitigate the risk of Modern Slavery occurring in our supply chains and monitor potential risk areas. During 2020, the global Britax business joined Sedex, one of the world’s leading ethical trade membership organisations, working with businesses to improve working conditions in global supply chains. Implementation of the Sedex platform should be completed during 2021. Sedex membership should help to further enhance our due diligence process.
Also, during 2020, as part of the Group’s ongoing employee training programme, the Group procured new employee training courses including specific courses covering the Modern Slavery Act 2015, practical steps for procurement teams and raising of awareness of Modern Slavery risks and issues. All applicable employees should complete this training, on a compulsory basis, during 2021. Enhanced employee awareness and training should help to further enhance our due diligence process and the effectiveness of our Modern Slavery measures.
We continue to review contractual arrangements and develop strategic business relationships with suppliers in key parts of our supply chains to help ensure that necessary standards are in place, and maintained, to prevent Modern Slavery in our supply chains.
Supplier adherence to our values & ethics
We have zero tolerance to Modern Slavery. As part of the steps taken to ensure all those in our supply chains and our contractors comply with our values and ethics we continue to operate a supply chain compliance programme. This includes visits by sourcing, quality and engineering teams, a periodic scorecard process and periodic visits by the Group’s general counsel. However, as a result of the global COVID-19 pandemic and travel and other restrictions, intended to limit the spread of the virus, imposed by governments around the world, periodic visits were suspended during 2020 and our ability to further develop our supply chain was adversely affected.
Our effectiveness in combating Modern Slavery
In order to assess the effectiveness of our Modern Slavery measures we review the following key performance indicators:
• the results of our supply chain compliance programme;
• the number of Modern Slavery allegations reported or uncovered in the supply chain; and
• staff training levels.
Sedex membership, as outlined above, should help to further enhance our effectiveness.
We continue to periodically review the effectiveness of existing steps we have taken with a view to maintaining and further improving our effectiveness in assessing and addressing issues and risks which are relevant to the prevention of Modern Slavery in our business and supply chains.
This will continue during 2021.This statement was approved by the board of directors of Britax Group Limited on 29 June 2021 and will be reviewed and updated annually.
30 June 2021
Chief Executive Officer
Britax Group Limited