Modern Slavery Statement

For the financial year ending 31st December 2023

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery statement for the financial year ending 31st December 2023. It was approved by the Vulcan Engineering Limited Board of Directors on 15th March 2024.

Introduction

Modern slavery is a crime and a violation of human rights. It takes various forms, including slavery, servitude, forced and compulsory labor, and human trafficking. All of these involve the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Modern slavery is a growing global issue that transcends age, gender, and ethnicity.

Our Pledge

We maintain a zero-tolerance approach to Modern Slavery. We are committed to its prevention, deterrence, and detection within our business and supply chain. Our policy is to conduct all business activities with honesty, integrity, and at the highest ethical standards. We are dedicated to implementing and enforcing effective systems and controls within our business and supply chain to continually combat Modern Slavery.

Our Business and Its Structure

The Vulcan Group, established in 1986, has grown into one of the world's leading specialists in the design and manufacture of sealing products. The group consists of subsidiaries strategically located worldwide to support customer requirements.

  • Employees: Over 150 employees globally
  • Operating Countries: 40
  • Global Turnover: £30 million (as of 31 December 2023)

Our Policy

In the current financial year, Vulcan Seals has employed its Modern Slavery & Human Trafficking Policy ("the Policy") to help ensure that Modern Slavery is not taking place within any part of our organization or supply chain.

We maintain a zero-tolerance stance on violations of anti-human trafficking and anti-modern slavery laws. In the event of any breaches found within our supply chain, we aim to support companies in their efforts to comply with the legislation.

Responsibility for the Modern Slavery Policy lies with the Compliance Committee, which has the authority and responsibility to prevent, deter, and detect unethical practices within our organization. All reports of actual or suspected breaches of the Policy are investigated by the Compliance Committee.

Supplier Adherence to Our Values

To ensure compliance with our values and zero-tolerance policy on Modern Slavery, Vulcan Seals has implemented measures to assess and monitor supplier conduct regarding Modern Slavery. Specific prohibitions against Modern Slavery are included in our contracting process, incorporated into our Standard Terms of Purchase, which were rolled out to all subsidiaries of the Vulcan Group.

A key provision requires our suppliers to adhere to the Modern Slavery Act 2015 and the statements in this document. We expect our suppliers to uphold these standards and to hold their own suppliers to the same level of compliance.

In 2023, Vulcan Seals conducted a supply chain risk assessment of our primary production and sourcing countries. The assessment highlighted that approximately 70% of our core product sourcing comes from suppliers in India and China, two of the top five countries for Modern Slavery risks (Global Slavery Index 2016). As a result, we are focusing on these regions, especially India, to ensure robust provisions are in place with all suppliers, especially new ones, in 2024.

Training

To ensure a comprehensive understanding of the risks posed by Modern Slavery, we plan to arrange internal training for Vulcan Group employees. This will raise awareness of this growing issue and inform employees on how to report any suspicions they may have in both business and personal contexts.

We will direct employees to resources such as the www.modernslavery.co.uk website, which provides valuable information on recognizing different forms of slavery, identifying the signs, and accessing telephone helplines. Additional resources, including links to relevant information, will be made available to all employees.

Reporting

We have established a whistleblowing hotline for reporting concerns or suspicions regarding Modern Slavery. This ensures that anyone with concerns has a confidential means of raising them. The hotline is highlighted in all relevant resources developed in relation to Modern Slavery.

Contact

We welcome any questions or comments regarding this statement. Please address any inquiries to hr@vulcanseals.com.

M. J. Carter
Managing Director

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