Daifuku Logan Ltd (“the Company”) Anti-slavery Statement For The Financial Year 2019
The Company values its reputation for ethical behaviour and financial probity and has a commitment to act professionally, fairly and ethically.
DAIFUKU LOGAN LTD is a member of the DAIFUKU group of companies and is therefore subject to the Daifuku commitments to ethics and sustainable development (including environmental and social responsibilities) as set out in the Daifuku corporate code of conduct and associated documents. The Company has a clear policy to ensure that slavery and human trafficking is not taking part in any of its supply chain and recognises that any such practice would reflect adversely on the Company’s image and reputation and on that of its owners.
This statement is made pursuant to s. 54 of the Modern Slavery Act 2015.
This statement sets out the steps the Company has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within its business or supply chain.
Statement of policy
The Company is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its business. It has a commitment to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere in its business or in its supply chains.
Application of this policy
This Policy applies to the entire DAIFUKU LOGAN LTD organisation.
The Company is a designer, manufacturer, installer and integrator of baggage handling and screening systems to airport customers worldwide and as a consequence it has supply chains in diverse areas of the World. It also works for many large clients in the airports sector who wish to ensure compliance with the Modern Slavery Act 2015 and ethical practices among their preferred baggage handling suppliers.
The Company is therefore committed to creating and maintaining effective systems and controls to safeguard against any form of modern slavery taking place within its business or supply chain.
This Policy will be made known to customers, contractors and suppliers. The Company will encourage the application of this Policy amongst its business partners, including contractors, suppliers, agents and joint venture partners.
Measures to be taken to combat slavery and human trafficking
- The Daifuku corporate code of conduct issued by its shareholder, Daifuku Co., Ltd, states that it and its subsidiary companies aim to achieve “awareness as a global company and compliance with rules and social principles” and that it does so by the implementation of “fair and transparent corporate activities in compliance with relevant laws and social principles, both foreign and domestic, while taking fully into consideration international standards and rules in a global perspective”.
- The Company avoids dealing with contractors and suppliers known or reasonably suspected to be in breach of its anti-slavery policy requirements. It undertakes due diligence, as appropriate, in evaluating prospective contractors and suppliers to ensure that they have effective practices and policies before they are accepted as a supplier or contractor. The Company’s supplier questionnaires have been amended to ensure that this issue is raised with every supplier.
- The Company conducts its procurement practices in a fair and transparent manner. It will continue to comply with its existing Practical Guide to Ethics when dealing with Suppliers which ensures that suppliers are dealt with fairly and transparently but also that in doing so the Company respects laws and regulations, external business practices, company values and internal procedures and that those dealing with suppliers make known and ensure compliance with the Company’s obligations as regards ethics, sustainable development and social responsibility.
- The Company monitors contractors and suppliers as part of its regular review of relationships with them and ensures that its contracts with contractors and suppliers include policies to give the Company a right of termination in the event that they conduct themselves or their business in a manner inconsistent with this Policy. This is achieved by the inclusion in supply contracts and subcontracts of its Ethics and Sustainable Development clause which includes a provision that the subcontractor/supplier shall “refrain from utilising child labour or any form of slavery, servitude, forced or compulsory labour or other similar exploitation in compliance with the International Labour Organisation standards and the provisions of the Modern Slavery Act 2015”.
- The Company’s Whistleblowing Policy ensures that all employees are aware that they can raise concerns with the Company or directly to its shareholder about how the Company’s workers are being treated or practices within its business or supply chain without fear of reprisals.
- Compliance with the aims of this policy will be assured by the Senior Management of the Company and their respective departments.
Internal Controls and Record Keeping
The Company will maintain records of its compliance with this policy and the due diligence it carries out.
Monitoring and Review
Senior management will monitor this Policy and periodically review its suitability, adequacy and effectiveness and implement improvements as appropriate.
This Policy will be communicated to all employees through established internal communication channels.
