Slavery & Human Trafficking
Policy Statement

(Qioptiq, Ltd. St. Asaph, Denbigshire)




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Compliance with Export and Import Laws


Slavery and Human Trafficking Policy Statement
Modern Slavery Act 2015
Qioptiq, Ltd., St. Asaph, Denbigshire

The following policies and procedures have been adopted to ensure that Qioptiq remains in compliance with legislative requirements. Legal compliance plays an important role in ensuring our success and the success of our customers and business partners. We maintain strict adherence to the following statements, reports, policies and procedures.

POLICY STATEMENT
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 ('the Act'). We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. We are proud of the steps we have taken to combat slavery and human trafficking. As such Qioptiq Limited. ("Qioptiq") has adopted the zero tolerance policy for slavery and human trafficking outlined below.

APPLICABILITY
This policy applies to all Qioptiq ("Qioptiq" or the "Company") personnel

ORGANIZATION'S STRUCTURE
We design and manufacture photonic products and solutions that serve a wide range of markets and applications in the defense and aerospace sectors. We are a part of the Excelitas Group (Group), and our ultimate parent company is Excelitas Technologies Corp. It has its head office in Waltham, Massachusetts USA.

Qioptiq Limited had a global annual turnover of £70.8 million in 2016.

OUR BUSINESS
Our business is organised into two business units: Land and Advanced Optronics.

OUR SUPPLY CHAIN
Our supply chains includes the sourcing of materials relating to the provision of photonic products.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in out supply chains.

We ensure:
  • Our values, which are embedded throughout our business, set the perimeters for how we expect our people to behave with colleagues, clients and the world at large;
  • We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted;
  • Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we:
  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains and expect these entities to have suitable anti-slavery and human trafficking policies and processes.
  • Where possible we build long standing relationships with suppliers and make clear our expectations of business behaviour
  • Monitor potential risk areas in our supply chains.
  • Have in place systems to encourage the reporting of concerns and the protection of protecting whistle blowers.

SUPPLIER ADHERENCE TO OUR VALUES
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we flow down the requirements of the Act to all Sub contractors and have in place a supply chain compliance programme. We expect all those in our supply chain and contractors comply with our values.

RESPONSIBILITY FOR THE POLICY
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Procurement Director has primary responsibility for implementing this policy, monitoring its use and effectiveness and dealing with any queries about it. The Compliance Director has primary responsibility for auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring:
  • those reporting to them understand this policy;
  • for day to day compliance in their respective departments; and
  • their supplier relationships comply with this policy

TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors and Vice Presidents have been briefed on the subject. We also require our business partners to provide training to their staff and suppliers and providers.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We use the following key performance indicators (KPls) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
  • Completion of audits by Compliance Director;
  • Use of labour monitoring and payroll systems by HR Director; and
  • Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations by Procurement Director. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 1st January 2018.

Signed,
Peter White, Managing Director

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