This statement constitutes Laird PLC’s slavery and human trafficking statement for the financial year ended 31 December 2016 pursuant to section 54 of the Modern Slavery Act 2015. It confirms our position in respect of such matters and highlights the steps we have taken to ensure that there is no slavery or human trafficking known to be taking place within Laird or its supply chains. While only part of the Laird Group falls within the ambit of Section 54 (as many of its group companies are incorporated and operate outside the UK), Laird has decided to make the statement in respect of its whole group.
Laird is committed to supporting work environments that are free from human trafficking, forced labour and unlawful child labour. We strongly believe that we are responsible for promoting ethical and lawful employment practices. These practices should operate not only within the Laird Group but also our suppliers. We will therefore require these practices from our suppliers. We also expect our customers to require them from us.
Our Business, Structure and Supply Chains
Laird is a global technology company focused on providing systems, components and solutions that protect electronics from electromagnetic interference and heat, and that enable connectivity in mission-critical wireless applications and antenna systems. Our aim is to be a trusted partner to our customers by delivering problem-solving solutions through innovation, reliable fulfilment and speed.
Laird provides supply solutions across five key markets: mobile devices, connected industry, connected transport, telecom/computing and connected medical.
We operate across North America, Europe and Asia. Our global footprint means our supply chains involve working with suppliers in a large number of countries with varying cultures, laws and standards of living. We source products from a combination of global and regional suppliers.
Laird has adopted a specific policy against Human Trafficking and Slavery which sets out the standards it expects in this particular area such as forbidding the use of forced labour and excessive working hours. It goes further however and requires such things as a safe and healthy working environment and preventing discrimination, harassment or other form of abuse.
The Human Trafficking and Slavery policy supplements Laird’s General Supplier Code of Conduct which sets out what Laird expects more generally from its suppliers. The General Supplier code also requires compliance with the Electronic Industry Citizen Coalition Code of Conduct (http://www.eicc.info) in its entirety including its elements related to Labour, Health and Safety, Environment, Management Systems and Ethics.
Suppliers are required to comply with these policies by the terms of the contracts which are signed with Laird. Laird believes the same standards should apply to itself, its suppliers and to its suppliers' suppliers. It therefore also requires its suppliers to impose the same standards on their suppliers.
Laird has in place a due diligence process to cover the appointment of new suppliers which includes checking their financial and employment practices. Failure to achieve the requisite standards may result in the appointment not being made.
Laird has a specialist audit team whose members visit new and established suppliers to check that that are complying with all the standards required by Laird. Where issues are identified these are raised with the supplier and, wherever possible, addressed. Visits are prioritised by reference to size of supplier and perceived general risk level.
As it is not practical to carry out a physical audit of every supplier, every supplier wishing to do business with Laird must sign an acknowledgement that they have read the Supplier Code of Conduct and that they intend to comply with them. They are expected to review and acknowledge compliance annually and report any violations.
Failure to comply may result in the delisting of the supplier from the approved supplier list.
Supply chain auditors receive training and guidance on all the issues on which they are required to provide assurance on, including anti-slavery and human trafficking.
Effectiveness of Approach
Laird is committed to ensuring that, in so far as it is reasonably practical, slavery and human trafficking does not exist in any form in its group or in its supply chain. The procedures it adopts seek to eradicate slavery from itself and its supply chain however, in part, their effectiveness depends upon the truthfulness of third parties in many instances. While most parties are, unfortunately some are not, and Laird will ensure going forward that its audit team seeks to identify such parties to make its approach as effective as possible.
This statement was approved by the Board of Directors on 25 January 2017
© 2017 LAIRD PLC