Environmental
Reabrook Ltd is committed to the effective management of environmental issues as an integral and fundamental part of the Company’s business activities.

It is the policy of Reabrook Ltd to take all reasonable precautions to prevent environmental issues from arising and to protect people, premises and surrounding areas from foreseeable environmental impacts.

It is also the company’s policy to ensure that products are developed to meet the latest environmental legislation and minimize their impact on the environment.

The Reabrook Board is ultimately responsible for all environmental matters within the Company.

Manufacturing
Reabrook Ltd fully recognises its responsibility to:

• Comply with all applicable legal and other requirements to which the organization subscribes that relate to its environmental aspects as a minimum, and by adopting industry best practice where technically and economically practicable.
• Provide suitable and sufficient training and instruction, to enable employees to perform their work in a manner that does not give rise to environmental issues.
• Conduct regular audits to verify the effectiveness of the environmental management system.
• Seek continual improvements in environmental performance and prevention of pollution, through annual objectives and programmes.

Employee Responsibility
Employees have a responsibility to co-operate with the Company:

• By adhering to Company policy and procedures.
• By working safely and efficiently in the manner to which they have been trained, so as to not give rise to environmental incidents.
• By reporting all incidents, accidents and near misses that have led to or may lead to damage to the environment, using the company reporting procedure.
• By assisting in the investigation of environmental incidents and near-misses with the objective of introducing measures to prevent their recurrence.
• By promptly raising any questions and concerns on environmental matters with their immediate supervisor and/or safety representative.

Full details of the organisational arrangements and the procedures currently in operation at Reabrook Ltd for managing environmental issues, are available from the company’s Safety, Health and Environment Manager.

As part of our commitment to the environment Reabrook signed a contract to support The National Forest’s latest five-year development in Boothorpe. This sponsorship agreement saw a total of 42,000 trees planted at The National Forest’s Boothorpe site, which also include parkland, grasslands and wetlands. Now this project has been completed, we are now supporting individual projects across The National Forest.

The National Forest area covers 200 square miles of the counties of Leicestershire, Derbyshire and Staffordshire. The objective is to increase the woodland cover from an initial six per cent to about a third. We chose to support the local organisation not only due to the central location of our 16-acre manufacturing site, but also because the local scheme will allow our employees to engage in the project directly thus learning about the impact they can have on the local area.

We have invested a lot of time in identifying our carbon footprint and we are actively working to reduce our consumption. We are focused on sustainable development in order to meet the needs of the present, without compromising future generations.

Organisation Structure and Principal Activities
This statement comprises the slavery and human trafficking statement of Reabrook Limited (the ‘Company’). The Company is not currently required to make this statement as required in the Modern Slavery Act 2015 but does so as if this did apply. The Company is a manufacturer of aerosol and liquid based products with focus on the personal care, automotive and industrial markets. The Company currently employs approx. 200 employees. The company has a permanent presence in the UK, selling products to many countries around the world.

Please see our statement here: Slavery & Human Trafficking Statement

Our Policies on Slavery and Human Trafficking
We are committed to ensuring that there is no slavery or human trafficking in our supply
chains or in any part of our business. The Company has committed to uphold the base code of the Ethical Trading Initiative (ETI) and is a registered member of Sedex, a not for profit organisation dedicated to driving improvements in ethical and responsible business practices in global supply chains.

Supply Chains
We have a zero tolerance to slavery and human trafficking. We expect all those in our chain and contractors to comply with our policy. The Reabrook Supplier Assessment Questionnaire incorporates questions relating to ethical trade in respect of their employees. The Company will not support or deal with any business knowingly involved in slavery or human trafficking. The Company sources the majority of its supply chain in Europe and America.

Plans for the future
We will ensure, through audits that providers of contract labour follow the highest standards of monitoring to ensure that they are not knowingly involved in practices associated with slavery or human trafficking

The Company is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The Company will not tolerate any form of bribery by or of, its employees, agents or consultants or any person or body acting on its behalf. Senior management is committed to implementing effective measures to prevent, monitor and eliminate bribery.

The Company is committed to complying with the Bribery Act 2010 in its business activities in the UK and overseas.

All employees and any temporary workers, consultants, contractors, agents or person or body acting on behalf of the Company (“associated persons”) are required to comply with this policy.

What is a bribe?
A bribe is a financial or other type of advantage that is offered or requested with the:

• Intention of inducing or rewarding improper performance of a function or activity;
• Knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity.

A relevant function or activity includes public, state or business activities or any activity performed in the course of a person’s employment, or on behalf of another company or individual, where the person performing that activity is expected to perform it in good faith, impartially, or in accordance with a position of trust.

