UK Modern Slavery Act Statement

Modern Slavery and Human Trafficking Statement Modern Slavery Act 2015
 
  1. Introduction

This statement is made on behalf of TGA Industries Limited and is issued pursuant to our obligations
under the UK’s Modern Slavery Act 2015 (“MSA”).

TGA Industries Limited is referred to herein as the “Company”.

These obligations comprise releasing a statement, signed by a Director, which details the steps the
Company have taken to ensure that slavery and human trafficking are not taking place in our supply
chains or in any part of their businesses.

The statement refers to our financial year ended 31 December 2020. We have, however, also
described in this statement actions and policies implemented since that time.

 

  1. Organisational structure, business and supply chains

The Company forms part of the Fortive Group (“Fortive”), an international group of corporate entities
whose principal activity is the production and supply of high quality, specialist technology to solve
customers’ critical needs.

The Company is organized into three divisions (referred to herein as the “Division” and/or the
“Divisions”):

  • Qualitrol (UK), specialized in the condition-based monitoring across the globe for
    utility assets;
  • West Control Solutions (UK) which primary business is the design, development and
    manufacture of Temperature controls used in a variety of commercial and industrial
    products across a variety of industries; and
  • Gems Sensors Ltd which principal activity is the design and manufacture of liquid
    level, flow switches and pressure switches, sensors and transducers, miniature
    solenoid valves, and pre-assembled fluidic systems.
  • As of November 2019, West Control Solutions and Gems Sensors Ltd report under the
    same business unit, Gems Sensors & Controls Inc.

All three divisions operate both within and at the top of a global supply chain across multiple
commodities.

Key countries each divisions source from:

  • UK
  • Китай
  • Индия
  • Франция
  • Германия
  • Чешская Республика
  • Швеция
  • Литва
  • Бельгия
  • USA

 

  1. The Company’s policies in relation to slavery and human trafficking

Our Company and its wider group deplore human trafficking and modern slavery in all its forms. We
support the MSA and its underlying aims.
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It is the established policy of the Fortive Group that workers at supplier facilities have the right to
freely choose employment. Fortive further expects that all suppliers who do business with Fortive and
its subsidiaries will comply with all applicable laws, including the laws against forced or involuntary
labour, and this expectation is embodied in Fortive’s Supplier Code of Conduct, available here. The
Company wholeheartedly supports these values and objectives.

A significant portion of Fortive’s Supplier Code of Conduct addresses labour standards. This part of the
Code of Conduct mandates fair treatment in terms of remuneration and working conditions and
prohibits abusive, violent or demeaning conduct towards employees as well as precluding all forms of
involuntary or child labour, including prison, bonded or indentured labour, and engagement in any
form of human trafficking, as well as all forms of discrimination

  1. Due diligence processes in relation to slavery and human trafficking

Our methodology is to conduct risk assessments, based on the Global Slavery Index (“GSI”) and other
bodies of empirical research which highlight particular sectors where slavery is prevalent. Risk
assessments are carried out annually by each division’s supply chain leaders with support from Fortive
Corporate Supply Chain team. Details of the Supplier Risk Management process are available to all
employees of the Company on the internal Fortive Sharepoint.

These checks involve engaging with suppliers in relation to slavery and trafficking issues, considering
the content of statements issued pursuant to Section 54 (where available), sending questionnaires
designed to elicit relevant information to gauge a supplier’s slavery and trafficking risk or where
considered appropriate by following up with meetings or supplementary requests for further
information. Where available, we will review the content of statutory slavery statements issued by
organisations pursuant to Section 54. We also intend to pay particular attention to the practices of
those suppliers who enjoy the highest levels of business with us.

Completed Risk Assessments are stored centrally on the FortiveProcurement.com. in addition to the
risk assessment, bot scheduled and unscheduled inspections of key supply sites take place
throughout the year, either by division Supply Chain leads or the Fortive Supply Chain team.

Whilst inspection visits to key supply sites would normally take place as part of the risk assessment
process, all assessments were completed remotely due to COVID travel restrictions. In person
inspection will resume as soon as it is safe to do so. All those on the preferred supplier list have
been risk assessed by the Fortive corporate Supply Chain Team prior to inclusion.

  1. Parts of our business and supply chains where there is a risk of slavery and human trafficking
    taking place, and the steps we have taken to assess and manage that risk

The Company is engaged in an on-going risk assessment exercise designed to identify areas of risk
within its supply chain. We consider that the areas of highest risk come from suppliers who make use
of facilities in those countries where the GSI indicates an elevated slavery and trafficking risk. We are
aware, for example, that some manufacturing installations in Asia are known to have exploited
bonded labour.

Consulting the GSI, however, we are advised by GSI that we have no direct suppliers based in areas
of the world which are considered to be medium or high risk. Fortive have a preferred supplier list
which the divisions in TGA adhere to. As stated above, all those on the preferred supplier list have
been risk assessed by the Fortive corporate Supply Chain Team prior to inclusion.

Whilst we have no information to suggest any of these suppliers are tainted by practices of forced
labour or trafficking, we fully realise the importance of remaining vigilant and keeping this under
review. This is the reason for our annual divisional risk assessments. [Our preferred process would be
to first work with any supplier to remediate (if possible and appropriate) any untoward issues that
come to light, but ultimately we reserve the right to terminate any business arrangements that our
not compliance with our standards for suppliers.]

Equally, we do not lose sight of the fact that modern slavery and human trafficking practices are also
occasionally found in the UK, albeit on a smaller scale. Closer to home, therefore, we do not forget
that certain industries may be prone to exploit low-skilled, low paid or migrant workers and require
them to work in conditions or under terms that are unacceptable. UK suppliers and contractors are
therefore to the same level of scrutiny as international suppliers..

We are aware that certain employment agencies can have an elevated slavery and trafficking risk,
particularly where they make travel arrangements or other arrangements on behalf of workers coming
to the UK. The Company, makes limited use of such agencies, but where it does we remain equally
vigilant and ensure that employment agencies are subject to the same due diligence as our other
suppliers. Furthermore, where we deem it appropriate, we will ask questions about candidates during
the recruitment process which are designed to spot red flags and determine whether there could be
problems. We are introducing a MSA statement and declaration into our onboarding packs for new
starters in 2020.

  1. Training about slavery and human trafficking available to our staff

The Company implemented and will continue to use training programs for our staff, concentrating in
particular on those areas of the organisation where personnel are most likely to come into contact
with slavery or human trafficking.

As of April 2020, the global MyLearning platform was rolled out across all Fortive OpCos. This system
tracks all learning and is now the platform through which all compliance training is rolled out and
monitored. Compliance training is managed centrally by the Fortive Compliance Team and is run on
an annual cycle. The next training roll-out on forced labour is released in June 2021.

Fortive corporate Supply Chain regularly circulates fact sheets and guidance about modern slavery
and trafficking to our staff with a view to raising awareness within the organisation, directly through
management channels, on our internal MS Teams Channels and through email. Regular updates are
circulated from Fortive Trade Compliance Team directly to the Supply Chain teams to ensure they are
kept up to date with any changes to policy or process.