Modern Slavery and Human Trafficking Statement

PHD Industrial Holdings Ltd (‘us’ or ‘we’ or ‘PHDIH’) has a zero-tolerance approach to any form of modern slavery, which we consider includes different types of exploitation such as forced labour, servitude, child labour and human trafficking. We are committed to acting in an ethical manner and with integrity and transparency in all our business dealings.

This statement has been created in compliance with the provisions of the Modern Slavery Act 2015 and has been approved by our Board of Directors and constitutes our modern slavery and human trafficking statement for the financial year ending 30th September 2021.

Our business and group structure

We are a UK-based acquisitive Group investing primarily in the UK SME sector. PHDIH group employs over 330 people located throughout the United Kingdom. We exercise significant influence and control over our group operations and have taken steps to educate and encourage awareness of slavery and trafficking within our group. We are committed to ensuring that all of our business dealings are carried out in full compliance with relevant laws and, in doing so, we endorse the implementation and promotion of ethical business practices to protect workers from being abused and exploited within our group and its supply chains.

As PHDIH Group businesses comprise separate small legal entities, this statement applies only to PHD Industrial Holdings Ltd (Company No. 13227041, with its registered office at 7400 Daresbury Park, Daresbury, Warrington WA4 4BS) and all steps taken in this statement are taken by PHDIH for our itself. Our group businesses are encouraged to consider publishing their own modern slavery statements, even where they fall below the legal turnover threshold.

Our policies

Recruitment policy. We conduct right to work checks for all our employees to safeguard against human trafficking or individuals being forced to work against their will.

Employee Handbook. We include, among other things, policies on diversity, health and safety, the environment, anti-bribery and corruption, grievance procedures and whistleblowing. In particular, our whistleblowing policy ensures that all employees know that they can raise any concerns that they may have without fear of reprisals.

Our supply chains

The activities that we engage in at our registered office and principal place of business are primarily focused on providing business support, accounting and corporate finance services and do not directly involve a supply chain. We regularly outsource legal services, taxation advisory services, financial due diligence services, insurance services, IT hardware and software application services, office cleaning services, waste management services, confidential document disposal services and facilities management services. Groupwide procurement is not a centralised function carried out at our registered office as supply chains are generally managed and monitored by our Group businesses themselves.

Managing risk

We are committed to preventing acts of modern slavery and human trafficking in any part of our business. We encourage our employees to report any concerns relating to unlawful conduct, malpractice, dangers to the public, or to the environment, and any other matter of a serious nature. Our aim is to act ethically and with integrity in all our business relationships and to implement and enforce effective due diligence in compliance with all areas of the Modern Slavery Act 2015.

Due diligence processes

We monitor areas of the business that we believe carry the highest susceptibility to the risk of employing slave or trafficked labour. This includes monitoring roles where low-skilled labour is required.
Our group businesses are required to complete the Social Responsibility Alliance’s Slavery & Trafficking Risk Template annually to assess the risks within each business and their respective supply chains. This process enables us to gauge their commitment to eradicating slavery, including group businesses with a turnover below the £36 million threshold. This continues to be an effective method of gathering key information.

Training

Our staff continue to receive up-to-date, awareness-raising information around issues involving modern slavery and human trafficking, including:

  • Types of slavery and trafficking
  • How to spot potential slavery or trafficking issues
  • Our whistleblowing processes

Assessment and effectiveness

Despite the impact of the global coronavirus pandemic on our resources, no significant risks were identified during the past financial year. However, we recognise that our commitment to a zero-tolerance approach to modern slavery is a continual journey. As such, we will continue to review and, where necessary, modify our processes on a regular basis.

This statement was last updated on 03/09/2021

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