Modern Slavery Act


Summit Windows


May 2017


This statement is made by Summit Windows in pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act") and constitutes its slavery and human trafficking statement.


1. Organisation’s Structure


2. Our Policies relating to Slavery & Human Trafficking


We expect high standards from those we work with and are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. Please click here to see our Anti-Slavery Policy.


3. Our Due Diligence processes in relation to slavery and human trafficking in our business and supply chains


Our procurement process includes vetting new suppliers and carrying out a risk analysis based on the nature and value of the product or service.


Our suppliers are expected to comply with all relevant legislation and we ask for information about:


Monitoring of tier 1 and 2 supply chains for unfair practices; Policies on fair sourcing of goods and services; Employment practices such as advertising vacancies, work/life balance; Training for staff; Diversity data; Corporate Social Responsibility; Willingness to share our values.


Supplier responses are taken into consideration when short-listing and we make any concerns known to the supplier.


4. The parts of our business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk


Whilst the majority of our materials are sourced from the UK, we do obtain some items from countries such as China. In such instances, we audit the supplier’s business and obtain confirmation that they understand and adhere to our policy on slavery & human trafficking. We expect our partners to ensure their goods, materials and labour are fully compliant with the Modern Slavery Act 2015 and that they are transparent, accountable & auditable.


5. Our effectiveness in ensuring that slavery and human trafficking is not taking place in our business.


We use the following KPI’s to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:


Communication & personal contact with next link in the supply chain, ensuring their compliance with our expectations Use of payroll systems and labour monitoring Completing supplier audits – we aim to audit our top 50 suppliers in year 1, the remaining suppliers in year 2 and suppliers of suppliers in year 3.


6. Training about slavery and human trafficking available to our staff.


We will be providing new training to staff involved in recruiting and sourcing/managing a supply chain so that they are able to identify risk factors, understand the implications and assist us with implementing the Anti-Slavery Policy effectively. Our staff have all been briefed on the subject.


Sean Gleeson


© All rights reserved. May, 2017.