Training has been developed by the Company for all of its employees to make them aware of the issues surrounding modern slavery and the provisions of the Modern Slavery Act 2015. It explains what practical steps employees can take to protect the supply chain and offers examples of good practice and practical steps to take. This training has been delivered to all Company employees and is given to any new employees joining the Company.
Raising Concerns and Seeking Guidance
Any person with concerns regarding the implementation of this Policy or possible violations of its provisions is encouraged to report those concerns to a member of the senior management of the Company or the Company Solicitor or the HR Manager. Any such report will be treated in confidence and without risk of reprisal.
The Company has in place a whistle-blowing policy which is set out in Appendix 2 of its Employee Handbook.
Approval for this statement
This statement was approved by the Board of Directors of the Company on 26th February 2019.
Daifuku Logan Ltd Fair Processing Notice
This policy explains how personal data that we might collect from you or that you might provide to us is processed by us.
‘Personal Data” means any information provided to us by you which relates to living individuals who can be identified from that information or from that information combined with other details in (or likely to come into) the possession of Daifuku Logan Ltd.
We explain how we deal with information about our employees in a separate Data Protection Policy set out in the Employee Handbook which applies to all of our employees.
Information we may collect from you
We may collect and process the following information about you:
- Information that you provide by filling in forms for us such as job application forms, supplier questionnaires or the contact form on our website;
- Information contained in brochures or quotes or communications submitted to us offering your business or services;
- Information that you provide or which we collect from you for use in delivering our projects such as personal details required for airport security or site passes, work permits or visas, logistics deliveries and shipping and health and safety files;
- Information provided when you correspond with us or visit our premises; and
We will not collect from you any personal data which is not necessary for the purpose for which the information is collected.
We will normally only collect basic personal data about you such as your name, e-mail address, telephone contact numbers, your business type, work address, job title and details of your relevant qualifications or trade credentials. If you are to do work for us in a personal capacity then we will also need details of your bank account and we may require financial references.
We will not normally collect from you any special categories of data such as personal data about your racial or ethnic origin, political opinions, religious beliefs, trade union membership, sexual orientation or information about your health. Where such information is required, this will be done through a confidential process and you will be asked to complete a form of consent telling you exactly what information you must provide, why you must provide it and what we will do with it.
How we may use the information
We will process your personal data:
- If it is necessary for us to perform a contract with you:
– to take steps at your request prior to entering into it;
– to decide whether or not to enter into the contract with you;
– to manage and perform the contract; and
– to update our records or to contact you.
- If it is necessary for our own legitimate interests. For example:
– for good governance, accounting and managing or auditing our business operations;
– to carry out a credit or financial search of you or your business; and
– to send you marketing communications or details of opportunities to do business with us.
- If it is necessary to comply with a legal obligation. For example:
– If you exercise your rights under data protection law and make requests;
– For compliance with legal and regulatory requirements and related disclosures;
– For the establishment and defence of legal rights; and
– To verify your identity and make checks for fraud prevention or anti-money laundering measures.
- Based on your consent. For example:
– If you request us to disclose your personal data to other people or organisations; To send you marketing communications if we have asked for your consent to this; and
– If we issue a press release with news about our business or place a press release or a report about our business on our website or in our brochures and you have consented to this.
We will use the information you provided to us for the purpose for which it was provided to us at the time it was provided. For example, we might use it to respond to your enquiries about employment with us or you may have submitted details of a quotation for work for a particular customer or potential customer of ours which we will forward to the customer or potential customer as part of a bid for project work.
We will not process your personal data for any use other than the purpose for which it was provided unless you have consented to the use or it is necessary for us to comply with a legal obligation.
We will use your information for the purposes of our business. This may be to enter into contracts with you for the use your services or to offer your services to our customers or potential customers in tenders we submit for project work. We will use your personal information to communicate with you about current work or work opportunities and also to pay you for work you do.
Security of your data
Where you have provided your personal details to us because you are a customer or supplier, we may use your contact details to send you news or details about our business and products. If at any time you decide you do not wish to receive such details then please let us know by contacting [email protected].
