Please see the below statement and linked document:
Modern Slavery Act Statement and Ethical Sourcing Policy 2024
This Statement is made pursuant to Section 54 (Part 6) of the Modern Slavery Act 2015 (‘Act’). Smith
Bros (Caer Conan) Wholesale Ltd and sets out the steps that the businesstakes to ensure compliance
with the act, to ensure ethical sourcing of goods and labour and to eradicate slavery in the supply
chain.
This Statement has been approved by the Board of Directors.
Company Overview
Smith Bros (Caer Conan) Wholesale Ltd are Electrical Material Distributors and provide Lighting
Design services to clients. We have a diverse range of clients whom we assist with Electrical Material
Supply Chain and solutions to reduce carbon footprints though design and supply of energy efficient
schemes. We work proactively to provide practical solutions to assist clients in achieving their
business SLAs while operating in compliance to current regulations
and individual client requirements.
We at Smith Bros (Caer Conan) Wholesale Ltd (also referred to as “we”, “us”, “our”) are a registered
company in England (Company number 267023).
Smith Bros (Caer Conan) Wholesale Ltd has long established relationships with the industries major
electrical manufacturers and suppliers within the United Kingdom. Whilst these manufacturers and
suppliers are neither owned nor controlled by us, it nevertheless remains an important requirement
that they operate to the ethical principles applied by Smith Bros (Caer Conan) Wholesale Ltd in
relation to its own business and to that of its supply chain.
Our Philosophies and Principles
Our Corporate Sustainability Strategy states our mission to ensure Smith Bros (Caer Conan)
Wholesale Ltd is a responsible business and its employees are upholding the highest level of ethical
conduct in their day-to-day business. We continually challenge ourselves to raise standards on quality
and ethics and hold ourselves accountable for the way in which we work.
We strive to ensure that it does not contribute towards adverse human rights impacts through its
supply chains.
There is an ongoing commitment to engage only those suppliers that uphold the same principles as
Smith Bros (Caer Conan) Wholesale Ltd and where necessary ensure the implementation of
www.smithbrosuk.com
corrective action measures. In the event that suppliers fail to take steps to cease or prevent adverse
human rights impacts, Smith Bros (Caer Conan) Wholesale Ltd will reconsider its business
relationships with those suppliers.
Supply Chain Management:
Smith Bros (Caer Conan) Wholesale Ltd source a wide range of goods and services from suppliers and
manufacturers based in the United Kingdom.
In all of our dealings with those suppliers we commit to doing everything in our power to make our
supply chain free of modern slavery. We will work proactively with our supply chain partners, local
and national government, law enforcement agencies to ensure that the highest ethical standards are
reached at all times. As part of this ongoing requirement, there is an increased focus on the long-
term commitment by those suppliers to eradicate slavery and human trafficking in their own
businesses and supply chains. Each supplier, new or old, shall be audited for their own compliance to
the Modern Slavery Act 2015 (where applicable) and ethical supply chain policy.
Each supplier may be subject to periodic audits and site visits to ensure continued compliance with
the standards declared. Any cause for concern will be investigated with the supplier being removed
from the supply chain until corrective action has been taken to eradicate those concerns. If serious
breaches continue to be evident then Smith Bros (Caer Conan) Wholesale Ltd. reserve the right to
report the organisation in question.
Management, Internal Auditing, and Review of Policies:
Internal audits of Smith Bros (Caer Conan) Wholesale Ltd direct suppliers and own policies shall be
conducted periodically, and any non-compliances discussed at senior management level and with
any supplier concerned.
In the case of those suppliers based abroad or that source goods from high-risk countries outside of
the UK, the manufacturing and production processes for Smith Bros (Caer Conan) Wholesale Ltd
product lines are not fully visible and further investigation into these areas is yet to be undertaken
but Smith Bros (Caer Conan) Wholesale Ltd will be requesting further information from those
suppliers in order to satisfy itself of their ongoing ability to comply with the Act.
A review of Smith Bros (Caer Conan) Wholesale Ltd existing Strategies and Policies has been
conducted in the last twelve months to ensure its relevance and compliance with the Act, with all
found to be compliant.
Training
All staff of Smith Bros (Caer Conan) Wholesale Ltd shall be made familiar with the contents of the
policy and periodically refreshed in the contents.
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Training on the signs and what to look for will be provided and information made available on how
to escalate any concerns. Such as:
* Physical Signs - Victims may look neglected, malnourished, carry injuries caused by abuse, and
wear the same clothes everyday
* Behavioural Signs - Body language may suggest they are fearful and anxious, they aviod
contact and are reluctant to speak. Someone may speak for them as they are unable to
communicate freely.
* Working Conditions - Victims made to work against their will. Not paid fairly with no contract
of employment, may not be paid at all. No breaks at work and forced to work to pay of a debt.
* Living Conditions - Victims may live in cramped and squalid conditions. This may be provided
by the employer.
* Restricted Freedom - Victims may not have ID or travel documents such as passports and this
may be withheld. Victims unaware of of their home or work address with limited contact
outside of the working environment.
If we suspect that someone is a victim of modern slavery, our people can contact the appropriate
service below:
* Emergency or threat to life situation, call 999
* Non-emergency concerns: call the modern Slavery Helpline- 0800 121 700 or visit
https://www.modernslaveryhelpline.org/ to report suspicions: call your local police on 101
and ask for the Modern Slavery Team
* To report concerns about how workers are treated or to seek advice on labour exploitation
or other labour abuses contact the Gangmasters and Labour Abuse Authority (GLAA) on 0800
432 0804.
GLAA is the UK's investigative agency working to protect vulnerable and exploited workers
* Contact the Salvation Army on 0800 808 3733. The Salvation Army provides specialist support
for all adult victims of modern slavery in England and Wales
www.smithbrosuk.com
Smith Bros (Caer Conan) Wholesale Ltd recognises the importance of maintaining constant vigilance
to identify and address any impacts associated with slavery and human trafficking throughout its
supply chains. In recognition of the salience of these issues, Smith Bros (Caer Conan) Wholesale Ltd
is committed to continuing to enhance its capacity to identify, prevent and mitigate any actual or
potential impacts in this field and to continually contribute to building a prosperous and slavery free
economy.
Signed:
M P Jervis
Director
01/06/2024