Modern Slavery Statement in relation to the Modern Slavery Act 2015
Slavery and Human Trafficking Statement in respect of the financial year ended 31 December 2018 and to 1 March 2019
Headlam Group plc (‘Headlam’ or the ‘Company’) is committed to taking steps, and improving its practices, to prevent slavery and human trafficking in both its organisation and supply chain.
The Company understands that the issue of slavery and human trafficking is a global one and that no business sector will be able to eliminate or be free of slavery or human trafficking within their supply chain without working collaboratively within its industry.
As part of its commitment, the Company undertakes regular reviews of its supplier base, encourages frequent interaction with suppliers by multiple persons from within its organisation, including members of the Executive Team, and strongly supports visits to manufacturing facilities as frequently as is possible.
Headlam is Europe’s leading distributor of floorcoverings, providing the distribution channel between suppliers and trade customers. Working in partnership with suppliers from 22 countries manufacturing a diverse range of floorcovering products and ancillary accessories, Headlam provides an unparalleled route to market for their products across the UK and certain Continental European territories.
To maximize customer and market penetration, Headlam comprises 67 individual businesses in the UK and Continental Europe (France, the Netherlands and Switzerland), each operating under their own unique trade brand and utilising individual sales teams.
Headlam’s extensive customer base, operating within both the residential and commercial sectors and comprising principally independent retailers and flooring contractors, receive the broadest product offering supported by next day delivery as well as additional marketing and other support.
Headlam’s offering is enabled through its unrivalled operating expertise, long-established supplier and customer relationships, and comprehensive distribution network.
Following years of considerable investment, Headlam’s distribution network currently comprises four national distribution hubs, 19 regional distribution centres and a supporting network of smaller warehouse premises, trade counters, showrooms and specification centres.
As at 31 December 2018, the Company had 2,612 employees based in the UK, France, the Netherlands and Switzerland.
Our Supply Chains
In 2018, purchases from suppliers in the EU (including the UK) accounted for 91.2% of total purchases (based on actual purchase prices from suppliers).
13 of the 22 supplier countries accounted for 99.7% of purchases. Of the 13 countries, four are non-EU and collectively accounted for only 8.7% of total purchases in 2018:
The Company works closely with its suppliers throughout the year, and suppliers are met with as frequently as is possible through:
Interaction is undertaken by the delegated buyers within the Company with regular support from members of the Company’s Executive Team. The Company is committed during its interactions to stating its commitment to a supply chain free from slavery and human trafficking. Additionally, the Company is committed to reviewing firsthand the suppliers’ operations and facilities to better ascertain that its supply chain is free from slavery or human trafficking. Where available, the Company also requests and reviews the results of its suppliers’ own audits.
One of the Company’s businesses (National Carpets) is registered on Sedex (Social, Ethical Data Exchange), an online platform which allows suppliers (including certain of the Company’s suppliers) to register and provide company information/audit reports which can be viewed by their customers. Sedex includes a self-assessment questionnaire which is required to be completed which includes a section on human rights, and the Company viewing its registered suppliers’ responses.
Actions during 2018 & 2019
In February 2019, the Company completed an internal audit of its supplier base, including an assessment of potential higher risk areas, and when each supplier’s facilities were last visited and the next scheduled visit.
During the DOMOTEX and BauMunchen trade shows in 2018 and January 2019, the Company, including members of the Executive Team, met with representatives from the majority its supply base, including suppliers from all four of the Non-EU countries detailed above.
Manufacturing facilities were visited in Turkey and Egypt during 2018, and will again be in 2019. Additionally, facilities will be visited in Korea and China during March 2019, including a member of the Executive Team.
During these visits, the Company will explain its zero-tolerance to slavery and human trafficking, and provide a questionnaire for each supplier to complete. These will subsequently be analyzed by a team comprising the Company’s Commercial Director, Company Secretary and members of the delegated buying team to consider whether each supplier is believed to be compliant with the Modern Slavery Act 2015. These questionnaires will additionally be sent to the Company’s other suppliers during 2019.
Ongoing support will be given to the Company’s employees with interaction with suppliers to better help them identify slavery or human trafficking practices. Employees are provided protected by certain policies the Company has in place, and during 2018 the Company updated its Whistleblowing Policy that sets out the formal process by which an employee of the business may, in confidence, raise concerns about possible improprieties in financial reporting or other matters.
This statement was approved by the Board of Headlam on 1 March 2019, and signed on its behalf by