Statement

Sims Engineering Systems Limited fully acknowledges its responsibilities in relation to tackling modern slavery and compliance with the provisions in the Modern Slavery Act 2015. The company promotes ethical business practices and policies to protect its workforce. If we identify at any time a specific case of Modern Slavery in the UK, we will take the necessary, immediate action to report this to the correct channels.

Structure and Business and Supply Chains

The company specialises in design and manufacture of automation solutions and special purpose machinery. We work to provide innovative, reliant and efficient solutions to our Tier one and OEM automotive customers and additionally customers within the life sciences industries. The company has been established since 1986 in the UK.

Any products or services are purchased from reputable high-quality industry recognised suppliers on an order, or contract basis, ongoing throughout the year. Sims Engineering Systems Limited regularly communicates with its suppliers throughout the year and due diligence is carried out in relation to its business and supply chains.

The company is committed to providing the very latest advances in technology. All of the services provided are continually monitored and controlled using industry best practice.

Our focus in tackling modern slavery in the last financial year include assessment of risks, monitoring, and training and awareness.

Sims Engineering Systems Ltd is ISO 9001 accredited.

Definitions

Sims Engineering Systems Limited recognises that Modern Slavery is a crime resulting in abhorrent abuse of human rights through human trafficking and forced work compulsory labour and has defined its policies in relation to promote ethical business practices and protection of workers from exploitation and abuse both in their own organisation and global supply chains.

We are aware of the mechanisms that are in place in the UK to assist victims of slavery and human trafficking. If we identify any potential victims of slavery or trafficking then we will refer this matter to the National Referral Mechanism following consent of the victim affected.

Employees

Sims Engineering Limited recruitment and employment process complies with UK Employment law rules and regulations, which are reviewed regularly. All new employees are appropriately checked, due diligence completed and also made aware of our Modern Slavery policies. On an ongoing basis, all employees of the company are remunerated and regularly reviewed in line with this statement. There is an employee code of conduct in place and staff training policies fall within the points covered in this statement.

If during training of our employees, we identify signs of modern slavery we will inform the appropriate bodies in the UK for further guidance and support.

Supply Chain

Internal business procedures are reviewed regularly to ensure that any demands made on suppliers or subcontractors avoid violation of human rights. Such demands include late payments, late orders, high pressure deadlines.

For all company contracts, zero tolerance is built into the contracts for modern slavery through, dialogue, self-assessment, audits, checking of supplier Code of Conducts, training and building of opportunities with suppliers, sub-contractors, customers and other business contracts.

Before engaging with new suppliers, we would assess the risk and level of influence a business may have. Additionally, we would look at the country and sector risks, transactions risks, and any business partnership risks.

Where we can benefit from working with other industry bodies or multi-stakeholder organisations to help support industry-wide labour standards to improve laws and policies, we will always endeavour to do this.

Due Diligence

Due diligence is regularly conducted to ensure that actual and potential human rights are assessed, and any impacts are addressed. Such assessment include level of influence business may have, risk assessment.

If any risks are identified than immediate action would be taken to address any instances found and how these actions can be prioritised to embed respect for human rights. Risks will be investigated in each sector that the business operates and business partnership risks.

Responsibility for this Policy

The company directors are responsible for the implementation and compliance of this policy which is reviewed annually. They ensure that sufficient resource is available to combat any modern slavery either internal to the organisation or within the supply chain.

Performance Indicators

Performance indicators are implemented to include such policies such as:

• purchasing goods and services to avoid modern slavery

• production contract delivery timings so not to increase staff workload pressure

• grievance procedures of staff, suspicions or concerns by staff and reporting

• mechanism

• visibility, leverage and oversight of suppliers in the supply chain

Training

Training on this policy is carried out to raise the necessary awareness and the importance of modern slavery and what people need to do to raise any concerns. If necessary, more bespoke training is provided to particular employee groups.

Communication

The policy is publicly available, both internally and externally

Authorisation

This policy has been authorised for use by Keith Sims Managing Director.

May 2022