Modern Slavery Statement

Tremco CPG’s code of conduct on Slavery and human trafficking

This statement sets out Tremco CPG’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2019/20.

Organisation

This statement applies to Tremco CPG UK Limited referred to in this statement as ‘the organisation’.

Organisational structure

Tremco CPG UK Limited is a private company limited by shares and is incorporated in England.

The organisation is a wholly owned subsidiary of RPOW UK Limited and its ultimate parent company is RPM Inc., a US based and stock exchange listed company.

The company is part of a larger Construction Products Group Europe which currently operates in the following countries:

  • Germany, Czech Republic, Finland, Latin America, United Kingdom, Hungary, France, Poland, Russia, Slovakia, Netherlands, Spain, Sweden, Turkey, Dubai, Switzerland, Korea and Austria.

Construction Products Group Europe has approximately 1,100 employees across Europe, Africa and Asia.

The directors are responsible for making key decisions in the business and the company is controlled by its parent company, RPOW UK Limited.

Principal activity

Tremco CPG manufacture and supply high-performance sealing and bonding solutions for the construction and manufacturing industry and consists of four brands being, illbruck, Flowcrete, Nullifire, Tremco, Vandex and Dryvit.

The organisation sells products which have been manufactured in-house and products that have been sourced from external suppliers.

The labour supplied to the organisation in pursuance of its operation is carried out in the countries listed above and at times employees move between geographic locations to aid business operations.

Definitions

The organisation 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.

Commitment

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

The organisation 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.

As part of the RPM Inc. group, Tremco CPG strictly follow RPM’s instructions to do everything reasonably possible to prevent being involved in any activities that are in any way connected or related to slave labour.

No labour provided to the organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation.

As part of the manufacturers of Sealants and Coatings industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Potential exposure

The organisation considers its main exposure to the risk of slavery and human trafficking to exist in its supply chain as a number of manufactured products require the raw materials produced in other countries whereby protection against breaches of human rights may be limited.

In general, the organisation considers its exposure to slavery/human trafficking to be relatively limited. 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.

Steps

The organisation 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.

The organisation 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, the organisation has taken the following steps to ensure that modern slavery is not taking place:

  • Risk assessments: performed by RPM Inc on request of any RPM affiliate;
  • Investigations/due diligence: to identify and assess the potential risks in the supply chain and is performed either by the RPM Legal Counsel or by individual departments;
  • Risk planning: creating action plans to address risks to modern slavery;
  • Review of supplier contracts: review of the organisation’s purchasing policy to identify opportunities to mitigate or reduce the risks that arise from modern slavery.

Key performance indicators

The organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the organisation or its supply chains.

  • requiring departmental managers, HR professionals and relevant purchasing and supply chain employees to have completed training on modern slavery
  • maintaining a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
  • reviewing its existing supply chains, whereby the organisation evaluates all existing suppliers.

Policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations

  • Whistleblowing policy The organisation encourages all its employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our confidential helpline/complete our confidential disclosure form. Further information on company policy can be found in the RPM ‘Values & Expectations’ handbook.
  • Employee code of conduct The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. This information can be found in the company handbook.
  • Supplier/Procurement code of conduct The organisation is committed to ensuring that its suppliers adhere to the organisation’s purchasing policy which helps ensure that suppliers comply with the legal rules and regulations applicable in the countries in which they operate as well as the norms set out by the international labour organisation and UN Declaration of Human Rights.
  • Recruitment/Agency workers policy The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. The HR department have further information on approved employment agencies.

Training

Employees are required to comply with RPMs code of conduct and are required to attend regular training sessions to ensure compliance with the Company’s policies.

This training includes the following items connected to Modern Slavery:

  • Comply with equal employment opportunity principles and regulations related to hiring, working conditions, training, promotions and other conditions of employment
  • Be alert for “red flags” associated with child or forced labour and human trafficking, and report any concerns to RPM’s or your Group’s legal department

The above training is also provided to new employees as part of the induction process.

Management responsibility and general awareness

Tremco CPG will continue to raise awareness of this published statements with employees and other relevant bodies and remind employees of our obligations under the Act.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and will be reviewed for each financial year.

Print name: John Gordon
Job Title: Managing Director
Date: 15.12.20