Modern Slavery Statement

Star Refrigeration Ltd Modern Slavery & Human Trafficking Statement

Introduction

This statement sets out the approach taken by Star Refrigeration to understand the potential modern slavery risks related to our business, and the actions undertaken to mitigate these risks during the company’s financial year 2018.

Organisational structure, business & supply chains

Star Refrigeration are the largest independent industrial refrigeration and heating engineering contractor in the UK. Renowned for innovation, the company constantly push forward the boundaries of environmentally focused refrigeration and heating and have an unrivalled track record of award winning products and services.  We are based in the UK and operate in the UK and internationally.  Our supply chains largely consist of UK suppliers of equipment, components and specialist engineering goods and services used in our products and services.

Our Board is committed to delivering high standards of corporate governance and a key element of this is managing our company and its group companies in a socially responsible way.  We aim to employ the highest ethical and professional standards and always to comply with all local laws and regulations applicable to our business; it follows that we are absolutely committed to preventing slavery and human trafficking in our corporate activities and supply chains. Our company also expects the same high standards which we set for ourselves from those parties with whom we engage, such as our suppliers and customers.

 

Due Diligence, Risk Assessment & Measuring effectiveness

Star Refrigeration recognises that slavery and forced labour can take many forms, including human trafficking and child labour.  We maintain regular contact and relationships with our suppliers. Where possible we build long standing relationships with suppliers and subcontractors and make clear our expectations of business behavior.  We expect these suppliers to have suitable anti-slavery and human trafficking policies and processes and for each entity in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. Where they do not have their own policies in place they will be expected to agree to comply with our policies and procedures. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the chain.

To date we have not been made aware of any human trafficking/slavery activities within the supply chain but if any were highlighted to us then we would act immediately in accordance with our legal obligations.

As we source our key raw materials from reputable, long-established companies from supply bases primarily within the European Union, we assess that there is very low risk of slavery and human trafficking in our business and supply chains.  However, we aim to periodically review the effectiveness of the relevant procedures that we have in place.  We do not have key performance indicators in relation to slavery or human trafficking as any instance would be expected to be a breach of law.


Actions

  • Establish robust procedures including requirements for compliance to be communicated within our supply chain and to all employees.
  • We will review current suppliers for compliance with the Modern Slavery Act 2015 and will ask new suppliers to confirm that they are complying with the Act.
  • Employee Training – During the next financial year, the company plan to review our procurement process and identify the key personnel involved in the appointment of suppliers and subcontractors with a view to providing awareness training where required.


This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, is approved by the Board of Directors of Star Refrigeration Ltd and signed on its behalf by:





Dr AB Pearson
Group Managing Director
April 2019