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Slavery and Human Trafficking

PROMOTING ANTI-SLAVERY AND HUMAN TRAFFICKING PRACTICES AT HAVEN PRODUCTS:
A MODERN SLAVERY STATEMENT

Haven Products Ltd operates in the UK and is a wholly owned subsidiary of Momentum Scotland, which in turn is a subsidiary of Rehab Group, an international charitable organisation headquartered in Ireland.


THIS IS A DRAFT STATEMENT PENDING APPROVAL BY THE MOMENTUM SCOTLAND BOARD.

Modern slavery encompasses forced labour, slavery, servitude, and human trafficking. We also recognise that it can encompass a variety of forms of exploitation of individuals.

Haven Products is committed to the principles and objectives of the Modern Slavery Act 2015. In line with our core values and our commitment to Human Rights, we would never knowingly conduct business with any organisation involved in any form of slavery or human trafficking.

[The Board of Momentum Scotland have examined the potential for modern slavery within its business and supply chains]. This statement sets out the steps that Haven Products has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within, or associated with, our operations.

We support and promote within our operations, adherence to the Ethical Trading Initiative (ETI) Base Code. Clause 1 of the code states that employment must be freely chosen, with no forced, bonded or involuntary labour.

Haven Products stringently checks that all of its employees have the right to work in the UK and are paid at or above the statutory minimum wage. Where we contract to use the services of agency workers, we ensure that they are subject to the same checks.

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include our recruitment and whistleblowing policies and our Procurement Policy which excludes on mandatory grounds any tender where there is an established link to child labour or human trafficking related offences. We also operate a Code of Conduct for all employees which enshrines, for everyone that works for us, the importance of representing and upholding our organisation values and ethical behaviours.

Haven Products reviews its entire operations, including the supply chain, on an ongoing basis to assess any non-compliance to human trafficking and slavery standards. Haven Products is assured that there is no evidence of slavery and human trafficking within its own operations and those of its suppliers and contractors. We consider the ongoing risk to be low but nevertheless remain vigilant to the potential of discovering breaches to the Modern Slavery Act and are prepared respond promptly in such an eventuality.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015, [is approved by the Momentum Scotland Board] and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2019.