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.
This statement applies to Tremco CPG UK Limited referred to in this statement as ‘the organisation’.
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:
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.
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.
The organisation considers that modern slavery encompasses:
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.
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.
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:
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.
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
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:
The above training is also provided to new employees as part of the induction process.
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