Modern Day Slavery and Human Trafficking Statement

DEFINITIONS

Beechwood Equipment Ltd considers that modern slavery encompasses:

• Human trafficking,
• Child Labour,
• Forced work, through mental or physical threat,
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse,
• Being dehumanised, treated as a commodity or being bought or sold as property,
• Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT

We, the Directors of Beechwood, understand that we have a moral and legal obligation to ensure our supply chain is slavery free. We are committed to managing our business in a socially responsible way and to preventing slavery and human trafficking in our business activities.

Beechwood Equipment Ltd. does not tolerate human trafficking, slavery or child labour within its organisation nor does it intend to engage with suppliers and subcontractors that fail to take steps to prevent these activities. Employees and third parties are encouraged to report any known or suspected conduct that runs contrary to our values and policy. Beechwood Equipment Ltd. will review and respond accordingly to such reported behaviour.

We periodically review the effectiveness of the relevant policies and procedures that we have in place.

These include:

Risk Assessment/Verification, Structure & Supply Chain:

We periodically assess the risks associated with our supply chain, including those of our subsidiaries. Where risk of exposure to modern slavery is identified we will undertake additional checks and may undertake a site audit of the supplier. Supplier Chain Management Procedure requires us to consider whether a supplier has a written policy barring the use of human trafficking, slavery or child labour or has certified to Beechwood that it will not engage in any such conduct when selecting its key suppliers.

All our employees are based in the UK & we undertake robust right to work checks on all workers. All our workers receive above the living wage. The nature of our products and services and our recruiting and hiring practices are not characteristic of those typically associated with human trafficking, slavery or child labour.

Most of our suppliers are based overseas in USA, Canada, Israel and Europe and the majority of items, components and parts supplied are not of the type that would present a significant risk of human trafficking, slavery or child labour within our supply chain. Some of our suppliers have supply chains that extend into China & Africa, and for these we assess that there is a minimal risk of slavery and human trafficking, mitigated through careful vetting and monitoring.

Supplier Vetting:

As part of our ISO certified management system we have implemented a supplier review process that includes identifying any suppliers that might pose exposure to modern slavery. Where risk of exposure to modern slavery is identified we will undertake additional checks and may undertake a site audit of the supplier. We communicate with our suppliers annually to remind them of their commitment to avoid & eliminate slavery and human trafficking in their supply chains.

This is included along with expectations for them to meet other Beechwood values and policies including anti-bribery, environmental sustainability, equality & diversity, health & safety, ethical business practices, quality controls, business continuity & risk mitigation.

Training:

Our staff & supply chain are made aware of the UK government website: https://www.gov.uk/government/collections/modern-slavery. The information provided allows staff to understand the nature of the problem and to highlight potential issues should there be a suspicion of law-breaking activities.

All employees are trained on our policies and procedures at induction, and via the staff handbook. Staff handling the supply chain must repeatedly update their training throughout the year in the process of engaging in government contracts.

Training is reviewed annually as part of our ISO9001 audit.

Compliance & Remediation:

Beechwood has no knowledge of human trafficking, slavery or child labour in our supply chain, so no remediation measures have been necessary to date. Where any evidence of abuse is found, Beechwood’s compliance manager will instigate an investigation into that supply chain and pause procurement until the risk is mitigated. If a direct supplier to Beechwood, we will end the business relationship with that supplier unless it is shown that the failure was an isolated and accidental incident and that reliable measures have been put in place to avoid it being repeated. Audits will be increased for a year to make sure. If the lapse was by a supplier sub-contractor, we will expect that supplier to show evidence they are investigating and dealing with the offending sub-contractor in order to continue the business relationship.

Assessing effectiveness:

Beechwood is ISO9001 certified. Our effectiveness in combatting anti-slavery, child labour and human trafficking are reviewed in the ISO9001 annual review.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.