A criminal offence will be committed under the Bribery Act 2010 if:

• an employee or associated person acting for, or on behalf of, the Company offers, promises, gives, requests, receives or agrees to receive bribes;
• An employee or associated person acting for, or on behalf of, the Company offers, promises or gives a bribe to a foreign public official with the intention of influencing that official in the performance of his/her duties (where local law does not permit or require such influence);
• The Company does not have the defence that it has adequate procedures in place to prevent bribery by its employees or associated persons.

What is prohibited?
The Company prohibits employees or associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be made to ensure that a person or company improperly performs duties or functions (for example, by not acting impartially or in good faith or in accordance with their position of trust) to gain any commercial, contractual or regulatory advantage for the Company in either obtaining or maintaining Company business, or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.

Employees and associated persons conducting business on behalf of the Company outside the UK may be at greater risk of being exposed to bribery or unethical business conduct than UK-based employees. Employees and associated persons owe a duty to the Company to be extra vigilant when conducting international business.

Records
All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts may be kept “off the record” to facilitate or conceal improper payments.

Facilitation Payments
The Company prohibits its employees or associated persons from making or accepting any facilitation payments. These are payments made to government officials for carrying out or speeding up routine procedures. They are more common overseas. Facilitation payments are distinct from an official, publicly available fast-track process. Facilitation payments constitute bribes and may not be made at any time irrespective of prevailing business customs in certain territories.

Corporate Entertainment, Gifts, Hospitality and Promotional Expenditure
The Company permits corporate entertainment, gifts, hospitality and promotional expenditure that are undertaken:

• For the purpose of establishing or maintaining good business relationships;
• To improve the image and reputation of the Company;
• To present the Company’s goods/services effectively;

Provided that it is:

• Arranged in good faith, and
• Not offered, promised or accepted to secure an advantage for the Company or any of its employees or associated persons or to influence the impartiality of the recipient.

The Company will authorise only reasonable, appropriate and proportionate entertainment and promotional expenditure. Any gifts, rewards or entertainment received or offered from clients, public officials, suppliers or other business contacts should be reported immediately to the Managing Director. If an employee or associated person wishes to provide gifts to suppliers, clients or other business contacts, prior written approval from the Managing Director is required, together with details of the intended recipients, reasons for the gift and business objective. These will be authorised only in limited circumstances.

Employees and, where applicable, associated persons must supply records and receipts, in accordance with the Company’s expenses policy.

This policy does not prohibit:

• Normal and appropriate hospitality and entertainment with clients (please see the Company’s expenses policy); and
• The use of any recognized fast-track process that is publicly available on payment of a fee.
• Any such practices must be proportionate, reasonable and made in good faith. Clear records must be kept.

Risk Management
The Company has established detailed risk management procedures to prevent, detect and prohibit bribery. The Company will conduct risk assessments for each of its key business activities on a regular basis and, where relevant, will identify employees or officers of the Company who are in positions where they may be exposed to bribery.

The Company will identify high-risk areas, for example projects undertaken in high-risk countries, tenders for work and those working on high-value projects.

The Company will:

• Regularly monitor “at risk” employees and associated persons;
• Regularly communicate with “at risk” employees and associated persons;
• Undertake extensive due diligence of third parties and associated persons; and
• Communicate its zero-tolerance approach to bribery to third parties, including actual and prospective customers, suppliers and joint-venture partners.

Charitable and Political Donations
The Company considers that charitable giving can form part of its wider commitment and responsibility to the community. The Company supports many charities that are selected in accordance with objective criteria, following a risk assessment. The Company may also support fundraising events involving employees.

Reporting Suspected Bribery
The Company depends on its employees and associated persons to ensure that the highest standards of ethical conduct are maintained in all its business dealings. Employees and associated persons are required to cooperate with the Company’s risk management procedures and to report suspicions of bribery to the Managing Director. While any suspicious circumstances should be reported, employees and associated persons are required particularly to report:

• Any suspected or actual attempts at bribery;
• Concerns that other employees or associated persons may be being bribed;
• Concerns that other employees or associated persons may be bribing third parties, such as clients or government officials;
• Close family, personal or business ties that a prospective agent, representative or joint-venture partner may have with government or corporate officials, directors or employees;
• A history of corruption in the country in which the business is being undertaken;
• Requests for cash payments;
• Requests for unusual payment arrangements, for example via a third party;
• Requests for reimbursements of unsubstantiated or unusual expenses; or
• A lack of standard invoices and proper financial practices.

If an employee or associated person is in any doubt as to whether a potential act constitutes bribery, the matter should be referred to the Managing Director. Employees should report in writing any instances of suspected bribery to the Managing Director. Any such reports will be thoroughly and promptly investigated by the Managing Director in the strictest confidence. Employees and associated persons will be required to assist in any investigation into possible or suspected bribery.

