The California Transparency in Supply Chains Act requires certain companies manufacturing or selling products in California to disclose their efforts to address the issues of human trafficking and slavery in their supply chain and efforts to eradicate each of these from their supply chain. In accordance with our Code of Conduct and Anti-Bribery and Anti-Corruption Policy, we seek out suppliers that demonstrate the same principles regarding human rights and ethical conduct. With a few exceptions, the products that Accudyne companies purchase from suppliers do not fall in the classes of products that the U.S. Department of Labor has identified in its List of Goods Produced by Child Labor or Force Labor and, to date, Accudyne has not observed activity within its supply chain that would trigger any human trafficking or slavery concern. Accordingly, Accudyne does not consider human trafficking and slavery to be a significant risk for its supply chain. Accudyne companies’ standard purchase order terms require our suppliers to comply with applicable laws and regulations in supplying products to them. Therefore, we do not verify their supply chain or audit suppliers specifically to evaluate risks of human trafficking and slavery or require their suppliers to certify specifically that products supplied to them were not produced with child labor or slave labor. Although Accudyne’s Code of Conduct and Anti-Bribery and Anti-Corruption Policy apply to all Accudyne employees, they do not include any standards specific to human trafficking and slavery and Accudyne does not provide training to its employees on human trafficking and slavery. However, the policies require compliance with the laws, rules and regulations of every country in which Accudyne does business, which would include laws on human trafficking and slave labor. In addition, the policies obligate Accudyne employees to act in every respect with honesty, fairness and integrity. Accudyne employees receive training on the standards and behavior expected of them under these policies.
Accudyne Industries Modern Slavery Statement 2017/18
This statement has been published in accordance with section 54(1) of the Modern Slavery Act 2015. It sets out the steps taken by Accudyne Industries and its subsidiaries and affiliates (Accudyne) to prevent slavery and human trafficking in its business and supply chain.
We recognize that slavery, forced labor and human trafficking is a global and growing issue in every region of the world. Accudyne is committed to protecting our organization and those at risk of exploitation. We are proud of the steps we have taken to raise awareness of slavery and human trafficking and to prevent it in our supply chain and our business.
Accudyne is a global provider of precision-engineered, process-critical and technologically advanced flow control equipment, systems and high efficiency industrial compressors that deliver consistently high performance and give confidence to customers in the critical industries and serve environments around the world. Our business is comprised of industry leading brands, including Sundyne, Milton Roy and Haskel. Accudyne is powered by approximately 2,000 employees at 11 manufacturing facilities, supporting a broad range of customers in more than 150 countries.
Our employees around the globe are provided with our Code of Conduct and undertake mandatory training (in their native language) in relation to our ethics and standards. Our employees play a key role in maintaining high standards. The Code of Ethics gives a clear understanding of our approach to ethics and gives employees tools to play their part. Each employee has a personal responsibility to read the Code of Ethics, as well as ensure they fully understand their obligations and the consequences for failing to meet those obligations. In addition, we have a global EthicsLine, through which employees can anonymously report any concerns regarding ethics and compliance. Employees can access the EthicsLine through an electronic portal or by calling a hotline, both of which are managed by a third-party vendor and are available 24 hour every day. Any reports coming through the EthicsLine are investigated by the Legal Department.
Our Supply Chain
The products that Accudyne companies purchase from suppliers do not generally fall in the classes of products that are believed to be at a high level of risk of being produced by child or forced labor in violation of international standards and, to date, Accudyne has not observed activity within its supply chain that would trigger any human trafficking or slavery concern. Accordingly, Accudyne does not consider human trafficking and slavery to be a significant risk for its supply chain. Accudyne companies™ standard purchase order terms require our suppliers to not only comply with our corporate policies, but also applicable laws and regulations.
Our policies on slavery and human trafficking
Accudyne is committed to good citizenship and believes that engagement with others improves the human condition. For our employees worldwide, Accudyne assures safe and healthy work environments, based on the more stringent of U.S. standards, local standards, or Accudyne policies.
Accudyne has a zero-tolerance policy prohibiting human trafficking-related activities. Pursuant to the policy, forced labor, child labor, commercial sex, involuntary prison labor and slavery shall not be used. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. Accudyne expects its suppliers to abide by this policy and the law and any violation could result in termination of a business relationship and termination of any contracts with Accudyne.
These policies require compliance with the laws, rules and regulations of every country in which Accudyne does business, which would include laws on human trafficking and slave labor. In addition, the policies obligate Accudyne employees to act in every respect with honesty, fairness and integrity.
Plans for the Next Financial Year
Following a review of the effectiveness of the steps we took this year to ensure that here is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking:
- Review the terms and conditions in our procurement contracts globally against best practices gained from suppliers, customers and employees, and where necessary, revise our terms and conditions;
- Assess risk in our supplier base; and
- Provide appropriate training for our employees.
This statement was approved by the board and signed on its behalf by:
Charles L. Treadway President and CEO