Modern Slavery Statement
This is statement made pursuant to section 54(1) of the Modern Slavery Act 2015. The
statement summarises the steps RLC (UK) Limited has taken during the financial year
ending 30th June 2020 to ensure slavery and human trafficking is not taking place in any
part of its own business or supply chain.
RLC (UK) Limited considers that modern slavery and human trafficking as an
intolerable crime and a violation of fundamental human rights and fully supports the
principles of the UK Modern Slavery Act of 2015.
Our Organisation
RLC (UK) Limited is a world leader in the precision aerospace engineering business,
supplying into the military and civil markets in the United Kingdom, United States,
Europe and Asia. The RLC (UK) Limited portfolio includes engines and airframe
components. The labour supplied to the organisation in pursuance of its operation is
carried out in United Kingdom.
RLC (UK) Limited is a privately owned company that elects to embrace public
company standards of corporate governance and is controlled by a board of directors.
The board consists of the Chairman, Chief Executive Officer, Director who is also the
Company Secretary. Reporting to the Chief Executive Officer is the Operations
General Manager for RLC (UK) Limited.
Commitment
RLC (UK) Limited acknowledges its responsibilities in relation to tackling modern
slavery and has a zero-tolerance approach to modern slavery. We are committed to
acting ethically and with integrity in all our business dealings and relationships and to
implementing and enforcing effective systems and controls to ensure modern slavery is
not taking place anywhere in our own business or in any of our supply chains. RLC
(UK) Limited is also committed to ensuring there is transparency in our own business
and in our approach to tackling modern slavery throughout our supply chains, consistent
with our disclosure obligations under the Modern Slavery Act 2015.
The Company understands that this requires an ongoing review of both its internal
practices in relation to its labour force and, additionally, its supply chains. The
Company does not enter 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. No labour provided to the Company in the pursuance of the provisions of its own
services is obtained by means of slavery or human trafficking. The Company strictly
adheres to the minimum standards required in relation to its responsibilities under the relevant employment legislation in the United Kingdom and in many cases exceed those minimums in relation to its employees.
Supplier Code of Conduct
RLC (UK) Limited carries out due diligence in relation to ensuring slavery and/or
human trafficking does not take place in its Company or supply chain. The Company
has not, to its knowledge, conducted any business with another organisation which has
been found to have involved itself with modern slavery. The Company is now
prioritising activities on how we undertake a review of our suppliers including audits of
people processes and constituent parts.
The RLC Supplier Code of Conduct, as issued by the Parent Company clearly
communicates to our suppliers that RLC is committed to conducting business fairly,
impartially, and in full compliance with all applicable laws and regulations; and with
the requirements of the US FAR 52.220 and the UK Modern Slavery Act 2015.
The RLC Supplier Code of Conduct confirms that we will not engage with or tolerate
from itself, its Suppliers or the suppliers supply chain slavery, servitude or forced
compulsory labour; trafficking or in persons or procuring commercial sex acts and we
do not accept child labour or any practice that inhibits the development of children.
Therefore, no persons under the age of lawful employment (as stipulated in any law to
which the Supplier is subject) shall be employed by the Company or its Suppliers.
Additionally, each Supplier is required to specify a minimum standard of human rights
that applies across all jurisdictions and demonstrate how compliance to this is
encouraged and observed. Such standards should refer to, at a minimum, the UN
Guiding Principles on Business and Human Rights.
To be an approved supplier, all suppliers must review and return to the Company, a
signed copy of the Supplier Code of Conduct and confirming that it complies with its
requirements.
Due Diligence
In accordance with section 54(4) of the Modern Slavery Act 2015, the Company has
taken the following steps to ensure that modern slavery is not taking place:
• Communication of the Company’s Anti-slavery and Human Trafficking policy to all its
employees.
• Employee able to access to all Company policies through an internal intranet.
• Training of all employees to embed a zero tolerance towards modern slavery and
human trafficking.
• A confidential whistle blowing helpline is available to all employees and suppliers to
raise concerns.
Risk Assessment
We have assessed the risk of modern slavery taking place in the Company’s business
during the year. Our HR processes are developed to reduce the risk of modern slavery
and human trafficking; we have robust recruitment and selection procedures that ensure
we only engage with reputable employment agencies to source labour and ensure all new employees, both permanent, temporary, direct hire or through a third party attend a formal induction programme. We believe our processes and controls are robust and
therefore the risk of modern slavery occurring within the Company’s direct and
contractor population are minimal.
Our Policies
Integrity is one of our core values and that reinforces our high standards of ethical
conduct in our Company and expect the same commitment from our suppliers,
contractors, and other business partners. The Company has the following policies
which further define our position on modern slavery:
Ethics and Business Conduct Policy
RLC is committed to upholding the highest standards of business conduct and
ethical behaviour. This policy requires all persons working for RLC or on its
behalf in any capacity, including employees, directors and from those who act
on behalf of RLC those who must comply with this policy to act with integrity
and honesty in all business dealings and comply with all laws and regulations
wherever RLC operates or transacts its business.
Code of Conduct Policy
The RLC Code of Conduct applies to all employees, in all roles, at all levels and
locations. This policy sets our commitment that all business is conducted fairly,
impartially, and in full compliance with all applicable laws and regulations. We
are firmly committed to integrity, honesty, and respect for others in all our
business relationships, including those with customers, suppliers, communities
where we conduct our business, and amongst employees. The highest standard
of ethical behaviour is expected from RLC employees, directors and those who
act on RLC’s behalf in the performance of their professional responsibilities and
in their own personal conduct.
Whistleblowing Policy
RLC is committed to conducting it business in accordance with its Ethics and
Business Conduct policy and Code of Conduct. To create a culture of openness
and accountability, our Whistleblowing policy enables all employees to report
suspected wrongdoing in the knowledge their concerns will be taken seriously
and investigated appropriately and that their confidentiality will be respected.
Employees have access to an external helpline, operated by an independent
service provider to enable employees to raise concerns anonymously and in
confidence. Disclosures are reported to the Parent Company who is responsible
for ensuring calls are investigated independently.
Responsible Officer
The Company has a Responsible Officer, the Company Secretary, to whom all concerns
regarding modern slavery should be addressed, and who will then undertake relevant
action regarding the Company’s obligations.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015
and will be reviewed for each financial year.
Approved by the Board of Directors of RLC (UK) Limited
And signed by a director on its behalf on 07 April 2021