Human Trafficking and Modern Slavery Policy
Update 23rd June 2025
Contents
1 Purpose and Scope
2 Introduction
3 Risks and Opportunities
4 Document Content
4.1 Supplier and Contractor Standards
4.2 Training and Awareness
4.3 Reporting and Whistleblowing
4.4 Monitoring and Continuous Improvement
4.5 Enforcement and Disciplinary Action
4.6 Governance and Review
5 Sources
6 Related Documents
1 Purpose and Scope
This policy applies to:
• All employees and officers of Paneltex Ltd.
• All temporary workers, contractors, and subcontractors.
• All suppliers, manufacturers, logistics partners, and third parties acting on behalf of Paneltex Ltd.
2 Introduction
At Paneltex Ltd., we are committed to acting ethically and with integrity in all our business dealings. We recognise that modern slavery and human trafficking are significant global issues and that the manufacturing industry is at particular risk due to complex supply chains and labour-intensive operations.
In compliance with the Modern Slavery Act 2015, we are committed to ensuring that slavery and human trafficking are not taking place in our operations or in any part of our supply chain.
3 Risks and Opportunities
We assess risks of modern slavery through:
• Third-party audits where appropriate.
• Onboarding and vetting processes for new suppliers.
Key risk areas for manufacturing include:
• Low-skilled or seasonal labour.
• Outsourced or subcontracted processes.
4 Document Content
4.1 Supplier and Contractor Standards
We expect all suppliers to:
• Comply with the Modern Slavery Act 2015 or equivalent international standards.
• Permit audits and inspections as part of our compliance process.
• Ensure their own suppliers and subcontractors follow ethical practices.
4.2 Training and Awareness
We provide tailored training for:
• Procurement teams, to identify red flags in supplier behaviour.
• HR and recruitment staff, especially for agency or factory-based hiring.
• Site managers and production leads to understand and identify risks on the ground.
• Awareness materials (e.g. posters, toolbox talks) are shared at manufacturing sites to reinforce our zero-tolerance stance.
4.3 Reporting and Whistleblowing
We encourage all employees and stakeholders to report any concerns regarding modern slavery. Reports can be made through:
• Contacting our Whistleblowing Officer, Keith Drake (keith.drake@paneltex.co.uk)
• Direct contact with HR.
All reports are investigated fully, and corrective actions are taken where required.
4.4 Monitoring and Continuous Improvement
We monitor our efforts through:
• Annual modern slavery statement publication.
• Regular policy review and risk reassessments.
We aim to strengthen transparency and ethical practices across all tiers of our supply chain.
4.5 Enforcement and Disciplinary Action
Violations of this policy by employees may lead to disciplinary action up to and including termination. Breaches by suppliers may result in:
• Contract termination.
• Removal from approved supplier lists.
• Referral to law enforcement where appropriate.
4.6 Governance and Review
This policy is overseen by the Board of Directors and is reviewed annually or more frequently if needed. Our Modern Slavery Statement is published each year on our website in accordance with Section 54 of the Modern Slavery Act.
5 Sources
• N/A
6 Related Documents
• N/A
Modern-Slavery and Human Trafficking Statement 2024
Paneltex Ltd. states, in compliance with sec. 54 of the Modern Slavery Act 2015, its enduring commitment to ethical practices and to ensure that neither modern slavery nor human trafficking takes place within the business, its subsidiaries or its supply chain. Paneltex is committed to an ethical, fair and safe business environment and culture, from its own operation down the entire supply chain. For copies of our commercial and ethical policies, please see the website or contact us.
For all Paneltex employees, as well as performing identity checks, we check a range of documents relating to their employment history and ability to work for the business. We have a number of agency staff from various employers and we check and verify that all agencies are appropriately following correct and ethical employment practices.
Paneltex is also committed to ensuring that the ethical treatment of workers throughout our supply chain remains positive and correct. We do this through working together with our ISO9001-approved suppliers and through our system of checks on new suppliers.
There is a copy of this statement, as well as all other Paneltex ethical policies, saved in our internal computer system, with copies available to all Paneltex employees in our QMS or on request to the HR Department.