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 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, with a history and heritage we are proud of. We've always insisted on using the finest materials and advanced manufacturing techniques to guarantee our customers receive luxury, high-quality products to help create their dream bathroom.

We have an annual turnover of £43m.

 

Our People

As at 1st January 2019, we employed approximately 240 employees across 17 sites in the UK.  We are committed to conducting business strictly in accordance with all applicable laws and regulations in the UK, including the Act, 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:


•    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 actively encourage our employees to confidentially report any concerns or breaches e.g. suspected unethical behaviour and wrong-doing. We have an independent whistleblowing hotline to ensure that all of our employees have a voice that will be heard in confidence – 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 will seek assurance during negotiations of the same high standards of corporate and ethical responsibility as we adhere to 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 further back along supply chains is limited to a degree, as we may be only one of many customers in an extensive marketplace.  Owing to this, we recognise that some countries in our supply chain may present an increased risk of modern slavery.  Accordingly, we will be committed to investigating what more can be reasonably done in this regard to help our effectiveness at mitigating human trafficking and promoting anti-slavery within our supply chain.

 

Further steps

In developing our response to, understanding and support of, the aims and requirements of the Act, going forward we will over the next 12 months:

  • Launch our internal ‘Code of Conduct’ & ‘Anti-Slavery and Human Trafficking Policy’, which we have developed this year
  • Develop a specific Modern Slavery Act training module which will be rolled out to all relevant colleagues during 2019
  • Establish a regular reporting cycle through our management team and board of directors
  • Obtain legal advice on further improving our supplier contracts more specifically to exclude modern slavery and human trafficking
  • Assess and, where material to our business, implement any relevant emerging best practice, either specific and/or applicable to our industry sector, related to the aims and objectives of the Act
  • Identify which of our suppliers source products from countries outside the EU and North America and confirm what steps they have taken to ensure there is no modern slavery or human trafficking in their supply chains.

 

Whilst we consider ourselves to be low risk, we will continue to review our processes and practices to ensure that we identify and manage risks to establish 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 (www.cphart.co.uk/Modern_Slavery_Statement_2019). This statement was approved on 29th March 2019 by C.P. Harts board of directors, who review and update it annually.