1. Standard and Expedited Shipping
A. ORGANISATION
This statement applies to Sure Purity Limited (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2022/2023.
B. ORGANISATIONAL STRUCTURE
Sure Purity with its headquarters at Unit 6, Blaydon Trade Park, Toll Bridge Rd, Blaydon on Tyne, NE21 5TR, England, is this centralised place of work and the sole place where Sure Purity products are manufactured and where all full time employees work. There are no foreign divisions. The company is controlled by its UK based board of Directors.
The main activity of the organisation is the manufacture of specialised filtration systems used in industries such as the beverage manufacturing industry and industrial gases industry, specifically Carbon Dioxide. The organization performs the sale of the aforementioned goods both directly to the end user, as well as through a Global network of independent distributors. Demand for our product is consistent throughout the year therefore not seasonal
The labour supplied to the Organisation in pursuance of its operation, is carried out in the United Kingdom at our headquarters in Blaydon.
C. DEFINITIONS
The Organisation considers that modern slavery encompasses:
- Human trafficking;
- 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.
D. COMMITMENT
The Organization acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains where accessible.
The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.
E. SUPPLY CHAINS
In order to fulfil its activities, the Organisation’s main supply chains include those related to the supply of components for the manufacture the products at our headquarters, we source predominantly within a 150 mile radius from our manufacturing base in Blaydon. One item is sourced from China. Several first-tier suppliers have further contractual relationships with lower tier suppliers.
F. POTENTIAL EXPOSURE
The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in lower tier suppliers to our first-tier suppliers, because they may involve the provision of labour in a country where protection against breaches of human rights may be limited.
In general, the Organisation considers its exposure to slavery/human trafficking to be very low, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
G. IMPACT OF COVID-19
During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the Organisation, as it did for others across the nation.
The Organisation welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.
The Organisation concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above.
During the pandemic, the Group’s employees still had access to the grievance procedure to raise any concerns that they may have had.
In line with emergency legislation passed by the Government, Group employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking where applicable.
The Organisation modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.
H. STEPS
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:
- reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
- putting measures in place to identify and assess the potential risks in its supply chains;
- undertaking impact assessments of its services upon potential instances of slavery;
- creating action plans to address risk to modern slavery;
- embed a zero-tolerance policy towards modern slavery;
I. KEY PERFORMANCE INDICATORS
The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.
- Regular communication with all tier-one suppliers to review the Modern Slavery Policy and their adherence to it.
J. POLICIES
The Organisation has the following policies which further define its stance on modern slavery.
- Supplier code of conduct policy.
K. TRAINING
The Organisation provides the following training to staff to effectively implement its stance on modern slavery;
- induction training includes the modern slavery policy.
SLAVERY COMPLIANCE OFFICER
The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
Date of approval 25/05/2023……………
Signed
Gary Robson
Chief Executive Officer
Date 25/05/2023
