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Eberspächer (UK) Limited – Anti-Slavery Statement for the Financial Year ending 31 December 2019

This statement refers to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps that Eberspächer (UK) has taken to ensure that slavery and human trafficking is not taking place in our supply chain or in any part of our business.

Organisation

Eberspächer (UK) is a wholly owned subsidiary of Eberspächer Climate Control Systems GmbH of Germany. The Eberspächer Group is one of the world´s leading system developers and suppliers of exhaust technology and climate control systems. Eberspächer is also a professional innovation partner for the automotive industry in air conditioning of special-purpose vehicles and in automotive electronics.

Supply Chain Overview

The Eberspächer (UK) supply chain can be complicated. There can be more than 4 levels of suppliers between final manufacture and the source of raw materials that enter the manufacturing process. The breadth and depth of the supply chain make it challenging to effectively manage business and sustainability issues. Respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility. As responsible customers, however, we play an active role in supplier development and have adopted various means to clearly communicate our expectations to our suppliers.

A significant proportion of our materials are sourced from the Eberspächer group of companies so are controlled under the Eberspächer Code of Conduct.

Policies

Our Anti Slavery Policy is available on request.

Our Code of Conduct outlines in one document the fundamentals for legal and regulatory compliance as well as moral and ethical behaviour while conducting business and working together within the Eberspächer Group.

https://www.eberspaecher.com/fileadmin/data/corporatesite/pdf/en/Code_of_conduct_EN_Screen.pdf

Eberspächer imposes a special Business Partner Code of Conduct upon its business partners. This contains references to strict compliance with human rights of their employees and their business partners.

https://www.eberspaecher.com/fileadmin/data/corporatesite/pdf/en/Businesspartner_Code_of_Conduct_EN_Screen.pdf

Due Diligence

  • Our Terms and Conditions forbid any form of modern slavery as defined in the Modern Slavery Act 2015 this includes but not limited to; the use of forced labour, human trafficking exploitation of children, debt bondage and physically abusive disciplinary practices. We reserve the right to terminate our relationship with a supplier if issues of noncompliance with our policies are discovered and/or noncompliance is not addressed in a timely manner.
  • We assess risk related to human trafficking and forced labour associated with our supply base. Our preliminary assessment is based upon geography, the commodity purchased. Eberspächer (UK) Ltd performs this risk assessment with input from external stakeholders.
  • We inform our employees through printed material and electronic communication about the signs of slavery and human trafficking and what they suspect slavery or human trafficking.
  • We conduct assessments of key suppliers to monitor compliance with Eberspächer (UK) Ltd expectations and legal requirements. If any issues are identified during an assessment or an audit, the supplier is required to prepare a corrective action plan and resolve all violations within an agreed upon time period.

December 2019