World leaders in specialist chemicals, sealants and surface coatings

Modern slavery statement for the financial year 2016

Norman Hay plc is a global chemicals, sealants, surface coating and engineering group (“Group”). Headquartered in the UK our three main business areas are surface coatings, impregnation sealants and process plant.

The Group takes its social responsibilities very seriously and strives to act in an ethical manner, with integrity and transparency in all business dealings. We are committed to improving our practices to combat slavery and human trafficking in our business or supply chain. We are aware that as a diverse business, we must focus on our internal communication and coherence and this includes in relation to the global issue of modern slavery.

This statement is published on behalf of each of the Group’s UK companies, however, all principles, policies and processes will be disseminated to its overseas group companies.

We procure a range of goods and services from a variety of suppliers in connection with our business activities, including:

  • Chemical raw materials and surface treatments.
  • Proprietary parts in connection with the manufacture of process plant.
  • IT services.
  • Recruitment.
  • Operations and business support.

We seek to partner with suppliers that operate fair and ethical workplaces and share our values and standards. We also operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  • Our recruitment policy detailing the eligibility to work in the UK checks for all employees to safeguard against human trafficking of individuals to work against their will.
  • Our corporate and social responsibility policy which explains the manner in which we behave as an organisation and our commitment to free trade and ethics.

As part of our initiative to identify and mitigate risk we have appointed a legal and compliance officer with responsibility for overseeing implementation of policies and procedures and annual preparation of the slavery and human trafficking statement.

During the next phase of our compliance programme we intend to take the following additional steps:

  • Launch an anti-slavery policy. This will set out our zero-tolerance approach to modern slavery in our organisation and supply chain, and highlights the steps that our staff can take if they are concerned about any such type of behaviour.
  • We will carry out a risk assessment process to assess the nature and extent to which our supply chains may be at risk of modern slavery and determine the appropriate steps to take in combating any risks.
  • The standard terms and conditions that we put in place with suppliers will be updated to include clauses that forbid the use of slavery and human trafficking.
  • We will develop and implement appropriate staff training to enable relevant members of our organisation to understand the requirements of the Modern Slavery Act and to give them the tools to flag potential issues.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group’s slavery and human trafficking statement for 2016.