Chillflow Solutions Australia

Modern Slavery Act

Introduction  

This statement sets out Chillflow Solution’s Australia Pty Ltd 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. This statement relates to actions and activities during the corresponding financial year.

As part of delivering servicing and engineering works to industrial chilled/ refrigerated, catering and compressed air plant, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation 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.

Organisational structure and supply chains

This statement covers the activities of Chillflow Solutions Australia:

  • Delivering servicing and engineering works to industrial chilled/ refrigerated, catering and compressed air plant and the ordering of spares and units from associated providers.

The organisation currently operates in the following countries:

  • Southwest UK and Australia; attendance to service and repair industrial chilled water plant, refrigeration systems, catering equipment and compressed air systems – marine and land based.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

High-risk activities:

We do not believe any of Chillflow Solutions Australia activities to be at risk of slavery or human trafficking:

  • Policies: The Executive Team is responsible for ensuring that all staff adhere to policy and are informed of the Group’s position regarding slavery and human trafficking. The Organisational Development department is responsible for updating the aforementioned policy and for the review and monitoring of this, in conjunction with the Executive Team.

Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: The Executive Team is responsible for ensuring that all staff adhere to policy and are informed of the Group’s position regarding slavery and human trafficking. The Organisational Development department is responsible for updating the aforementioned policy and for the review and monitoring of this, in conjunction with the Executive Team
  • Risk assessments: We require all senior managers to carry out risk assessments of their services to determine our risk exposure. We update our risk register to ensure that any risks are appropriately flagged, mitigated and monitored
  • Investigations/due diligence: The Executive Team will be responsible for ensuring that the appropriate individuals are assigned for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
  • Training:  The organisation will ensure that training takes place either directly within the company, or with suppliers and others, to better understand and respond to the identified slavery and human trafficking risks.
  • Relevant policies: The organisation 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 organisation encourages all its workers, customers 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 organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can [use our confidential helpline/complete our confidential disclosure form].

  • Employee code of conduct: The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier/ Procurement code of conduct: The organisation 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 organisation 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 organisation’s supplier code of  conduct will lead to the termination of the business relationship
  • Recruitment/ selection policy: The organisation 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.

Due diligence

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

  • evaluating the modern slavery and human trafficking risks of each new supplier
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2018. As a result, the organisation is:

  • requiring all staff to complete training on modern slavery
  • developing a system for supply chain verification whereby the organisation evaluates potential suppliers before they enter the supply chain
  • reviewing its existing supply chains, whereby the organisation evaluates all existing suppliers.

Training

The organisation requires all staff within the organisation to complete training on modern
slavery.

The organisation’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 organisation;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness-raising programme

As well as training staff, the organisation will raise awareness of modern slavery issues by distributing any updated information to staff relating to:

  • the basic principles of the Modern Slavery Act 2018;
  • 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 organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.

 Approval

  • This statement has been approved by a Chillflow Solutions’ Director, who will review and update it annually.