Modern Slavery Statement

A) ORGANISATION

This statement applies to Metal Developments Limited(referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2021/2022.

B) ORGANISATIONAL STRUCTURE

Metal Developments Limited is a single organisation controlled by a Board of Directors.  The Organisation has a main office and manufacturing site and another smaller office and manufacturing sit, both based in Devon.

Metal Developments Limited manufacture domestic heating appliances and associated parts, the Organisation also manufacturers electric and gas kits for range cookers.  Metal Developments Limited sell these products through independent retail outlets, heating engineers and via our websites.  Selling of our products can be seasonal, but production is kept up throughout the year to build stocks of our products.

The labour supplied to Metal Developments Limitedin pursuance of its operation is carried out in Devon in the United Kingdom.

C) DEFINITIONS

Metal Developments Limited considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

D) COMMITMENT

Metal Developments Limited acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Metal Developments Limited understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Metal Developments Limited does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Metal Developments Limited in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Metal Developments Limited strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom and in many cases exceeds those minimums in relation to its employees.

E) SUPPLY CHAINS

In order to fulfil its activities, Metal Developments Limited’smain supply chains include those related to the supply of domestic heating appliances manufactured at our premises at Greenham Industrial Estate, Wellington (Woodwarm Stoves) and Ethmar Court, Willand (Oilwarm Burner Products).  Most of our suppliers are based in the UK, with the rest being based in central Europe.  We understand that some of our suppliers are intermediary traders and, therefore, have further contractual relationships with their own suppliers.

F) POTENTIAL EXPOSURE

Metal Developments Limited considers its main exposure to the risk of slavery and human trafficking to exist with our suppliers who are intermediary traders and may have contractual relationships with lower tier suppliers in a country where protection against breaches of human rights may be limited.

In general, Metal Developments Limited considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

G) IMPACT OF COVID-19

During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for Metal Developments Limited, as it did for others across the nation.

Metal Developments Limited welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.

Metal Developments Limited concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above.

Its use of suppliers dropped significantly due to the fact that homeworking was swiftly implemented in March 2020 which meant that its premises, from which it usually conducts day to day business, were temporarily closed.  Several of our workforce were placed on furlough as a result of the drop in demand for our services, meaning there were no additional temporary labour needs.

During the pandemic, the Organisation’s employees still had access to the grievance procedure to raise any concerns that they may have had.

In line with emergency legislation passed by the Government, the Organisation’s employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking.

Metal Developments Limited modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.

H) STEPS

Metal Developments Limited carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Metal Developments Limited has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Metal Developments Limited has taken the following steps to ensure that modern slavery is not taking place:-

Through Metal Developments Limited’s ISO 9001 accreditation our suppliers Modern Slavery Statements were requested and received.

I) KEY PERFORMANCE INDICATORS

Metal Developments Limited has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in Metal Developments Limited or its supply chains:-

Before taking on any new employees, Metal Developments Limited implements checks to make sure an employee has the right to work in the UK. Metal Developments Limited has a Wellness and Employee Assistance Programme.

J) POLICIES

Metal Developments Limited has the following policies which further define its stance on modern slavery: –

a corporate social responsibility policy
supplier code of conduct;
recruitment policy.

K) TRAINING

Metal Developments Limited provides the following training to staff to effectively implement its stance on modern slavery e.g. induction training.

L) SLAVERY COMPLIANCE OFFICER

Metal Developments Limited has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Metal Developments Limited’s obligations in this regard. 

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval: 08/06/21

Signed: Dave Steele
Director

Date: 08/06/21