Employees will also be required to comply with the Company’s whistle-blowing policy. Employees or associated persons who report instances of bribery in good faith will be supported by the Company. The Company will ensure that the individual is not subjected to detrimental treatment because of his/her report.

The Company will fully investigate any instances of alleged or suspected bribery. The Company will invoke its disciplinary procedures where any employee is suspected of bribery, and proven allegations may result in a finding of gross misconduct and immediate dismissal. The Company may terminate the contracts of any associated persons, including consultants or other workers who act for, or on behalf of, the Company who are found to have breached this policy.

The Company may also report any matter to the relevant authorities, including the Director of Public Prosecutions, Serious Fraud Office, Revenue and Customs Prosecutions Office and the police. The Company will provide all necessary assistance to the relevant authorities in any subsequent prosecution.

Review of Procedures and Training
The Company will regularly communicate its anti-bribery measures to employees and associated persons. The Company will set up training sessions where applicable. The Managing Director is responsible for the implementation of this policy.

The Managing Director will monitor and review the implementation of this policy and related procedures on a regular basis, including reviews of internal financial systems, expenses, corporate hospitality, gifts and entertainment policies. Employees and those working for or on behalf of, the Company are encouraged to contact the Managing Director with any suggestions, comments or feedback that they may have on how these procedures may be improved.

Reabrook Ltd is an Equal Opportunities employer. The Company commits itself to promote and develop equal opportunities and will keep under review its policies, procedures and practises to ensure that they accord with the principles of equal opportunities and are consistently applied.

The Company recognises that discrimination is unacceptable and it is in the Company’s own best interest, as well as the interests of its employees, to utilise the skills of the total workforce.

The aim of the Equal Opportunities Policy is to ensure that no present or future employee or job applicant receives less favourable treatment on the grounds of race, colour, creed, religion, ethnic or national origin, nationality, sex, marital status, disability, age, sexuality, sexual orientation or social status, or is disadvantaged by any conditions or requirements which cannot be shown as necessary.

In the promotion of the policy we will endeavour to meet the full statutory requirements relating to Equal Opportunities.

All staff of the Company will accept personal responsibility for practical application of the policy. Responsibility for its implementation will rest with the Managing Director.

Monitoring
The Company will create and maintain employment records in order to monitor the progress of this policy. This will involve the collection and classification of information regarding the ethnic origin, gender and disability of all current employees in line with current Data Protection legislation. This information may be passed to government agencies or may be collated and provided to auditing bodies. Your identity will not be revealed.

Recruitment
The purpose of the company’s Recruitment and Selection Procedure is to ensure that highest standards of recruitment and selection practice are followed in the recruitment and promotion of employees. Line Managers shall notify the HR Department of recruitment needs at the earliest opportunity.

Applications
All internal and external applications will be reviewed by Department Manager and HR. Selection of candidates will be made for interview based on suitability in comparison with Job Description and person specification. It is the responsibility of the Department Manager and HR to ensure that the selection of candidates for interview complies with the Company’s Equal Opportunities Policy. There shall be no discrimination on the grounds race, colour, creed, religion, ethnic or national origin, nationality, sex, marital status, disability, age, sexuality, sexual orientation or social status. All candidates will receive a written response to their application within a 4-week time period.

Recruitment and Selection
The intention of the recruitment procedure is to ensure the most appropriate response to any vacancy in the Company. The Company wishes to ensure the highest quality of candidates and will advertise the vacancies within the organisation. Jobs will be advertised via job centres, careers service, local press and use appropriate external vacancy advertising outlets. The selection process is of crucial importance and must therefore be carried out according to objective, job related criteria. The effectiveness of the policy will be determined to a great extent by this aspect of the employment procedure. The Company will endeavour through appropriate training to ensure that employees making selection decisions will not discriminate in making these decisions.

Proof of Identity
To comply with the Asylum and Immigration Act 1996 the Company must obtain evidence from new employees of their right to work in the UK. This evidence will normally consist of a current passport. If they are unable to provide a passport the Company will need to see an original birth certificate showing the name of at least one parent, plus one other form of identification showing a National Insurance number. All documentation must be produced on their first day of employment.

Training and Promotion
All steps will be taken to ensure equal access to opportunities for training and promotion. The Company will endeavour to provide appropriate training to enable staff to perform their jobs efficiently and pursue career development opportunities.

Training and guidance will be given to members and senior staff of the Company to increase awareness of their role in implementation of the policy. Training and guidance in appropriate techniques will be provided for staff involved in recruitment and selection.