Modern Slavery Act

INTRODUCTION
We, Survitec Group, are proud of the steps we take to combat slavery and human trafficking and are committed to improving our practices going forward. We have a zero tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and improving effective systems, controls and practices to ensure modern slavery is not taking place in our supply chains.
We are also committed to ensuring there is transparency in our own business. We believethat for people to excel, they must feel valued and included. We make certain that everyone is treated fairly, honestly and respectfully, and we expect the same standards from all our contractors, suppliers, third parties and other business partners.


OUR BUSINESS
We are a global leader in survival and safety solutions to the marine, defence, aviation and energy markets. We have around 3000 employees worldwide, covering 8 manufacturing facilities, 15 offshore support centres and over 50 owned service stations. We are further supported by a network of over 500 third party service stations and distributors. We are a class-approved service provider with ISO 9001 certification, the international standard for quality management systems.
Throughout its 160-year+ history, Survitec has remained at the forefront of innovation, design and application engineering and is the trusted name when it comes to critical global safety and survival solutions.


OUR STRUCTURE
Our business comprises the parent company, Survitec Group Limited, along with numerous subsidiary companies operating worldwide. Survitec Group Limited’s head office is in the United Kingdom.
This statement applies to Survitec Group Limited and its subsidiaries as set out above.

 

OUR SUPPLY CHAINS
Our supply chain includes the manufacture, sourcing, procurement and delivery of raw materials, components, finished products and related servicing of life saving equipment for end customers who are principally in the marine, defence, aviation and energy markets. 
We buy from approximately 7000 suppliers in 70 countries. These suppliers are largely based in countries with a lower risk of modern slavery.
To mitigate against modern slavery risks we audit our Suppliers and ask them to comply with our Responsible Sourcing Policy.


OUR POLICIES
We strive to act ethically and with integrity in our business relationships and we expect high standards from our employees as well as our contractors, suppliers, third parties and other business partners. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have in place certain policies that aim to encourage and develop these standards of behaviour.


Code of Business Conduct & Ethics
Our Code of Business Conduct & Ethics sets the standard for how we operate our business and how our staff conduct themselves with the highest levels of integrity, honesty, ethical conduct and compliance with the law. It aligns with and reflects our core Values – Safety, Customers, People, Excellence, Innovation and Integrity.


Responsible Sourcing Policy
Our Responsible Sourcing Policy reflects our commitment to acting ethically and with integrity in our business relationships. The policy is provided to suppliers who are requested to sign up to the policy as well as the principles and standards contained therein.
The policy underlines the commitment that business should be conducted lawfully and ethically. It outlines the principles that work should be conducted on a voluntary basis and that workers should be treated with respect and dignity. In particular, the policy makes clear that slavery and human trafficking in any form should not be taking place in supply chains. All Survitec Group directors have been briefed on our Responsible Sourcing Policy and the policy specifically refers to the need for transparency in approaching issues of modern slavery as well as suppliers' disclosure obligations under the Modern Slavery Act
2015.
No instances of non-compliance with the Group’s Modern Slavery policies have been identified to date.

 

Modern Slavery Policy
Our Modern Slavery Policy communicates our zero-tolerance approach to modern slavery and that we are committed to acting ethically and with integrity in all our business dealings and relationships. It outlines our commitment to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our business or supply chain.
The Policy applies to all our employees, contract workers, officers and directors. It also applies to individuals, companies, associations, partnerships, or other entities retained to act on our behalf of or for our benefit, and includes, but is not limited to, consultants, representatives, agents, brokers, lobbyists, distributors, and resellers.
The policy encourages employees to report any actual or potential violations of law, regulations or the policy of which they become aware. There is a Survitec Hotline whereby employees can report concerns anonymously and, if employees have any concerns relating to slavery, they can report these concerns via this route.


DUE DILIGENCE PROCEDURES
Each supplier who does business with us should sign our Responsible Sourcing Policy which confirms the supplier will uphold certain prescribed standards concerning human rights, labour, health and safety, environmental, and business ethics practices.
We aim to only engage with third parties who uphold our Values and the principles of this Policy. Where we enter into an arrangement with a third party and where such third party does not have its own policy concerning compliance with modern slavery legislation, then we shall ensure that the third party’s adherence to our Modern Slavery Policy is a term of the agreement.


KEY PERFORMANCE INDICATORS
We will continue to monitor the following key performance indicators to assess how effective we have been in ensuring slavery and human trafficking is not taking place in any part of our business or supply chain including the following:

  • Continuing to strengthen our risk assessment and due diligence processes for the onboarding of suppliers and customers;
  • Seeking to verify information about the country of origin of sourcing inputs in our supply chain;
  • Arranging audits and inspections of our suppliers where appropriate;
  • Continuing to include language with respect to compliance with anti-slavery and human trafficking laws and policies in all new supplier and all new third-party contracts;
  • Ensuring that all new employees are aware of our Modern Slavery Policy.

 

FUTURE STEPS
We aim to deliver refresher training on our Modern Slavery Policy to all relevant
employees in 2021. This will include, but will not be limited to, the Modern Slavery Act 2015 and shall cover:

  • Provisions of the Modern Slavery Act 2015;
  • 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; and
  • What external help is available, for example through the Modern Slavery Helpline.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2021.