Jablite is the UK's largest producer of EPS products for insulation and civil engineering applications

Modern Slavery Policy

Modern Slavery Statement
Introduction
This statement is aimed at meeting our obligations under the Modern Slavery Act 2015 and covers
our current status as at August 2018.
“Modern slavery” is a term which covers slavery, servitude, forced and compulsory labour and human
trafficking. It includes exercising ownership over a person; coercing or threatening someone to perform
work they would not do voluntarily; and arranging or facilitating another person’s travel with a view to
them being exploited (even where the person consents to the travel).
Jablite Limited and Styropack (UK) Limited aim to ensure that there is no modern slavery within its
business or supply chains. This statement sets out the steps we are taking to develop our procedures
and to check our compliance.
Overview
An overview of our organisational structure, key business activities and supply chains is as follows:
We manufacture expanded polystyrene products for the construction, civil engineering, horticulture,
fresh produce (fish and processed foods) and the packaging and automotive industries.
We supply finished products via distributors and direct to end users from five manufacturing sites across
the UK. We only supply products to the UK.
Whilst our end users may transfer our products outside the UK, this is a very rare occurrence due to
the high cost of transportation and easy availability of similar products in other countries. In any event
our customers have their own fiduciary duties regarding the UK legislation on modern slavery as well
as any responsibilities they may have in relation to the laws of countries they are exporting to.
The main raw material used in our process is Styrene which we responsibly source from companies
manufacturing worldwide, but particularly in EU countries.
The suppliers of our raw material manufacture and supply for example from the Netherlands, Germany,
France, Austria, Italy, Mexico and Turkey.
When we choose suppliers we will be using a number of strict criteria we require them to meet. Firstly,
a Quality Control Audit in accordance with BS EN ISO 9001. Secondly, under BS EN ISO 14001 an
environmental management system must be in place.
The raw material used to produce Styrene is Styrene Monomer. This is a by-product of the oil extraction
and oil refining/petrochemical industries and is noted as a risk of modern slavery due to the countries
in which it operates.
Due to demand and availability from time to time they may source Styrene Monomer from outside their
organisation. Under either their own ISO 14001 certification or their own nationally recognised
environmental management system, they must only purchase from other ISO 14001, or equivalent
approved manufacturers.
The Petrochemical industry are required to report every year on the steps they are taking to ensure
that slavery and human trafficking is not taking place in any part of its own business. If they are taking
no steps this must also be reported.
Consultation: we will work closely with our employees, customers and main suppliers as well as with
bodies such as BSI, in order to ensure compliance with ethical trading initiatives.
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Responsibilities
The HR Department is responsible for our anti-slavery initiatives, including the writing and
implementation of policies and employee training. The Finance Director, as the Compliance Officer for
both Companies, is responsible for due diligence, risk assessments and investigations
The Directors of Jablite Limited and Styropack (UK) Limited are responsible for overseeing our efforts
to eliminate modern slavery and for monitoring progress against the KPIs contained in this document.
The HR department is responsible for ensuring that all recruitment and terms and conditions of
employment comply with statutory requirements, and that any agencies used are appropriately checked
and commit to ethical standards. Our supply team is responsible for ensuring that appropriate checks
are made prior to any orders being placed, and our Sales and Technical Teams work with our own
customers to provide them with appropriate information.
Documentation
We have the following policies in place for employees:
 Code of Conduct Updated August 2018
 Whistleblowing policy Updated August 2018
 Environmental policy ISO 14001 – We have for all 5 sites
These are referenced in our employee handbook, and copies are available from Line Managers, on a
shared drive or the HR Department. Employees are reminded of the policies from time and time, and
notified of any updates. All policies are updated on an annual basis.
Risk assessments
We consider that the main areas of risk of modern slavery within our business and supply chain are as
follows:
 Recruitment of permanent or temporary staff via Agencies.
 Purchase, in particular, of Production equipment, Production and Office consumables and
engineering spares.
 Downstream suppliers of petrochemical products to the suppliers of our raw bead a key element
of our products.
 Oil extraction businesses operating in countries outside the Modern Slavery Act disclosure
requirement.
Actions
Employees: all recruitment of new employees conforms to the CIPD Code of Practice.
Agency workers: should we use agencies for permanent or temporary appointments, we will require
written confirmation from them that no agency worker is being exploited as part of any slavery or human
trafficking. Steve Huxham to action.
Raw materials: we embrace socially responsible trading and wherever possible we use Fairtrade
ingredients. We will endeavour to audit all of our suppliers of raw materials to ensure their production
sites meet our hygiene and working standards, and all suppliers are issued with a Supplier Code of
Conduct which they commit to, and which sets out key minimum standards relating to employment and
workers. This will be extended to cover modern slavery. Our supplier contracts will be updated to
include clear provisions that require our suppliers to commit to ensuring that there is no modern slavery,
both within their own business but also within their own supply chain (including with anyone with whom
they sub-contract). Suppliers are required to self-certify their compliance with the code but contractual
provisions also include that we may undertake ad hoc site visits, audits and regular monitoring etc (or
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to end the contract early, and without penalty to us, in the event of a breach). Contractual penalties
may be awarded against any supplier for a breach of contract, or for incorrect self-auditing responses,
questionnaires or the giving of incorrect information.
Major suppliers are requested to inform us of the steps that they are taking to eliminate modern slavery.
Customers: we also work closely with our major customers to ensure that our employment practices
and procedures comply with national standards.
Due diligence, monitoring and auditing processes:
All suppliers will be issued with our Code of Conduct and will be required to sign and return a
commitment to ensuring that their businesses and supply chains are free from modern slavery by the
end of Q2 2019.
We plan to physically audit Major suppliers’ contracts annually in 2019.
Penalties for breach
If a supplier is found to be involved in any form of modern slavery, its contract will be terminated either
immediately or on its due renewal date, depending on the severity of the breach. If the breach is a
minor one, we commit to helping that supplier by providing guidance and support. Any suspicions of
criminal activity will be reported to the police.
If it is established that any employee has acted in breach of any of our policies, or is aware of, has
condoned or failed to report any suspicion of modern slavery within our business or supply chains,
he/she will be subject to the Company’s disciplinary procedure.
Training:
The Company will provide suitable training for all employees to ensure that they are aware of this
Statement and can be vigilant in identifying and reporting any concerns they have.
Employees and managers are informed of any updates to our policies via email, briefings or
noticeboards.
Relevant performance indicators:
– all Senior Managers and staff in sales and purchasing will have more training by end of Q1 2019
– supplier verification procedures established and issued
– no of complaints raised through our grievance or whistleblowing procedures
– no of suppliers who are terminated due to allegations of modern slavery
– 100% of suppliers signed up to our Code of Conduct
– no of suppliers failing their annual onsite audit
Approved by the Board: October 2018