Modern Slavery Statement

1. Introduction

Malvern Optical is committed to preventing modern slavery and human trafficking in all its forms within our organisation and supply chains. This statement outlines our approach and the steps we take to ensure compliance with the Modern Slavery Act 2015.

2. Organisational Structure, Business, and Supply Chains

Organisational Structure:

Malvern Optical is a private limited company registered in England and Wales operating in the Defence and Security sector. Our headquarters are in Worcestershire, United Kingdom, where our main facilities are located.

Business Operations:

We provide research and development, test and measurement, and consultancy services to the UK Defence and Security market, and those wishing to supply into it, focusing on impartiality, innovation, and quality.

Supply Chains:

Our supply chains involve sourcing raw materials and components for use in our products, from a range of specialist global suppliers. Malvern Optical are also supported by a UK domestic supply chain to provide technical and support services. We work with a diverse range of companies, from small to medium enterprises, to large multi-national businesses, as well as consultants and academic institutions.

3. Policies in Relation to Slavery and Human Trafficking

Malvern Optical has implemented a comprehensive set of policies to combat modern slavery and human trafficking, including:

Modern Slavery Policy: This policy outlines our commitment and approach to preventing modern slavery in our operations and supply chains.

Supplier Code of Conduct: Sets out the ethical standards and fair labour practices we expect from our suppliers.

Whistleblowing Policy: Provides a confidential mechanism for reporting concerns, including those related to modern slavery.

4. Due Diligence Processes

We implement robust due diligence processes to identify and mitigate the risk of modern slavery and human trafficking in our business and supply chains:

Risk Assessment: Conduct regular risk assessments of our supply chains to identify potential areas of concern.

Supplier Audits: Perform audits of high-risk suppliers to ensure compliance with our ethical standards.

Contractual Clauses: Include specific clauses in supplier contracts requiring adherence to anti-slavery laws and our Supplier Code of Conduct.

Supplier Engagement: Engage with suppliers to communicate our expectations and provide support for compliance.

5. Risk Assessment and Management

We recognise that certain parts of our business and supply chains may be at higher risk of modern slavery and human trafficking. These include:

Raw Material Sourcing: Areas where raw materials are sourced from regions with weak labour protections.

Manufacturing: Facilities located in countries with higher risks of forced labour and poor working conditions.

Temporary Labour: Use of temporary or migrant labour, which can be more vulnerable to exploitation.

To manage these risks, we have taken the following steps:

Enhanced Due Diligence: Focused due diligence on high-risk areas and suppliers by our procurement team.

Staff Training: Provided training to all staff on recognising and preventing modern slavery and using this in the procurement decision making process.

6. Measuring Effectiveness

We measure our effectiveness in combating modern slavery and human trafficking through the following performance indicators:

Audit Results: Number and results of supplier audits conducted.

Training Completion: Percentage of staff who have completed modern slavery training.

Incident Reports: Number of reported incidents related to modern slavery and the outcomes of investigations.

Supplier Compliance: Percentage of suppliers meeting our Supplier Code of Conduct requirements.

7. Training and Capacity Building

We are committed to educating our staff about modern slavery and human trafficking through mandatory training. This helps employees recognise and prevent modern slavery practices within our supply chains.

Malvern Optical staff are encouraged to maintain awareness and vigilance, and to report any suspected instances of modern slavery identified. If required, staff can report any concerns to an external body as detailed in our Whistleblowing Policy.

8. Review and Approval

The Management Team will annually review this statement to ensure its effectiveness and relevance. This statement is effective as of June 2024.

Signed on behalf of the Malvern Optical Management Team by Andrew Turner, Managing Director.

(Ref. MSS-2024)

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