We have in place in our organisation various different technical and organisational measures to protect the personal data we hold against accidental or unauthorised use, destruction, loss, damage, alteration or disclosure. We use various security programmes and procedures to ensure that unauthorised persons do not have access to the personal data or to any equipment used to process the Personal Data.
We take steps to ensure that our employees, agents, partners and sub-contractors comply with the procedures and policies we have in place whenever they are processing personal data.
Who we will share your information with
- Our employees and others we have employed to carry out services for us. They will only be permitted to use your information for the purpose of carrying out those services for us;
- We may share your information with any member of the Daifuku Group who will use it in accordance with this policy;
- Our legal and professional advisers including our auditors;
- Credit reference agencies or debt collection agencies;
- Government bodies and agencies in the UK or overseas;
- Our insurers where necessary for us to obtain cover for the purposes of our business;
- To customers, potential customers and suppliers both inside and outside the European Economic Area. This will only be done for the purposes of compliance with a contract we have entered into or where we are trying to win business which we consider to be a legitimate interest. We only forward to customers, potential customers and suppliers information which you have provided for that purpose;
- To third parties if we are under a duty to disclose or share the personal data in order to comply with a court order or a legal or regulatory requirement;
- To third parties for the issue of airport security or site passes, visas or work permits or for the carrying out of logistics services or other requirements for the purposes of our business projects:
- To Microsoft and associated companies for the provision of cloud services for our computer servers
We do not collect personal data for dissemination or sale to third parties for marketing purposes.
We do not use your personal data in relation to automated decision making.
Information storage and retention
Once we have received your information it will be stored at our premises in the UK or France and may be entered on our electronic systems. Strict procedures will be used to try to prevent unauthorised access.
The personal data you submit to us will be retained for as long as it is required for the purposes for which it was collected or as required by law.
Our contracts often require us to retain information about subcontractors and their work for a number of years after the work has been completed in case there are any problems. Upon completion of a project all personal data contained in our project files will be archived and securely stored.
We will retain your personal data for as long as you might legally bring claims against us.
Where personal data is retained we do not assume responsibility for verifying the on-going accuracy of the content of the personal data. When practically possible we will request updated information periodically.
Access to information
The Data Protection Legislation gives you the right to access information held about you. To obtain a copy of the personal data we hold about you, please send a written request to the HR Manager, Daifuku Logan Ltd, Sutton Road, Hull, HU70DR, England. This will usually be free of charge and we will respond to you within one month.
The Data Protection Legislation gives you various rights regarding the use of your personal data:
- You have the right to be informed about our processing of your personal data.
- You have the right to make us correct any data we hold which is inaccurate or to make us complete any personal data we hold which is incomplete.
- You have the right to have your personal data erased if it is no longer necessary for us to hold it or if we have no legal grounds for processing your data (the “right to be forgotten”).
- You may also request deletion of your data if it was only being processed as a result of your consent and you withdraw your consent to it.
- You have the right for certain data you provided to us to be provided to you in a structured and commonly used electronic format (eg Microsoft word or excel) so that you can move, copy or transfer this data easily to another data controller and you can request us to transmit this directly to another organisation if it is practical for us to do so.
- You have the right to raise objections to the processing of your personal data, but please note this is not a blanket right to insist that we cease all processing.
- You have the right to restrict the processing of your personal data in certain circumstances such as if you have contested the accuracy of the data or objected to its processing, in which case processing will be restricted until we can verify the accuracy or determine whether our use of it is legitimate.
- The right to request access to any of your personal data that we process.
You can exercise these rights at any time by writing to the HR Manager, Daifuku Logan Ltd, Sutton Road, Hull, HU7 0DR, England. We will advise you of the action we take in response to your request.
How to complain about the use of your data
If you are not happy about the way we are dealing with your personal data you can address your complaint to the Managing Director, Daifuku Logan Ltd, Sutton Road, Hull, HU7 0DR. You also have the right to lodge a complaint with the Information Commissioner for the UK. You can do this by visiting the ICO website on https://ico.org.uk.