Modern slavery & human trafficking

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 53(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activites for the financial year ending 31 Dec 2022.
Nicholson STS Ltd (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, supply chain and it’s products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational structure

Nicholson STS Ltd has business operations within the United Kingdom. We operate in the construction sector supplying specialist products to contractors and resellers. We work closely with a number of selected supply chain partners who supply goods and services th enable us to fulfil our product offering to the market.

More information on our products can be found on our website www.nicholsonsts.com

Policies

We operate the following internal polices to ensure that we are conducting business in an ethical and transparent manner

Supplier code of conduct

We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they operate and to seek similar commitments across their supply chain.

Procurement policy

We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and checks undertaken to help verify this.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking in our supply chain, we have adopted internal supplier audits as a due diligence procedure. This is carried out by sending a questionnaire to our suppliers which is aimed identifying, monitoring and reducing any potential risks in our business or supply chain.

Risk and compliance

The company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in it’s supply chain through

  • Evaluating the slavery and human trafficking risks of each new supplier
  • Creating an annual risk profile for key suppliers
  • Reviewing on a regular basis all aspects of the supply chain through supply chain mapping.

We do not consider that we operate in a high risk environment because the majority of our supply chain is located within the UK. Only a very small amount of labour involved in the producing the products we supply is done externally and where this does happen it is monitored.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

Effectiveness

The Company uses KPI’s to measure it’s effectiveness and ensure slavery and human trafficking is not taking place in it’s business and supply chains. These KPI’s are as follows;

  • We will contact suppliers about their modern slavery practices every 12 months
  • We will train our staff about modern slavery issues and increase awareness within the Company
  • We will carry out a Supplier questionnaire update on the issue of modern slavery every 12 months
Training

The company requires it’s key staff to complete training and ongoing refresher courses on slavery and human trafficking.

This statement was approved by the Board of Directors

Paul Boyt, Managing Director, Nicholson STS Ltd