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Modern Slavery

Modern Slavery

This policy and the statement contained within it has been written to confirm Nationwide Windows Ltd (NWW) understanding of The Modern Slavery Act and our commitment to prevent ‘slavery servitude and forced or compulsory labour’ and ‘human trafficking’ within the scope of our business.

Slavery and Human Trafficking Statement;

Business overview;
Nationwide Windows Ltd manufactures, supply’s and installs windows, doors, conservatories and curtain walling. The main sectors that the business operates are local authority, new build and domestic.

NWW manufacturing facility and head office are based in Rugby, Warwickshire, in addition to this there are regional depots situated throughout the UK.

All NWW supply chain partners either are, or have UK based offices, no items are procured directly from abroad.

Commencing of the statement;
Whilst it is not a mandatory requirement under the act for NWW to have a documented policy/ statement on Modern Slavery. NWW is committed to the prevention of Modern Slavery and wants to demonstrate a clear commitment to our stakeholders and other interested parties.

The requirement to generate and issue a statement is for businesses with an annual turnover of E36m or more.

High risk areas;

  • Recruitment
  • Materials procurement (supply chain)
  • Appointment of bona-fide contractors

The above detailed have been identified as being the areas of the business where Modern Slavery are considered to be most high risk.

Due diligence checks;
Below set out the controls implemented and planned to mitigate the risk of Modern Slavery occurring within the high risk areas identified;

Recruitment; checks are undertaken on potential new recruits to ensure that they are eligible to work in the and that their identity is validated. Where employment agency services are utilised, the same checks and balances are implemented.

Material procurement (supply chain) & appointment of bona-fide contractors; there aren’t currently any processes implemented to check for compliance. However for both of the aforementioned NWW does have applicable policies.

One of this statements aims is to implement suitable processes to affirm Suppliers/ Contractors understanding of the act and that suitable controls are implemented.

  • Revise relevant questionnaires to include checks/ confirmation of understanding of the act

Applicable polices that have relevance to Modern Slavery;

  • Modern Slavery
  • Recruitment
  • New Supplier
  • Whistleblowing
  • Code of Conduct

All of the above mentioned are either individual policies or are contained within the Companies Handbook.

Training/ communication;
NWW are committed to training all relevant personnel on;

  • This policy/ statement
  • Key indicators that someone may be subject to ‘slavery servitude, forced or compulsory labour’ and ‘human trafficking’
  • How to report any concerns internally within the business or to a regulatory body

How will the training be disseminated?

  • On induction/ retraining
  • Via toolbox talks
  • Posters

Performance indicators;
Compliance will be checked by undertaking internal audits, the results of which are communicated as part of the management review process contained within the businesses integrated management systems to senior management.

Reporting concerns;
Where anyone has concerns regarding ‘slavery servitude and forced or compulsory labour’ and ‘human trafficking’ please report;

  • Internally; to HR, or the Compliance department
  • Externally;
    • Modern Slavery -Phone no; 0800 0121 700
    • Trafficker or illegal gangmaster— Phone no; 101

This policy and statement is authorised by and has the full commitment of the board of Directors and is confirmed by the signature of the Managing Director which appears hereunder. This policy will be reviewed as a minimum annually.

Signed: Mr John Whalley, Managing Director
Date: 16/03/18

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74-88 Somers Road Rugby,
CV22 7DH

Phone: 01788 224 466

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