The Modern Slavery Act 2015 (‘the Act’) creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking.  C.P. Hart & Sons Limited (‘C.P. Hart’) is committed to supporting both the aims and the letter of the Act, namely, to combat all forms of modern slavery and human trafficking and to improve our practices across our group to help achieve this.

 

Our Business

C.P. Hart has been one of the UK’s leading bathroom retailers since 1937. We have always sourced the finest materials and sought advanced manufacturing techniques to guarantee that our customers receive luxury, high-quality products for all their bathrooms.

Our annual turnover is over £40m.

 

Our People

In April 2021, we employ 177 employees across 17 sites in the UK.  We are committed to conducting business in accordance with all applicable laws and regulations in the UK, including the Act and health & safety, environmental, anti-bribery, equality and employment legislation. This extends to maintaining high standards of behaviour amongst our employees through our training and development initiatives.

We have established rigorous HR processes and controls to ensure that:

  • All employees are assessed for their right to work in the UK
  • Workplace equality policies and practices are in place, promoted and implemented
  • Remuneration and benefit schemes comply with relevant UK employment legislation

We continually review and develop our policies, procedures and controls to ensure ethical and legal compliance. 

We encourage our employees to report, in confidence, any concerns or breaches e.g., suspected unethical behaviour and wrongdoing. We have an independent whistleblowing hotline which operates 24 hours a day, every day of the year.  All matters raised either via whistleblowing, through direct communication with management or highlighted by our auditing processes are investigated and appropriate action is taken in accordance with our policies and procedures.

 

Our Supply Chains

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or any part of our business. Further, we are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

We purchase and source products primarily from countries within the EU, including the UK, but also globally on a much smaller scale.  From the suppliers with whom we have direct purchasing relationships, we seek assurance during negotiations that they adhere to the same standards of corporate and ethical responsibility as we do ourselves.

A proportion of our purchasing is through agents and intermediaries. Where this occurs, we recognise our ability to influence labour standards and human rights is more limited, given that we are more reliant on third parties.  With such trading relationships we accept that some countries in our supply chain present an increased risk of modern slavery.  Accordingly, we are committed to investigating what more can be reasonably done in this regard to help our effectiveness at mitigating the risk of any human trafficking and promoting anti-slavery within our supply chain.

 

Further steps

In developing our response to understanding and supporting the aims and requirements of the Act, going forward we will:

  • Continue to raise awareness of our internal ‘Code of Conduct’ & ‘Anti-Slavery and Human Trafficking Policy’
  • Roll out a refresher Modern Slavery Act training module to all colleagues, with key colleagues undertaking an accredited training course
  • Continue to bring our standpoint and responsibilities to the fore in our communications with all stakeholders
  • Continue a regular reporting cycle through our board of directors and management team
  • Implement various measures to identify and mitigate risk and build on the approach deployed to ensure that we operate, as far as possible free from enforced labour, human trafficking and slavery.

Whilst we consider ourselves to be low risk given the vast bulk of our sourcing is from within the UK and EU, we will continue to review our processes and practices to ensure that we identify and manage risks to ensure our ongoing compliance with the Act.

 

Summary

This statement is made by C.P. Hart & Sons Ltd (0889832).

This statement is made pursuant to section 54(1) of the Act and constitutes our slavery and trafficking statement for the financial year ending 31st March 2019. In accordance with the Act, this statement is published on our website (https://www.cphart.co.uk/modern-slavery-statement/). This statement was approved on 29th April 2021 by C.P. Harts board of directors, who review and update it annually.

 

 

Kevin Ohle

Chairman

For and on behalf of Charco 2010 Limited and C.P. Hart and Sons Limited

29th April 2021