Modern Slavery Act Statement
Statement from IMI plc (“IMI”) in relation to the steps taken to prevent slavery and human trafficking pursuant to the Modern Slavery Act 2015 (“the Act”) and the California Transparency in Supply Chain Act of 2010. This statement is made on behalf of IMI plc and its subsidiaries Norgren Limited, IMI Precision Engineering Limited, IMI Kynoch Limited and Control Components Inc.
This statement has been published in accordance with S.54(1) of the Act and sets out the steps IMI has taken during the financial year ending 31 December 2021 to ensure that slavery and human trafficking is neither taking place in its own operations nor in its supply chains. IMI recognises other jurisdictions in which we trade have similar relevant legislation covering human rights in the extended supply chain. Our processes and in-house training enable us to declare that we are compliant to the California Transparency in Supply Chains Act 2010 which applies to Control Components Inc. On 25 June 2021 the Supply Chain Due Diligence Act (the “Act”) passed the German Federal Council and will come into force on 1 January 2023. Both Acts oblige companies to disclose their efforts to eradicate slavery and human trafficking from their direct product supply chains for the goods that they offer for sale. This Statement addresses the endeavours undertaken by IMI plc and its businesses to comply with these Acts.
IMI is a specialist engineering company that employees approximately 10,000 people in 50 countries around the world. Further information on IMI’s organisational structure can be found via the following external link https://www.imiplc.com/what-we-do.
1. The IMI Way and Code of Conduct
IMI continues to believe all companies must take their role seriously in preventing modern day slavery and human trafficking. IMI utilises a combination of general corporate responsibility policies and specific supply chain compliance actions to combat modern slavery in its supply chain. These include; the IMI Way and the IMI Code of Conduct, IMI Supplier Code of Conduct and Audit Process, IMI New Supplier Approval and Self-Declaration Process, IMI Standard Procurement Contracts and relevant staff training.
The IMI Way sets out our values – customer intimacy, playing to win, integrity and one big team – and embraces all our activities.
Our Code of Conduct embodies the IMI Way and covers all aspects of the way we conduct business. It covers everything from anti-bribery and corruption to our environmental responsibilities. Our policies are designed to ensure that we do not involve forced labour or human trafficking in the manufacture of our own products or in any of our operations. The IMI Code of Conduct states that:
“We take steps to ensure that we and our immediate supply chain do not illegally exploit employees.
We have processes in place to protect the integrity of our raw materials.
We conduct audits on suppliers to make sure that at sites visited, child or forced labour is not used and workplaces are safe and healthy.”
IMI is also committed to sourcing our services and raw materials responsibly. This means that we have a process to identify the origins of conflict minerals in our supplies, and are committed to ensuring they originate from legal, audited mines. We ask all of our suppliers of products containing conflict minerals to take immediate action to identify their origins in the products they supply to us.
The ‘Speaking Up’ section of the Code of Conduct also refers to IMI’s whistleblowing policy, which includes the IMI Hotline, a third-party reporting service which allows employees to raise concerns in confidence, and if necessarily anonymously. Matters raised through the IMI Hotline or via other methods by employees and third parties are reviewed by the Ethics & Compliance Committee, which includes three members of the IMI Executive and is chaired by the Head of Group Risk & Compliance. IMI’s Board reviews the nature of reports received by the Committee in order to ensure there are effective mechanisms in place to receive concerns, and that such concerns are properly investigated and that there are no recurring trends that would suggest underlying cultural or ethical issues in the Group. Since the creation of the Act there have been no suspected cases of modern slavery or human trafficking reported through the IMI Hotline or into our Ethics & Compliance Committee.
You can find out more about the IMI Way and Code of Conduct on this website by following this link on the IMI Plc website: http://www.imiplc.com/corporate-responsibility/our-approach.aspx
2. New supplier approval and declaration process
The New Supplier Approval procedure has been established and embedded across the divisions. This requires an ethical declaration from suppliers to confirm that they do not engage in any forced labour and that they abide by all applicable local labour laws.
3. IMI supplier Code of Conduct and audit process
Our Supplier Code of Conduct process provides a structured approach to ensuring our suppliers are managing their businesses responsibly and are not engaged in human slavery or trafficking.
The Supplier Code of Conduct risks cover a range of issues from bribery and corruption, providing safe and healthy workplaces, safeguarding the environment and labour standards.
Each of our three divisions (IMI Precision Engineering, IMI Critical Engineering and IMI Hydronic Engineering) assesses the specific Supplier Code of Conduct risks in their supply chains and audit any high-risk suppliers. This current practice results in audits taking place in what we consider “high risk” areas for all aspects of supply chain risk including any forced labour risk.
In addition, we have identified our electronics supply chain as a higher risk area. We have established a programme to investigate our suppliers of tin, tantalum, tungsten and gold (otherwise known as “conflict minerals”) within our electronic products, back to the smelters of these minerals. Whilst we do not buy directly from smelters, we work with our suppliers to ensure smelters are fully audited, reputable and meet the standards established by the Responsible Minerals Initiative www.responsiblemineralsinitiative.org, thus reducing the risk of human rights abuses in our supply chain.
4. IMI standard procurement contracts and staff training
IMI has standard procurement contracts which contain provisions that oblige suppliers that no forced, bonded or involuntary prison labour will be used and that no children under 16 years old are to be employed. The personal data of IMI’s employees (including temporary labour) are checked against official documentation to ensure eligibility to work in that jurisdiction.
IMI updates and trains its procurement professionals to monitor, detect and take steps to prevent forced or trafficked labour on visits to suppliers. This is carried out by an online training module specifically developed by IMI for our people and available to all staff via IMI Learn, our learning management platform. This module is compulsory for all procurement professionals within the organisation and to date we have trained over 600 staff.
This statement was approved by the Board of IMI plc.
Chief Executive Officer
22 February 2022