Modern slavery statement

(for financial year ending 2021)

According to the International Labour Organisation, there are some 21 million people worldwide subjected to forced labour.  We do not tolerate forced labour either within our business itself or within our supply chain. We expect our supply chain (whether direct suppliers or those that directly or indirectly supply our direct suppliers) to share the same values. 

We have reviewed our business and our supply chain. Neither we nor, to the best of our knowledge, our supply chain make use of forced labour. We have taken the following steps to assess and manage any risk that our supply chain may use forced labour:

• We expect our suppliers to comply with the Supplier Code of Conduct and to place similar expectations on their respective suppliers.
• When entering into arrangements with suppliers, suppliers undergo a supplier approval process in which we assess them from a qualitative and economic perspective. As part of that assessment, we are alert for any indicators of forced labour.
• We may impose contractual obligations on suppliers under which they:
  • undertake to comply with our Supplier Code of Conduct;
  • warrant that their business and, to the best of their knowledge, their own supply chain do not use forced labour;
  • agree to provide us on request with responses to a self-assessment questionnaire regarding use of forced labour and steps they have taken to ensure it is not used by them or their supply chain. 
  • agree to permit us and third parties acting for us to inspect their facilities, records and practices, to have access to their personnel and to audit their business for the purposes of ensuring that they comply with these obligations and that there is no use of forced labour.
  • impose equivalent obligations on their own suppliers.
• We have reviewed statements published by our suppliers on use of forced labour to ensure that they in turn are taking what appears to us to be appropriate steps.

We have prepared this statement for the purposes of the Modern Slavery Act 2015. References in the statement to “forced labour” mean any conduct which is an offence under Part I of that Act including slavery, servitude, any type of forced or compulsory labour and trafficking for the purposes of exploitation.

Approved by the Directors of Navien and signed on their behalf: