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Statement March 2019
This Statement, which is pursuant to Section 54 of the UK Modern Slavery Act 2015 is made on behalf of Festo Limited (“Festo”) which is part of the Festo Group and whose ultimate parent company is Festo SE & Co. KG.
Festo is committed to upholding human rights and preventing acts of modern slavery and human trafficking. In this Statement we set out those actions taken by Festo in the proceeding financial years up to and including the financial year 2017/2018 which are designed to drive out acts of modern day slavery and human trafficking from within its own operations and its supply chain.
Founded in 1925, the Festo Group is a worldwide supplier of automation technology and delivers industrial training and education programmes. The Festo Group has approximately 20,100 employees and operates in 61 countries worldwide.
The Festo Group has a global annual turnover of 3.1 billion Euros.
We work with a supply chain that includes contractors, sub-contractors, suppliers, manufacturers, and professional advisers. We impose the same high standards aimed at driving out modern slavery and human trafficking in our supply chains as we do in our own operations.
Festo’s Own Operations
Policies and Compliance
The Festo Group is committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. All employees of Festo are issued with contracts of employment and they are expected to comply with the Code of Conduct (“the Code”). The Code is available in 16 languages and is published on the Festo Group’s corporate website https://www.festo.com/group/en/cms/10310.htm. The Code reflects our commitment 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.
In addition, the Festo Group has a corporate Whistle-Blowing Policy which is published on Festo’s intranet and includes a hyperlink so employees can send confidential and anonymous emails detailing concerns they have about unethical or unlawful practices. The Festo Group also operates a “Whistle-Blowing Hotline” which provides another confidential channel for all employees to raise concerns they may have about suspected unethical behaviour or other breaches of the Code. The hotline is operated externally and is certified ISO/IEC 27001 compliant. Alternatively, staff can notify suspected breaches either via their Line Manager or the Chief Compliance Officer (“CCO”) via a dedicated email address.
To ensure a sufficient level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, Festo provides modern slavery training to its staff.
Each company within the Festo Group has a recognised Local Compliance Officer (LCO) who ensures the integrity of Festo compliance management and auditing. As part of their responsibilities the LCO ensures that all Corporate Binding Instructions are adhered to and all staff have access to training and information about their responsibilities imposed by the Modern Slavery legislation and the Code. This information and training is provided via a mixture of media platforms including induction programmes, information bulletins, intranet and mandatory training sessions.
Audit and Compliance
The Festo Group has been audited by the Bureau Veritas Certification Germany GmbH and certified as Sedex Members Ethical Trade Audit Four Pillars compliant. The Four Pillars Audit covers labour standards, health and safety, environment and business ethics, overall reflecting best practices for corporate responsibility.
The Festo Group’s Supply Chain
As part of its efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, Festo issues each supplier with the Festo Group’s Supplier Guidelines and the Festo Supplier Code of Conduct (“Supplier Code”).
The Supplier Guideline impresses upon suppliers the need to comply with the Supplier Code and observe the Code. Compliance is overseen by the CCO and any breaches notified are reported to either the Chairman of the Management Board, the Management Board in entirety or the Supervisory Board. The Festo Group has implemented a Compliance Management System which enables it to monitor compliance with the Code. In addition, the Festo Group’s Risk Management and Internal Audit departments work with the CCO to further develop compliance checking systems and keep under review the Code in line with industry best practice.
The Supplier Code is sent to all suppliers and they are asked to respond via Festo’s share point site to confirm they will conform with its requirements which include compliance with Human Rights principals of the International Labour Organisation of the United Nations and a strict prohibition on child and compulsory labour. The Supplier Code also sets out specific requirements designed to protect against sub-standard workplace and environments, and unlawful working conditions as well as providing guidance on bribery and corruption.
In addition, suppliers are required to self assess their compliance with all applicable rules and regulations covering items such as Health and safety, safe working, modern slavery, ISO standards etc. Following self assessment, on site audits are undertaken of the supplier to confirm conformity and address any issues.
Following our review of actions taken by slavery or human trafficking from occurring in its business or supply chains, Festo intends to continue tackling slavery and human trafficking by taking the following steps:
1. Training – we are developing our local compliance network to ensure compliance information is fed to all employees. Employee training programmes are instigated locally so they continue to deliver additional and up to date guidance and support to staff on modern slavery issues.
2. Future regular updates and reminders will be posted via the Festo internal system WeNet and all important communications will continue to be made available on this system.
3. Policy Review – Festo is continuing to keep under review and update when necessary all policies and procedures designed to further drive out slavery and forced labour.
4. The Corporate Social Responsibility department will draft and publish the Corporate Responsibility Report 2018/2019 which identifies additional actions to be taken by the Festo Group which designed to further reduce modern slavery within our own operations and within our supply chains.