Modern Slavery Policy Overview

Last updated – 01.11.18

1. 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.
Tharsus Group is committed to ensuring that its business dealings are carried out in compliance with the relevant laws and, in doing so, we endorse the implementation and promotion of ethical business practices to protect workers from being abused and exploited.
The Company is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

2. OUR BUSINESS
We are a Group that consist of two businesses as stated below. Our businesses operates in Blyth, Northumberland, UK. Tharsus Group has over 200 employees and we have an annual turnover above £36 million.
Tharsus Limited is an Original Equipment Design & Manufacture Business focusing on the design and manufacture of a diverse range of customer products from electromechanical assemblies to outdoor advertising and media signs. We work with many of the world’s leading companies to help them achieve their sales and branding goals, by constantly providing cost effective and innovative products against challenging lead times.

Universal Wolf is a sub contract sheet metal and fabrication business based in the UK. Our combination of continually developing processes, engineering technologies and discerning staff ensures the success at delivering our customers’ varied needs in Aluminium, Steel and stainless steel products.

3. WHISTLEBLOWING
The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

4. SUPPLY CHAIN MANAGEMENT
Our supply chains include obtaining electro-mechanical raw materials parties from various suppliers. Also, we work with contractors who supply engineers or consultants for our projects.
Tharsus Group expects the highest standards from all of its suppliers and has put in place this Modern Slavery Policy to reflect its commitment to acting ethically and with integrity in all its business relationships. This includes implementing and enforcing effective systems and controls in order to minimise the risk of slavery and human trafficking taking place anywhere in its business or its supply chains.

5. RECRUITMENT PROCESS
The Company uses only specified, reputable employment agencies to source labour. All entities in the Group ensure appropriate controls are in place to ensure employees have the right to work and are therefore protected by employment legislation. This includes checking right-to-work documents, visas and passports.
The Company and its associated subsidiaries do not employ individuals that would be considered to be ‘child workers’. Young and inexperienced workers may be employed or given work experience, but they are subject to the rights and protections that we afford all workers.

6. COMMUNICATION AND AWARENESS OF THIS POLICY
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, in our supply chains and in our business partners, we provide relevant awareness training to our staff. This Policy is also available in the Tharsus & Universal Wolf websites.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

7. RESPONSIBILITIES AND SIGN OFF
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.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
This Anti-slavery policy will be reviewed by the Company’s board of directors on a regular basis (at least annually) through the Risks & Opportunities Matrix.

8. OUR CONTINUING COMMITMENT
We will continue to engage with our people and our suppliers to raise awareness and to take further steps to ensure that slavery and human trafficking are not taking place in our business and our supply chain.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31st March 2018 and was approved by the Executive Committee on 22 October 2018.

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