Modern Slavery and Human Trafficking Statement 2021
- Our business
- Our high risk areas
- Our policies
- Our suppliers
- Our performance indicators
- Future steps and continued commitment
- Approval for this statement
This is the third statement made by AP Racing with regard to the anti-slavery and human trafficking measures implemented across our business. This statement is for the financial year ending 31st December 2021 and is made pursuant to section 54 of the Modern Slavery Act 2015.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. AP Racing has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
AP Racing is the leading manufacturer of performance brake and clutch systems for road and race cars. The business is part of the Brembo group of companies and we have more than 160 people working in our UK factory. The core areas of the business are the design, manufacture and assembly of clutches, calipers, discs, pads, master cylinders, pedal boxes and air jacks, as well as road and competition brake systems for motorcycles. The primary supply chain includes engineering and manufacturing companies, office services (including the provision of security, catering, office supplies and cleaning), IT and technology, professional services, and business travel. There are more than 150 first tier, (i.e. direct), suppliers in our supply chain.
OUR HIGH RISK AREAS
The majority of risk lies in our supply chain. Whilst the majority of our suppliers are UK-based and supply standard goods or services, we recognise there are areas of potentially higher risk in our suppliers outside of the UK. Suppliers have been risk assessed and categorised taking into account the nature of their business, as well as their country of operation and product and industry characteristics. Suppliers categorised as presenting significant risk of modern slavery are subject to additional due diligence, primarily based on public sources of information including checks of their own modern slavery and human trafficking statements where applicable, and any other published policies and procedures. This risk assessment exercise has been completed in respect of suppliers to our Coventry factory, we continue to have not identified any occurrence of modern slavery within our supply chain.
We have a team that is addressing risks in the area of modern slavery and ensuring that appropriate measures are applied to assess, manage and minimise risk. This team is made up of representatives from Human Resources, Procurement and Quality departments.
As an employer of predominantly professionally qualified and highly skilled people, we consider that the risk of modern slavery within our business remains low. We apply robust policies and procedures concerning employment screening and selection, such as work eligibility checks and employment conditions.
We have adopted our parent company’s, Brembo, Supplier Code of Conduct which applies to our providers of goods and services and sets out the standards we expect them to observe, including in respect of modern slavery risks. Where our standards are not met, suppliers are expected to take and evidence remedial steps to ensure their activities in our supply chain are free from modern slavery.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Supplier Code of Conduct. This policy sets out the supplier responsibilities for expected requirements on human rights, forced labour, human trafficking, health and safety at work, environmental protection and corruption.
- Policy on non-discrimination and diversity. This policy describes the requirements of business partners to establish and maintain an environment free of discrimination.
- Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
- Code of Basic Working Conditions. This code explains the manner in which we behave as an organisation and our expectations of our own business on forced labour, human trafficking, child labour corruption and discrimination.
- Conflict Minerals. This policy ensures that we are not sourcing from our suppliers any parts and products containing tungsten, tantalum, tin and gold, any parts or products sourced must be DRC Conflict-free.
- Anti-slavery and Human Trafficking Policy. This policy describes our commitment to enforcing and reporting the requirements within AP Racing and its interested parties.
AP Racing operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery. Our anti-slavery policy and supplier code of conduct forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. Regular audits of our supply base is conducted by both operational and procedures auditing.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business.
- They hold their own suppliers to account over modern slavery.
- (For UK based suppliers). They pay their employees at least the national minimum wage / national living wage, as appropriate.
- (For international suppliers). They pay their employees any prevailing minimum wage applicable within their country of operations.
- We may terminate the contract at any time should any instances of modern slavery come to light.
We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
OUR PERFORMANCE INDICATORS
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
- No reported occurrences highlighted either internally or externally for year ending 31st December 2021.
FUTURE STEPS AND CONTINUED COMMITMENT
AP racing recognises the importance of maintaining constant vigilance to identify and address any impacts associated with modern slavery and human trafficking throughout its supply chains, and to continuing to enhance its capacity to identify, prevent and mitigate any actual or potential impacts in this field. We will continue to work with our suppliers and interested parties to improve our understanding of their processes and policies in order to prevent modern slavery within their organisations and their supply chains.
We will continue to assess the effectiveness of the measures we take and we will regularly review and refine our policies and procedures in relation to modern slavery and human trafficking.
APPROVAL FOR THIS STATEMENT
This statement was approved by the Directors of AP Racing on 30/06/2022.
David Hamblin (Managing Director)