Modern Slavery Policy

Modern Slavery Policy

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that CTS Europe Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. CTS Europe Limited has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our business

CTS Europe Limited specialize in providing application based safety solutions to the worldwide laboratory market. Our business encompasses all areas of design, manufacture, service and testing and we work with a small specialist supply chain to support our business.

Our high risk areas

Due to the bespoke nature of our work we work very closely with our supply chain, many of whom are located close to our manufacturing facility in Portsmouth. Our key relationships involve working with suppliers who are skilled and geographically local, and we believe this approach has addressed any high risk areas.

Our policies

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
2. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
3. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
4. Code of business conduct. Employees and suppliers understand the manner in which we behave as an organisation and how we expect them to act.

Our suppliers

Within our robust business procedures, we operate a supplier policy and maintain a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes basic checks to ensure that particular organisation has never been convicted of offenses relating to modern slavery and we continue to monitor this.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

1. They have taken steps to eradicate modern slavery within their business.
2. They hold their own suppliers to account over modern slavery.
3. For UK suppliers, that they pay their employees at least the national minimum wage.
4. For international suppliers, that they pay their employees any prevailing minimum wage applicable within their country of operations.
5. We may terminate the contract at any time should any instances of modern slavery come to light.

Our procurement/buying staff understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Approval for this statement       

This statement was approved by the Managing Director.

Sean Codling,
10th May 2023