Modern Slavery Statement

A) ORGANISATION

This statement applies to Bartley Industries Ltd T/A Seddon Boxes (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year April 2021 – March 2022.

B) ORGANISATIONAL STRUCTURE

Bartley Industries Ltd T/A Seddon Boxes is a packaging and jigsaw puzzle manufacturer based at a single site in Kettering, Northamptonshire, UK. The Organisation is controlled by two Directors and employs circa 35 permanent employees. The labour supplied to the Organisation in pursuance of its operation is carried out solely in Kettering, Northamptonshire, UK.

C) DEFINITIONS

The Organisation considers that modern slavery encompasses:

Human trafficking;
Forced work, through mental or physical threat;
Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
Being dehumanised, treated as a commodity or being bought or sold as property;
Being physically constrained or to have restriction placed on freedom of movement.

D) COMMITMENT

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK.

E) SUPPLY CHAINS

In order to fulfil its activities, the Organisation’s main supply chains include those related to the supply of raw materials required to produce rigid boxes and jigsaw puzzles e.g., paper, cardboard, printed materials etc. It also includes logistical suppliers, and temporary labour. The Organisation’s supply base is largely within the UK, although some materials and parts are supplied by companies based in the EU. Very infrequently machines, or machine parts, are supplied from China. Suppliers are asked to complete a Self-Assessment Questionnaire and agree to a Supplier Code of Conduct, which covers core labour standards and allows the Organisation to audit suppliers against these standards and terminate any contracts if they are not met.

F) POTENTIAL EXPOSURE

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in the Far East where there may be limited protection against human rights and the provision of labour, however supply from this region is extremely limited and the suppliers are subject to due diligence and risk assessment checks.

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

G) STEPS

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

Reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
Measures in place to identify and assess the potential risks in its supply chains
Reviewing company policies and procedures

H) KEY PERFORMANCE INDICATORS

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

Adherence to the Supplier Code of Conduct
Maintenance of relevant up-to-date records
Staff training
Annual review of company policies and procedures
Records of complaints

I) POLICIES

The Organisation has the following policies which further define its stance on modern slavery:

Company ethical policy
Supplier Code of Conduct
Whistleblowing policy
Anti-bribery and corruption policy

J) TRAINING

The Organisation provides the following training to staff to effectively implement its stance on modern slavery:

Induction training
Training on company policies

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.