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At the Britax Group, we are committed to our responsibilities under the Modern Slavery Act 2015. This statement sets out the steps that we have taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
This statement has been published in accordance with the Modern Slavery Act 2015 and constitutes the Group’s slavery and human trafficking statement for the financial year ending 31 December 2022. It sets out the steps taken by Britax Group Limited and other relevant companies controlled by it (the “Group”), including Britax Excelsior Limited, to prevent modern slavery and human trafficking in its business and supply chain.
Slavery, servitude, forced labour and human trafficking (“Modern Slavery”) are global issues. We are committed to ensuring that there is no Modern Slavery in our supply chains or in any part of our business. We act ethically and with integrity in our business relationships and in developing, implementing and enforcing systems and controls to ensure Modern Slavery is not taking place anywhere in our supply chains.
We are a global manufacturer and distributor of children’s car seats, strollers, bicycle seats, nursery products and related accessories. Our parent company on 31 December 2022 was Persimmon Midco LLC, a Delaware limited liability company, with its head office in South Carolina. On 31 December 2022, the Group had approximately 602 employees worldwide and carried out manufacturing operations in the UK, USA and Germany with sales and marketing operations in North America, South America, Europe, Asia, Australia and New Zealand. The Group’s global annual turnover during the year to 31 December 2022 was approximately €282.9m. Turnover for Britax Excelsior Limited was (subject to audit) approximately £18.9m. We are organised in regional business units (Americas, EMEA and Asia-Pacific regions) and our supply chains include raw materials suppliers and contract manufacturers.
We are committed to ensuring that there is no Modern Slavery in our supply chains or in any part of our business.
We act ethically and with integrity in our business relationships and in implementing and enforcing systems and controls to ensure Modern Slavery is not taking place anywhere in our supply chain.
Under our global and regional codes of conduct we:
We also operate a whistleblowing policy which provides a framework within which individuals can openly or anonymously report any ethical concerns, including issues in connection with Modern Slavery. Any issues raised are handled at a senior level, brought to the attention of the board of directors and thoroughly investigated. Any necessary actions are taken. The anonymity of whistle-blowers is protected. No Modern Slavery concerns were reported during the financial year.
We operate a supply chain which includes suppliers we have worked with, visited and inspected over a number of years. We know that Modern Slavery can be most prevalent in the parts of a supply chain operating in certain high risk geographic areas and among vulnerable groups. Therefore, before new suppliers are added, we carry out an approval and accreditation process. A key area of this process, before approving and adding any new supplier to our supply chains, involves an assessment of that supplier’s labour practices, including practices in relation to child or forced labour, payment of a minimum wage, employee working environments and protection against discrimination.
We have in place and/or are continuing to develop further systems to identify and assess potential risk areas in our supply chains, mitigate the risk of Modern Slavery occurring in our supply chains and monitor potential risk areas. During 2020, the global Britax business joined Sedex, one of the world’s leading ethical trade membership organisations, working with businesses to improve working conditions in global supply chains. During 2022, Sedex membership helped to further enhance our due diligence process.
During 2022, the Group’s ongoing employee training programme, provided by a specialist third-party service provider, continued. The training programme includes specific compulsory courses covering the Modern Slavery Act 2015, practical steps for procurement teams and raising of awareness of Modern Slavery risks and issues with integrated assessments to measure awareness and understanding of key issues, risk indicators and necessary actions. Increased employee awareness and training should help to further enhance our due diligence process and the effectiveness of our Modern Slavery measures.
We continue to review contractual arrangements and develop strategic business relationships with suppliers in key parts of our supply chains to help ensure that necessary standards are in place, and maintained, to prevent Modern Slavery in our supply chains.
We have a zero-tolerance policy towards Modern Slavery. As part of the steps taken to ensure all those in our supply chains and our contractors comply with our values and ethics we continue to operate a supply chain compliance programme. This includes visits by sourcing, quality and engineering teams, a periodic scorecard process and periodic visits by the Group’s general counsel. However, as a result of the global COVID-19 pandemic and travel and other restrictions, intended to limit the spread of the virus, imposed by governments around the world, periodic visits remained suspended during 2022 and our ability to further develop our supply chain was adversely affected. Following the relaxation of COVID-19 related travel restrictions during 2023, we now expect the frequency of visits to supply chain partners to increase during 2023.
In order to assess the effectiveness of our Modern Slavery measures we review the following key performance indicators:
We continue to periodically review the effectiveness of existing steps we have taken with a view to maintaining and further improving our effectiveness in assessing and addressing issues and risks which are relevant to the prevention of Modern Slavery in our business and supply chains. This will continue during 2023.
This statement was approved by the board of directors of Britax Group Limited on 26 June 2023 and will be reviewed and updated annually.
Michael Pacharis Chief Executive Officer Britax Group Limited
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